Privacy Policy

Updated: 3/10/2023

Please read this Privacy Policy (“Policy”) carefully before using the Services. Campendium, Inc. (“Campendium,” “we,” “our,” or “us”) (an affiliate of TH2connect, LLC d/b/a Roadpass Digital) respects your privacy and is committed to protecting it through our compliance with this Policy. This Policy explains how we collect, process, use, store and disclose your Personal Data, as well as your rights associated with that data. Campendium operates in countries with differing requirements for data protection. This Policy is written for the broadest application to Campendium’s practices. Specific differences for California (US) will be highlighted in the section on “Your Rights.” Please also use the Glossary at the end of the document to understand the meaning of some of the terms used in this Policy.

Who we are
Principles
The data we collect about you
How we collect your Personal Data
Why we collect your Personal Data
Marketing
Change of purpose
How we share your Personal Data
Choices about how we use and disclose your information
International transfers
Your rights
Security of your Personal Data
How long will we use your Personal Data for?
Contact Details
Changes to the Privacy Policy and your duty to inform us of changes
Glossary

1. Who we are

We strive to improve the camping experience through innovative products, services, and technologies, including mobile applications and premium membership benefits. We respect your privacy and we

believe you should be informed about what Personal Data we may collect when you interact with us. This Policy applies to Personal Data collected by us unless an exception applies. This Policy tells you about what information we may collect and how we may process, share, and use it. Please read this Policy carefully.

When we reference our “Service” or “Services”, we mean technologies, capabilities, features, applications, websites, social media pages which reference this Policy, and other products and services, and communication channels we may provide (including but not limited to the Campendium website and mobile application).

This Policy does not apply to: (a) any services that have a separate privacy policy which does not incorporate this Policy; or (b) third-party cookies, products or services (including websites, mobile applications, platform features, app stores, and applications), all of which are governed by their own respective privacy policies (even if our Services contain them, use them, or link to them). We are not responsible for third-party privacy practices.

Note: You have a choice as to whether you want to share Personal Data with us. If you choose not to provide us with certain information, we may not be able to offer you certain Services, you may not be able to access certain features of our Services, or our Services may not function properly or at all.

2. Principles

Basic Principles. The Policy adheres to the GAPP privacy principles, based on internationally known fair information practices, included in many privacy laws and regulations under which Campendium or its parent companies may operate. The GAPP principles are as follows:

Principle	Description
Management	Campendium will define, document, communicate, and assign accountability for its privacy policies and procedures.
Notice	Campendium will provide individuals with required notice in a timely manner where required and identify the purposes for which Personal Data is controlled or Processed.
Choice and consent	Campendium will provide individuals with any required choices regarding the Processing of their Personal Data.
Collection	Campendium will collect Personal Data only for legitimate business purposes.
Use, retention, and disposal (Purpose Limitation)	Campendium will limit the use of Personal Data to the purposes identified in the notice and for which the individual has provided implicit or explicit consent, as required by law. Campendium will only retain Personal Data for as long as necessary to fulfill the stated purposes as required by law or regulation and thereafter appropriately dispose of such Personal Data.
Access	Campendium will provide a mechanism to allow individuals to access and correct their Personal Data, when required by applicable regulation.
Disclosure to third parties (Onward Transfers)	Campendium will disclose Personal Data to third parties only for the purposes identified in the notice and with the implicit or explicit consent of the individual in accordance with regulatory requirements.
Safeguarding (Security)	When Processing Personal Data, Campendium will protect it from unauthorized access (both logical and physical).
Quality (Data Integrity)	Campendium will maintain accurate, complete, and relevant Personal Data for the purposes identified in the notice.
Monitoring and enforcement	Campendium will monitor compliance with its privacy policies and procedures and have procedures to address privacy-related complaints and disputes.

3. The data we collect about you

Types of Personal Data. This Policy applies to information we previously collected, currently collect, or may collect in the future. We may collect, use, store and transfer different kinds of Personal Data about you, which we have grouped together as follows:

Identity Data includes first name, last name, username, photographs, videos or similar identifiers.
Contact Data includes address, telephone numbers and email address.
Location Data includes location information obtained from smartphones, tablets or other devices that monitor your current and previous geographic locations.
Financial Data includes payment card details (through our third party payment processor).
Profile Data includes your username and password, purchases or orders made by you, and your interests and preferences.
Transaction Data includes details of payments to and from you and other details of Services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services (through our third party service providers such as Google Analytics).
Usage Data includes information about how you use our Services, including date and time of usage, and the content of API and other service requests.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data, which may be derived from your Personal Data but is not Personal Data as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our Services. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat that combined data as Personal Data which will be used in accordance with this Policy.

Sensitive Data. We do not collect any Sensitive Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, criminal convictions and offences, information about your health and genetic and biometric data).

Children under 18 Years of Age. Our Services are designed to enhance the travel experience. We do not market our Services towards consumers under the age of 18. We do not knowingly collect Personal Data from children under 18 years of age. No one under age 18 may provide any information to or on our Services. If you are under 18, do not use or provide any information through our Services or their respective features. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us.

Consent to Policy. Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Policy. You do not have to provide your Personal Data when we request it, but if you choose not to, we may not be able to respond to your queries and perform any contract we have or are trying to enter into with you. That may mean we have to cancel a Service you have with us. We will notify you at the time if that is the case.

4. How we collect your Personal Data

We use different methods to collect Personal Data from and about you including through:

Direct Interactions. You may give us your Identity, Contact, Profile, Financial, and other data by filling in forms on our Services, on third-party websites, applications, or services, or in paper form or by corresponding with us by post, phone, email or otherwise. That includes Personal Data you provide when you:

Make an inquiry with us or otherwise apply for any of our Services;
Purchase a Service from us;
Create or use an account on our Services;
Send or receive messages through our Services;
Subscribe to our Services or publications;
Request marketing to be sent to you;
Enter a competition, promotion or survey in connection with our Services (including on third- party social media platforms);
Give us feedback; and
Speak to us on the telephone.

Automated Technologies or Interactions. As you interact with our Services, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns through our third party service providers such as Google Analytics, including:

Details of your usage of our Services, including traffic data, location data, logs and other communication data and the resources that you access and use in connection with our Services; and
Information about your device and internet connection, including your IP address, operating system, and browser type.

We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We may combine Technical Data (some of which will be anonymous) with other Personal Data we have collected from you in order to understand and measure your online experiences and determine what products, promotions and services are likely to be of most interest to you.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on your device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website or other Services.
Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons. Certain parts of our websites, emails, and Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited specific pages or opened an email and for other related statistics (for example, recording the popularity of certain Services content and verifying system and server integrity).
API. We automatically collect and/or process certain information, including Technical Data, limited Location Data and Usage Data, whenever requests are made to an API connected to our Services. If you are an end user of a product or service that integrates our Services, your privacy options will be largely determined by the developer of the product or services. In addition to any privacy options that the developer may have provided you, you may also be able to control the applications that can collect information about your location by using the settings available on your device.

We may tie automatically collected information to Personal Data about you that we collect from other sources or you provide to us.

Third Parties or Publicly Available Sources. We may receive Personal Data about you from various third parties including our affiliates, customers, business partners, and certain public and technical sources:

Technical Data from analytics providers such as Google and advertising networks such as Facebook.
Identity and Contact Data from data brokers or aggregators such as Facebook, from third-party business partners, and from publicly available sources such as phone directories, membership lists, and professional and trade associations.
Identity, Contact and Profile Data from our business partners that use our application(s) to provide, research, improve, and market our Services.

Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on our Services are served by or integrated with third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. The marketing and analytics services that integrate directly into our Services include Google Analytics.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the “Choices About How We Use and Disclose Your Information” section of this Policy.

The Services are affiliated with CMI Marketing, Inc., d/b/a CafeMedia (“CafeMedia”) for the purposes of placing advertising on the Services. CafeMedia will collect and use certain data for advertising purposes. To learn more about CafeMedia’s data usage, click here: https://www.cafemedia.com/publisher- advertising-privacy-policy. The Services also utilize Google Analytics as a third party service provider. Google uses cookies to serve ads on the Services. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to the Services or other web sites on the internet.

By using the site from which you linked, you consent to the use of such cookies and the sharing of data captured by such cookies with CafeMedia, Google, and the Service’s other third party partners. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com.

You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page. You can also opt out of the network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org.

Third Party Links. The Services may contain links to other websites or applications (“Linked Sites”) that are not owned by us. We do not control the collection or use of any information, including Personal Data, which occurs while you visit Linked Sites. Therefore, we make no representations or warranties for —and will not in any way be liable for—any content, products, services, software, or other materials available on Linked Sites, even if one or more pages of the Linked Site are framed within a page of the Services. Furthermore, we make no representations or warranties about the privacy policies or practices of the Linked Sites, and we are not responsible for the privacy practices of those Linked Sites. We encourage you to be aware of when you leave the Services and read the privacy policies of Linked Sites.**

Unsolicited Personal Data. If we receive Personal Data that we have taken no active steps to collect (such as a job application sent to us by an individual on their own initiative, rather than in response to an advertisement), then we may keep that Personal Data if it is reasonably necessary for one or more of our functions or activities. We will destroy it or ensure it is de-identified, provided it is lawful and reasonable to do so.

5. Why we collect your Personal Data

Purpose/Activity	Type of data	Lawful basis for processing
New customers: To provide, administer, protect, and enhance our Services, to enhance user experiences, and to develop new services	(a) Identity (b) Contact (c) Profile	Performance of a contract with you
Provide services: To provide our Services to you, including: register your account(s) and purchased subscriptions and Services, and to provide customer support (including assisting you with your account and solving other problems you may experience) respond to your inquiries, to help you solve problems you may be experiencing, and provide support regarding your account and our Services	(a) Identity (b) Contact (c) Profile (d) Financial (e) Transaction (f) Marketing and Communications (g) Technical (h) Location (i) Usage	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
Relationship management: To manage our relationship including: inform you about changes or enhancements to our Services and changes to our Services, terms of use, and policies asking you to leave a review or take a survey keeping you up to date with our latest news	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services)
Improve Services: To constantly improve our Services, tailor them to your needs, develop new Service ideas and inform you of any changes to our Services To conduct and facilitate market research (including surveys, data analytics, market research, financial analysis, and customer segmentation) To engage in ad retargeting and evaluation of the effectiveness of marketing efforts	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Technical (f) Location (g) Usage	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep developing and improving our Services in line with customer expectations)
Promotions/ Advertisements: To communicate about, promote, and administer our Services, events, programs, and promotions (including sending marketing communications, promotional materials, notices, alerts, newsletters and conducting sweepstakes and contests)	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our Services, to develop them and grow our business)
Technical maintenance: To administer and protect our business, content, websites and mobile apps including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and monitoring for unauthorized use To maintain and promote the safety and security of our Services, our IT network, and our employees	(a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications (f) Transaction (g) Location	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud) (b) Necessary to comply with a legal obligation (c) Performance of a contract with you
Data analytics: To perform data analysis to: improve and personalize your experience on our platforms	(a) Technical (b) Usage (c) Identity	Necessary for our legitimate interests (to define types of customers for our Services, to keep our website updated and relevant, to develop our
improve our Services, marketing, customer relationships and experiences	(d) Profile (e) Marketing and Communications	business and to inform our marketing strategy)
Promote our Services: To provide you with information and ads about third party offers, merchants, attractions, locations, and Services which may be nearby or which otherwise may be of interest to you To conduct marketing and sales activities (including lead generation, pursuit of marketing prospects, market research, managing and evaluating the effectiveness of advertising and marketing efforts, and managing our brands)	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) Location	Necessary for our legitimate interests (to develop our Services and grow our business)
Safety and security: To verify your identity and to protect against unauthorized transactions, fraud, and other unlawful activity, claims and other liabilities, and to manage risk exposure and quality.	(a) Identity (b) Contact (c) Technical (d) Usage	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to maintain the safety and security of our Services and users)
Other: To carry out our obligations and enforce our rights arising from any contracts entered into between you and us (including for billing and collection); to conduct investigations; to comply with and enforce applicable legal obligations, relevant industry standards, other contractual obligations, and our terms, policies and procedures; to fulfill any other purpose for which you provide it or for which you give consent.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Transaction	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation

5. Marketing

We aim to provide you with choices about how your Personal Data is used for marketing and advertising purposes.

You will only receive marketing communications (including newsletters, marketing or promotional materials, or other information that may be of interest to you) from us if you have opted in or consented to receiving those communications. We may use your Personal Data collected in those circumstances to contact you and keep you up to date with the latest news, events, special offers and promotions of our brands, including by email, text messages, or push notifications. We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. This may include email communications, push notifications, and other notifications.

If you do not want us to use your information in this way, please follow the instructions in the “Choices About How We Use and Disclose Your Information” section of this Policy under “Promotional Offers from us.”

You can update your subscription preferences or unsubscribe from marketing communications at any time by following the update preferences or unsubscribe instructions provided in each such communication, or alternatively by following the instructions in the “Choices About How We Use and Disclose Your Information” section of this Policy under “Promotional Offers from Us.”

Please be aware that although you may opt-out of update messages and/or direct marketing communications, we reserve the right to email you administrative notices regarding the Services, as permitted under the CAN-SPAM Act.

We may display advertising for you to see on third-party websites. We do this by matching information about your activity on Campendium’s Services with information collected on third-party sites or services. That may involve using your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

7. Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider we need to use it for another reason compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the contact information provided below. If we need to use your Personal Data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. How we share your Personal Data

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may share your Personal Data with the following parties for the purposes set out in the table in Section 5 above or for other purposes directly related to the purpose for which the information was collected.

Affiliates. When consistent with the purposes set forth in the policy, we may share Personal Data with affiliates, including entities within the Roadpass Digital Group of Companies (including TH2connect, LLC d/b/a Roadpass Digital, Togo Tech, LLC, Roadtrippers LLC, RV Friend Network, LLC d/b/a RVillage) and their divisions (including Togo RV and Overnight RV Parking). The other affiliates that make up the Roadpass Digital Group of Companies are contractually bound to keep Personal Data confidential, to maintain adequate safeguards, and use it only for the purposes for which we disclose it to them or to comply with legal requirements.

Service Providers (Data Processors). We may also share Personal Data with contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them, providing services on our behalf, including:

Payment processing;
Data processing;
Customer support;
IT and system administration;
Marketing, market research, and communication; and
Price comparison service;
Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, consultants, insurers and recruiters.

Merger or Acquisition. We may also share Personal Data with other third parties in the following circumstances:

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data we hold is among the assets transferred.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners or newly associated companies may use your Personal Data in the same way as set out in Policy:

Other entities in the same or similar industries to us, for reasons of public safety;
Where the law requires or authorizes us to do so;
To fulfill any purpose for which you provide it or for which you give consent; and
Other third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. For more information, see the “Choices About How We Use and Disclose Your Information” section below.

Law Enforcement, Safety and Legal Processes. We may also disclose your Personal Data:

With regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances and/or where disclosure is required by law; and
To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
To enforce or apply our Terms of Use and other agreements; and
If we believe disclosure is necessary or appropriate to detect, prevent, or otherwise address threats to our Services or to protect the rights, property, or safety of Campendium, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

9. Choices about how we use and disclose your information

We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of our Services may then be inaccessible or not function properly.
Promotional Offers from Us. If you do not wish to have your contact information used by us to promote our Services or third parties’ products or services, you can opt out by sending us an email stating your request to the contact information provided below. If we have sent you a promotional email, you may opt out by clicking the relevant unsubscribe link in the email or by sending us a return email asking to be omitted from future email distributions.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by sending us an email stating your request to the contact information provided below.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website: http://www.networkadvertising.org/managing/opt\_out.asp.

10. International transfers

We process your Personal Data primarily in the United States. Therefore, we may transfer your Personal Data outside of the country where you live to the United States. If we transfer your Personal Data outside of the country where you live, we will take all reasonable steps to ensure the Personal Data we transfer is secured by an adequate level of data protection during and after your Personal Data is transferred.

11. Your rights

Depending on your jurisdiction, you may have the following rights in relation to your Personal Data. Your California Privacy Rights (applicable to California residents)

Access (California Civil Code Section § 1798.110)

Because we collect consumer information, a California consumer can request the following from us in a portable, readily usable format that allows you to transmit your information to another entity without hindrance:

The categories of Personal Data we have collected about that consumer.
The categories of sources from which the Personal Data is collected.
The business or commercial purpose for collecting Personal Data.
The categories of third parties with whom we share Personal Data.
The specific pieces of Personal Data we have collected about that consumer.

Access (California Civil Code Section § 1798.115)

Because we disclose consumer information to 3rd Parties, a California consumer can request that we disclose:

The categories of Personal Data that we have collected about the consumer.
The categories of Personal Data that we have sold about the consumer and the categories of third parties to whom the Personal Data was sold, by category or categories of Personal Data for each third party to whom the Personal Data was sold.
The categories of Personal Data that we have disclosed about the consumer for a business purpose.

Deletion (California Civil Code Section § 1798.105)

Because we collect consumer information, a California consumer can request that we delete any Personal Data we have collected about them to the extent permitted by applicable laws or regulations. This right is referred to as the right to deletion.

Non-Discrimination (California Civil Code Section § 1798.125)

We will not discriminate against a consumer because the consumer exercised any of their consumer’s rights.

Submitting Requests (California Civil Code Section § 1798.130)**

We provide the following methods for making these requests:

E-Mail: privacy@roadpass.com
Traditional Mail: Campendium, Attn: Privacy, 601 E Beardsley Ave, Elkhart, IN 46514
Please indicate what kind of request you are making (e.g., “Opt-Out,” “Access to categories of Personal Data collected) in your initial communication. This will help us process your request more efficiently.
No fee usually required: You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. If we choose to deny your request, we will inform you of the decision and your right to complain to the supervisory authority within the one-month deadline.
What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure that Personal Data is not disclosed to any person who has no right to receive it.
Time limit to respond: We respond to all legitimate requests without undue delay. Occasionally, if your request is particularly complex or you have made a number of requests, we may need to extend this, in which case we will notify you and keep you updated.

12. Security of your Personal Data

We have implemented measures designed to secure your Personal Data from accidental

loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All Financial Data is handled directly by our third-party PCI-certified payment providers, Stripe (and any information you provide to them is governed by their privacy policy). Your Financial Data is encrypted and transmitted directly and securely to Stripe via HTTPS, and is not stored on our systems.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to or from our Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures provided in connection with any of our Services.

In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

13. How long will we use your Personal Data for?

We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means and the applicable legal requirements.

14. Contact Details

Data Protection Officer. We have appointed a data protection officer (DPO) who is responsible for overseeing privacy issues for Campendium. If you have any questions or complaints about this Policy, including any requests to exercise your rights in relation to your Personal Data, please contact the DPO using the details set out below.

Name: Josh Knepfle

Email address: privacy@roadpass.com

Postal Address: 131 E McMicken Ave, Cincinnati, OH 45202

Your concerns will be addressed promptly, in a manner consistent with our Privacy Principles.

15. Changes to the Privacy Policy and your duty to inform us of changes

We reserve the right to update and change this Policy at any time by posting changes on this webpage, applicable mobile apps or via other channels that we think are suitable. It is our policy to post any changes we make to this Policy on this page with a notice that this Policy has been updated on the applicable Service. The date this Policy was last revised is identified at the top of the page.

You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Policy on the applicable Service to check for any changes. Please keep us informed if your Personal Data changes during your relationship with us.

Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

16. Glossary

Comply with a legal or regulatory obligation means processing your Personal Data where that is necessary for compliance with one of more of our legal or regulatory obligations.

Data Controller means whomever determines the purposes and means of processing Personal Data.

Legitimate Interest means our interests in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where that is necessary under a contract with you or to take steps at your request before entering into such a contract.

Personal Data means any information about an individual that can be used to identify that person directly or indirectly by reference to a range of identifiers. It does not include anonymous data where the identity of the individual has been removed.

Processing means any operation or set of operations performed on Personal Data.

Processor means the entity that processes Personal Data on behalf of the controller.