PRIVACY STATEMENT FOR CEA PASSPORT USERS
CEA Passport is developed and operated through third-party software that allows CEA Study Abroad to create Content and conduct Challenges online. This Privacy Policy applies to all the products, services and websites offered by Influitive Corporation and its subsidiaries and affiliates, except where otherwise noted. We refer to those products, services and websites collectively as the “Services” in this policy. Some Services have supplementary privacy statements that explain in more detail our specific privacy practices in relation to them. Additionally, CEA Study Abroad has Privacy Policies and Services Terms of Use that apply to all CEA Study Abroad services, including CEA Passport.
Content is administered by CEA Study Abroad. CEA Study Abroad uploads Content in their Hub, including but not limited to challenges, surveys, referrals, testimonials, stories, and other contests each day using Influitive’s Services (collectively, “Challenges” or the “Content”). Influitive hosts the Content on its websites and collects the responses that you, as a CEA Passport User, submit to CEA Study Abroad. If you have any questions about a Challenge you are taking or any Content that is uploaded in a Hub you are visiting, please contact CEA Study Abroad directly as Influitive is not responsible for the content in the Hub, the Challenges or your responses to it.
We don’t sell your responses to third parties. Influitive doesn’t sell or share your Challenge responses with third party advertisers or marketers, nor does CEA Study Abroad. Influitive merely acts as a custodian on behalf of CEA Study Abroad who controls your data, except as further described in this Privacy Policy with regard to public Content.
If you think a Challenge or any content in a specific Hub violates Influitive’s Terms of Service or may be engaging in illegal activity, please contact Influitive via email at privacy@influitive.com.
1. What information does Influitive collect?
When you respond to a Challenge hosted by Influitive, Influitive collects, on behalf and upon instructions (including the ones provided in this Privacy Policy) of CEA Study Abroad, information relating to you and your use of Influitive Services from a variety of sources. These are listed below. The sections afterward describe what Influitive does with this information.
Information we collect directly from you
Challenge responses. Influitive collects and stores the Challenge responses that you submit. CEA Study Abroad is responsible for this data and manages it. A Challenge may ask you to provide personal information or data. If you have any questions about a Challenge you are taking, please contact CEA Study Abroad directly at alumni@ceastudyabroad.com as Influitive is not responsible for the content.
Are your Content responses anonymous? It depends on how each individual Challenge has been configured. For applicable challenges, you, the CEA Passport User, will see “public” or “private” indicated within said Challenge. Responding to a challenge listed as “public” will make your response or answer visible to other CEA Passport users. A challenge listed as “private” indicates that your responses will not be visible to other CEA Passport users and will only be collected for CEA Study Abroad purposes. CEA Study Abroad can ensure that responses will be anonymous if the challenge is marked as “private.” However, even if CEA Study Abroad has marked a challenge as “private”, specific questions in the Challenge may still ask you for your personal information or data that could be used to identify you by CEA Study Abroad.
Information we collect about you from other sources
Registration information. When you register as a CEA Passport User to visit the Hub, Influitive collects your username and password.
Usage data. Influitive collects usage data about you whenever you interact with their Services. This may include which webpages you visit, what you click on, when you performed those actions, and so on. Additionally, as with most websites today, Influitive’s web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on Influitive’s site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps. Note that Influitive does not link this usage data to your Challenge responses.
Device data. Influitive collects data from the device and application you use to access their Services, such as your IP address, operating system version, device type, system and performance information, and browser type. Influitive may also infer your geographic location based on your IP address. Your IP address will be linked to your Content responses unless CEA Study Abroad has disabled IP address collection for the Content you respond to.
Referral data. Influitive records information about the source that referred you to a Content (e.g. a link on a website or in an email).
Information from page tags. Influitive uses third-party tracking Services that employ cookies and page tags to collect aggregated and anonymized data about visitors to their websites. This data includes usage and user statistics.
Your email address. If CEA Study Abroad uses an email invitation collector to send you a Challenge invitation email, Influitive collects your email address when CEA Study Abroad provides it to Influitive. Influitive doesn’t use this to send you email except at the direction of CEA Study Abroad. The emails Influitive sends on behalf of CEA Study Abroad appear to come from CEA Study Abroad’s email address. If you no longer want to be contacted by CEA Study Abroad, please contact CEA Study Abroad directly at alumni@ceastudyabroad.com.
Providing Content responses is voluntary. Remember, you can always choose not to provide an answer to any given Challenge (especially those requesting your personal information or data). However, this may prevent you from completing a Challenge if CEA Study Abroad has marked that question as requiring an answer. Failure to complete required challenges could make you ineligible for continued program participation, reward redemption, etc.
2. How does Influitive use the information they collect?
Your responses are owned and managed by CEA Study Abroad, and Influitive treats that information as private to CEA Study Abroad. Please contact CEA Study Abroad directly to understand how they will use your responses. Influitive does not sell Content responses to third parties and does not use any contact details collected from customers to contact CEA Passport Users.
Influitive also uses the information they collect from you (including usage data, device data, referral data and information from page tags) to manage and improve Influitive Services, for research purposes, etc.
3. With whom do we share or disclose your information?
Influitive does not sell your responses. Influitive will share your Challenge responses with third parties only as described in this Privacy Policy.
Influitive discloses:
Your responses to CEA Study Abroad. Influitive hosts Content for CEA Study Abroad, but CEA Study Abroad is the primary curator of Content Data. Anything you expressly disclose in your responses will, naturally, be provided to CEA Study Abroad. Please contact CEA Study Abroad directly at alumni@ceastudyabroad.com to understand how they might share your Content responses.
4. What are your rights to your information?
Contact CEA Study Abroad to access and correct your responses and personal information. Because Influitive collects responses on behalf of CEA Study Abroad, you will need to contact CEA Study Abroad if you have any questions about the Content, or if you want to access, update, or delete anything in your responses. Influitive provides CEA Study Abroad with tools to maintain the responses they collect through their Challenges. You may request access to and correction of the personal information Influitive holds about you by contacting customer support, but in most cases Influitive cannot provide you with this access since responses are CEA Study Abroad’s private information and giving you access may have an unreasonable impact on the privacy of other individuals. Influitive will respond to your request for access or correction within a reasonable time and, where reasonable and practicable to do so, Influitive will provide access to your personal information in the manner requested by you.
Opt out of receiving Content. You may opt out of receiving email invitations to take Challenges which are sent by CEA Study Abroad via Influitive.
5. Security, cookies and other important information
Changes to this Privacy Policy. CEA Study Abroad may modify this Privacy Policy at any time, but if they do so, they will notify you by publishing the changes on this website. If CEA Study Abroad determines the changes are material, they will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email or in another conspicuous manner reasonably designed to notify you. If, after being informed of the changes, you continue to use CEA Passport beyond the advance-notice period, you will be considered as having expressly consented to the changes in this Privacy Policy. If you disagree with the terms of this Privacy Policy or any updated Privacy Policy, you may close your account (if you have one) at any time or not respond to a Challenge.
Security. Details about Influitive’s security practices are available in Influitive’s Security Statement. Influitive is committed to handling your personal information and data with integrity and care. However, regardless of the security protections and precautions Influitive undertakes, there is always a risk that your personal data may be viewed and used by unauthorized third parties as a result of collecting and transmitting your data through the Internet. If you have any questions about the security of your personal information, contact Influitive customer support.
Data locations. Influitive’s servers are based in the United States, so your personal information will be hosted and processed by Influitive in the United States.
Cookies. Influitive, CEA Study Abroad, and their respective partners use cookies and similar technologies on their websites. Cookies are small bits of data Influitive stores on the device you use to access Influitive Services so they can recognize repeat users. Each cookie expires after a certain period of time, depending on what Influitive uses it for. Influitive uses cookies and similar technologies for several reasons:
To make CEA Passport easier to use. If you use the “Remember me” feature when you sign into your account, Influitive may store your username in a cookie to make it quicker for you to sign in whenever you return to Influitive.
For security reasons. Influitive uses cookies to authenticate your identity, such as confirming whether you are currently logged into CEA Passport.
To provide you with personalized content. Influitive may store user preferences, such as your default language, in cookies to personalize the content you see. Influitive also uses cookies to ensure that users can’t retake certain Challenges that they have already completed.
To improve our Services. Influitive uses cookies to measure your usage of Influitive websites and track referral data, as well as to occasionally display different versions of content to you. This information helps Influitive to develop and improve CEA Passport and optimize the content that is displayed to users.
Influitive doesn’t believe cookies are sinister, but you can still choose to remove or disable cookies via your browser. Refer to your web browser’s configuration documentation to learn how to do this. Please note that doing this may adversely impact your ability to use CEA Passport. Enabling cookies ensures a smoother experience when using CEA Passport. By using CEA Passport, and agreeing to this Privacy Policy, you expressly consent to the use of cookies as described in this policy.
Blogs and Forums. CEA Passport may offer publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by other CEA Passport Users. Neither CEA Study Abroad nor Influitive are responsible for any personal information you choose to submit in these areas of CEA Passport. To request removal of your personal information from the CEA Passport blog or community forum, contact CEA Study Abroad directly at alumni@ceastudyabroad.com. In some cases, CEA Study Abroad may not be able to fulfill your request and they will let you know why.
Online Tracking. Influitive currently does not process or comply with any web browser’s “do not track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit Influitive websites or use their Services (unless otherwise stated in a service-specific privacy statement).
Social Media Features. CEA Passport may include social media features or widgets, such as the Facebook Like button. Use of these features may allow these third parties to collect your IP address, detect which page you are visiting on CEA Passport, and set a cookie to enable the feature to function properly. Your interactions with these features are governed by the Privacy Policy of the third party providing it.
Safety of Minors and COPPA. Influitive Services are not intended for and may not be used by minors. “Minors” are individuals under the age of majority in their place of residence (or under 13 in the United States). Influitive does not knowingly collect personal data from minors or allow them to register. If it comes to Influitive’s attention that they have collected personal data from a minor, they may delete this information without notice. If you have reason to believe that this has occurred, please contact Influitive customer support.
6. Additional information for European Union users
Influitive provides some of its Services to users in the EU.
“Personal data”. For users located in the EU, references to “personal information” in this policy are equivalent to what is commonly referred to as “personal data” in the EU.
About IP addresses. Influitive servers record the incoming IP addresses of visitors to Influitive websites (whether or not the visitor has an Influitive account) and store the IP addresses in log files. Influitive uses these log files for purposes such as system administration and maintenance, record keeping, tracking referring web sites, inferring your location, and security purposes (e.g. controlling abuse, spam and DDOS attacks). Influitive also stores IP addresses along with certain actions you take on their system. IP addresses are only linked to Content responses if CEA Study Abroad has configured a Challenge to collect IP addresses. By agreeing to this Privacy Policy, you expressly consent to Influitive using your IP address for the foregoing purposes. If you wish to opt out from the foregoing consent to use your IP address, you must cancel your account (if you have one) or not respond to a Challenge if requested to do so.
Data controller. Influitive is the data controller for registration, billing and other account information that they collect from users in the EU. However, the data controller for Content Data is CEA Study Abroad. CEA Study Abroad determines how their Content questions and responses are used and disclosed. Influitive only processes such Content Data in accordance with the instructions and permissions (including those given under this Privacy Policy) selected by CEA Study Abroad when they create and administer their Content.
Accessing and correcting your personal data. You have the right to access and correct the personal information that Influitive holds about you. This right may be exercised by contacting Influitive customer support.
Right to be Forgotten. Influitive is committed to taking reasonable steps to ensure that any personal information requests to be forgotten can be erased in a reasonable time of the request. However, this doesn’t apply to information that you have made public by posting on CEA Passport forums, blogs, or have made available to third parties yourself since once made public, it falls beyond the reach of what Influitive can erase. Influitive will do everything possible to erase any personal information you may have given them for marketing purposes if you withdraw your consent (opt out) from receiving information from Influitive and request the right to be forgotten.
Data Export Request. Under GDPR you have the right to receive an exported file of the personal data Influitive holds about you, including any data you have provided Influitive. You can also request that this data be changed, updated or removed. This does not include any data Influitive is obliged to keep for administration, legal or security purposes.
Consents. By clicking “I Agree” or any other button indicating your acceptance of this Privacy Policy, you expressly consent to the following:
You consent to the collection, use, disclosure and processing of your personal data in the manner described in this Privacy Policy, including Influitive’s procedures relating to cookies, IP addresses and log files.
Influitive’s servers are based in the United States, so your personal data will be primarily processed by Influitive in the United States. You consent to the transfer and processing of your personal data in the United States by Influitive Corporation and their various affiliates and service providers.
You consent and agree that Influitive may transfer your data to data processors located in the United States. Your consent is voluntary, and you may revoke your consent by opting out at any time. Please note that if you opt-out, Influitive may no longer be able to provide you their Services.
You consent to Influitive sharing your personal data with relevant persons working for service providers who assist Influitive to provide their Services.
If you have enabled cookies on your web browser, you consent to Influitive’s use of cookies as described in this Privacy Policy.
7. California Residents
The California Consumer Privacy Act requires businesses to disclose whether they sell Personal Data. As a “service provider” covered by the CCPA, Influitive does not sell Personal Data. Influitive may share Personal Data with third parties or allow them to collect Personal Data from their sites or Services if those third parties are authorized service providers or business partners who have agreed to Influitive’s contractual limitations as to their retention, use, and disclosure of such Personal Data, or if you use Influitive’s SaaS products (i.e. CEA Passport) or services to interact with third parties (CEA Passport Users) or direct Influitive to disclose your Personal Data to third parties.
California law requires that Influitive detail the categories of Personal Data that they share or disclose for certain “business purposes,” such as disclosures to service providers that assist Influitive with securing their services or marketing their products. Influitive discloses the following categories of Personal Data for their business purposes:
Identifiers;
Commercial information;
Internet activity information;
Financial information;
Professional and employment-related information;
Education information; and
Inferences drawn from any of the above information categories.
California law grants state residents certain rights, including the rights to access specific types of Personal Data, to learn how Influitive processes Personal Data, to request deletion of Personal Data, and not to be discriminated against or denied goods or services for exercising these rights.
If you are a California resident under the age of 18 and have registered for an account with CEA Passport, you may ask Influitive to remove content or information that you have posted to CEA Passport. Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another user.
If you are a CEA Passport User or visitor wishing to exercise your rights as a resident of California, please contact Influitive at privacy@influitive.com.
Influitive may need to verify your identity and place of residence before completing your rights request.
Questions and Requests
Influitive is committed to responding to reasonable requests to review any of your personal information or content they may have and to amend, correct, or delete any inaccuracies. To have your information amended, corrected, or deleted, or if you have any questions that weren’t answered in this Data Privacy Policy, you can contact Influitive at Influitive, 111 Peter Street, 4th floor, Toronto, ON M5v 2H1, Canada or email Influitive at privacy@influitive.com.