Campus To Market (CTM) — Privacy Policy
Version v1.1 — October 2026
This Privacy Policy explains how January News Inc. ("January," "we," "us," or "our") collects, uses, and discloses information in connection with Campus To Market ("CTM"). This Policy is written to reflect current CTM use, which is focused on students located in the United States, including California residents. If CTM later serves individuals located outside the United States, this Policy will need to be updated to address additional legal frameworks (e.g., GDPR) before that use begins.
1. Our Role: Platform Provider vs. Data Controller
For Ambassador personal data, the Company Customer running the ambassador program generally acts as the party determining why and how that data is used, and January acts as a service provider processing that data on the Company Customer's behalf. This Policy describes our data practices across CTM generally; a Company Customer's own policies may also apply to its Ambassadors.
2. Information We Collect
2.1. Information Ambassadors Provide
This subsection applies only to individuals participating in an ambassador program. If you are a Company Customer admin, see 2.2 instead.
Name, email address, phone number, school/campus, and year of study; application information (year, interests, content style preferences, motivation, social media handles); profile information (photo, bio); content submitted through the app (photos, videos, written posts, links); messages sent through in-app messaging with Company Customer teams and campus channels.
2.2. Information Company Customer Admins Provide
This subsection applies only to admin console users. If you are an Ambassador, see 2.1 instead.
Name, email address, and role information for admin console access.
2.3. Information Collected Automatically
Device and usage information (app version, general usage activity); location information, only when an Ambassador completes a location-based task (e.g., campus check-in), and only with device-level permission granted by the Ambassador.
When someone opens an ambassador's January referral link on campustomarket.com, we set a first-party cookie (ctm_rsid: HttpOnly, Secure, SameSite=Lax, about 30 days) so we can count unique qualified scans rather than unique people. We may also store an HMAC of the visitor's IP address keyed by a server-only secret; we do not store the raw IP. The cookie is used for scan uniqueness. The hashed IP is a soft signal for abuse review and App Store Connect reconciliation. If the IP-hash secret is not configured, no IP hash is stored.
3. How We Use Information
To operate and provide the Service, including account creation, application review, and task/content workflows; to calculate and display referral attribution, performance metrics, and leaderboards; to communicate with users, including application status, task assignments, and support; to maintain the security and integrity of the Service; to comply with legal obligations.
4. How Information Is Shared
4.1. With the Applicable Company Customer
This subsection describes what happens to Ambassador information. It does not apply to Company Customer admin information, which is not shared in this way.
An Ambassador's information is shared with the Company Customer running the program they applied to or joined.
4.2. With Service Providers
We share information with third-party service providers who help us operate CTM, including: Supabase (database and authentication hosting), Vercel (application hosting), Resend (transactional email delivery), and Brandfetch (school logo lookup). These providers are authorized to use information only as necessary to provide services to us.
4.3. Legal Requirements
We may disclose information if required to do so by law, or in good faith belief that such action is necessary to comply with legal process, protect our rights, or protect the safety of users or the public.
4.4. We Do Not Sell Personal Information
January does not sell Ambassadors' or admins' personal information to third parties.
5. Data Retention
We retain personal information for as long as necessary to provide the Service, comply with legal obligations, resolve disputes, and enforce our agreements.
6. Data Security
We implement reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, or misuse. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
7. Your Choices and Rights
You may update certain account information directly within CTM. Depending on your state of residence, you may have additional rights regarding your personal information, such as the right to request access to, correction of, or deletion of your information. To exercise these rights, contact us using the information in Section 11.
7A. Your California Privacy Rights
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), as amended, including the right to know what personal information we collect and how it is used, the right to request deletion of your personal information, and the right to non-discrimination for exercising these rights. January does not sell or share personal information as defined under the CCPA. To exercise your California privacy rights, contact us at privacy@campustomarket.com.
8. Children's Privacy
CTM is not directed to, and is not intended for use by, individuals under 18 years of age. We do not knowingly collect personal information from individuals under 18. If we become aware that we have collected personal information from someone under 18, we will take steps to delete it.
9. International Users
CTM is currently designed for use within the United States. This Policy does not address the legal requirements of other jurisdictions. If CTM expands to serve individuals located outside the United States, this Policy will be updated accordingly before such expansion.
10. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated through the Service or by email.
11. Contact Us
Questions about this Privacy Policy or our data practices can be directed to privacy@campustomarket.com.