Privacy Policy

The SchoolPass Privacy Policy (hereinafter, the “Policy”) addresses individuals whose personal information or other profile data, as further detailed below (“PD”) is received, collected, or processed by MHR Technologies, Inc. DBA SchoolPass (“us”, “we,” “our,” or “SchoolPass”) in our web-based application located at schoolpass.com or any of our other websites or web-based applications and the SchoolPass mobile apps (the “Services”).

This Policy applies to non-California residents who utilize the Services. California residents should reference the California Policy. This Policy describes how your information is collected, used, shared, and secured, as well as your related choices regarding use, access and correction. This Policy applies when you utilize the Services and applies only to personal information we may otherwise collect in or through the Services and in email, text, and other electronic communications sent through or in connection with the Services. This Policy does not apply to the information we receive from the third-party websites, third-party mobile apps or other digital products. The Policy also does not apply to websites, mobile apps, or other digital products maintained by other companies or organizations to which we may link or who may link to us. You should consult the relevant privacy policies on the websites, mobile apps, or other digital products affiliated with those companies or organizations to find out more about their privacy practices and your related choices. We are not responsible for the actions and privacy policies of third-party apps or websites.

This policy explains what information we collect, how we collect it, how we may use the information, what your rights are, how to opt-out or express choices, when your information is shared and to whom it may be shared, and how to know when the policy is updated.

We value your trust and aim to safeguard your PD and to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners, and others who share their personal information with us.

BY USING OUR SERVICES, YOU ARE EXPRESSLY ACCEPTING THE PRACTICES DESCRIBED IN OUR POLICY, INCLUDING OUR USE OF COOKIES AND SIMILAR ONLINE TOOLS.

We may change this Policy to accommodate changes to our Services, new technologies or industry practices, updated regulatory or legal requirements, or for other purposes. We reserve the right to modify or amend the terms of this Policy from time to time without notice. Your continued use of our Services following the posting of changes to these terms will mean you accept those changes. Notices may be emailed to the most recent email address you provided us, by posting notice of such change on the Services or our website, or by other communication channels. You consent to receiving notices in these ways. We reserve the right to determine the form and means of providing notifications to you, consistent with applicable law.

Categories of PD

The categories of personal information or PD processed by the Services include information you provide and information gathered from other sources, such as from device and browser information. The Services enable you to share your contact information, such as your name, your email address, your phone number, and an optional photograph as a profile picture. Student arrival and dismissal scheduling data may also be processed by the Services. Additionally, the Services contain user-selected fields, which may include other categories of personal information that you consent to sharing with us. The application is designed to manage arrival and dismissal schedules and basic contact information (email address and mobile phone number) of users. The application may also be used to process other types of data that may be associated with a user, such as the role of the user at that the school that is licensed to use the application.

The Services use cookies. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. The cookies enable us to remember data you have entered or choices you have made, such as your email address and app school code and provide you with a better user experience. We use session ID cookies to recognize you, as you move from one page to another within the application. If you have chosen to identify yourself to the SchoolPass Service, we use cookies containing encrypted data to enable us to uniquely identify you. Each time you log into the SchoolPass Service, a cookie containing an encrypted unique identifier that is tied to your account is placed on your computer. These cookies allow us to uniquely identify you when you are logged into the SchoolPass Service and enable us to provide you with the best user experience. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

How this Information is Collected

This information may be collected when you fill out a form, create an account, access our Services, use our Services, respond to customer surveys, or otherwise interact with us, such as through social media or networking sites. This information may also be provided to us from third parties, such as schools and companies you are affiliated with.

How the Information is Used

We use information that we collect about you or that you provide to us, including any personal information or PD, to:

• Provide you with the Services and its contents, and any other information, products or services that you request from us;
• Fulfill any other purpose for which you provide the PD;
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, or between us and the schools or companies with which we contract, including for billing and collection and provision of the Services, and
• Notify you when Service updates are available, and of changes to any products or services we offer or provide though it.

The usage information we collect helps us to improve our Services and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Speed up the application
• Recognize you when you use the Services.

We maintain and use PD for the purposes of providing the Services to our users and account holders at their instruction, processing PD on behalf of users and account holders, communicating within the school or school district about arrival and dismissal schedules, providing information on the Services to prospective SchoolPass account holders, improving the Services, and conducting related tasks for legitimate school purposes.

Sharing PD with Third Parties

We send non-identifiable PD elements to our data sub-processors, who further process such PD on behalf of, and under the instruction of, SchoolPass. Such data sub-processors include:

• infrastructure service provider (AWS);
• SMS notification service provider (Twilio); and
• Email service provider (SendGrid).

We require any of our data sub-processors to maintain at least the same level of confidentiality, integrity, and availability that we maintain for such PD. SchoolPass remains liable for the protection of your PD that we transfer to our sub-processors. We may also disclose PD (i) to other third parties for the purposes for which we receive the PD (e.g., performance of contractual obligations and rights); (ii) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders; (iii) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring or other company change; and (iv) to our subsidiaries, only if necessary for business and operational purposes. If we must disclose your PD in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your PD will maintain the privacy or security of your PD.

You may opt out of having your information shared with entities working on our behalf, as discussed below. Although you can opt out of promotional messages, we reserve the right to send you informational email messages about any administrative notices regarding the Services, as permitted under the CAN-SPAM Act (15 U.S.C. §7701 et seq.).

Data obtained through the short code program will not be shared with any third-parties for their marketing reasons/purposes.

Your Legal Rights

Under certain circumstances, you may have rights under data protection laws in relation to your PD or personal information, including the right to:

1. request access to your personal data;
2. request correction to your personal data;
3. request limitations to your personal data;
4. request erasure of your personal data;
5. object to processing of your personal data;
6. request restriction of processing your personal data;
7. opt-out of automated decision-making;
8. request transfer of your personal data; and
9. withdraw your consent.

If you wish to exercise any of your rights listed above, please contact us at:

info@schoolpass.com or (301) 255-1870

We try to respond to all legitimate requests in a timely manner. Occasionally, it may take an extended period of time (a month or longer) to respond to your request if your request is complex or if you have a number of requests.

Privacy of Children

Th Services are not intended for children under 13 years of age and we do not intentionally collect personally identifiable information from users of the Services who are under the age of thirteen without parental consent. If we become aware that a user of the Services is under the age of 13 we will remove that child’s personal information from our files, in accordance with the federal Children’s Online Privacy Protection Act of 1998.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Non-U.S. Residents

Non-U.S. residents should be advised that their personal data, including order information, may be transferred outside of their country of origin to Canada and to the United States, and may be transferred to a third-party data processer. All information is appropriately safeguarded and is in compliance with all applicable guidelines. By using the Services, you consent to the transfer of your personal data, including order information, to third party data processers located outside of your country of origin.

Changes to This Policy

We may update this Policy from time to time by posting a new version through, or in connection with, our Services or on our website. Continued use of the Services constitutes agreement to this Policy. When we make a material changes to the Policy, we will update the Last Updated date above to reflect the effective date of the most recent version of the Policy. We suggest you visit this Policy periodically to determine whether or not any such changes have been made. Any changes or updates to the Policy are effective immediately upon posting through, or in connection with, our Services or on our website and your continued use of the Services after we make changes is deemed to be acceptance of those changes.

Contact

If you have any questions or complaints about how we process your PD, please contact us via our contact form or using the information below.

MHR Technologies, Inc. DBA SchoolPass Security and Compliance Manager
267 Kentlands Blvd, #2034 Gaithersburg, MD 20878
Email: info@schoolpass.com

We strive respond to your inquiry within two weeks of receipt.

This Policy was last updated December 13, 2021