Mobile Guardian is a technology company that provides software products to schools, districts and multi-academy trusts (Schools) as well as small to medium enterprises (SMEs) and Parents. We respect your privacy and take it very seriously. We are Mobile Guardian Limited (Registration number 07441190) and this is our plan of action for the protection of your personal information.
Mobile Guardian is a software development company that provides software products to schools, districts and multi-academy trusts (collectively referred to as “Schools” for the purposes of this document), small to medium enterprises (“SMEs”) and parent(s)/legal guardian(s) (“Parents/Legal Guardians”).
The purpose of this Product Privacy Policy (“Product Privacy Policy”) is to explain how we collect, use, share, disclose and protect information collected from and about Schools that are deploying our Mobile Device Management (MDM) and Classroom Management solutions (“Products”) on devices used by Authorised School Personnel.
Our School Products include:
Please note that this Product Privacy Policy does not apply to:
We encourage you to review the applicable third-party privacy policies and terms of use before submitting any information through those sites or services.
By using our Products, you (as Authorised School Personnel) are declaring that you have read and understood this Product Privacy Policy. Additionally, you are acknowledging that you represent the School and have the authority, the right and the capacity to legally bind the School, and warrant that you are at least eighteen (18) years old.
1.Information that Mobile Guardian gathers through our Products
1.a. School Information
1.b. Personal Student Information
1.c. Parent/Legal Guardian Information
1.d. Log and Cookie Information
2. How Mobile Guardian shares this information
2.a. Access within a school
2.b. Third-party access
2.c. With School permission or instruction
2.d. For the protection of Mobile Guardian and others
2.e. When legally required to do so
2.f. Should all or part of the business transfer to new ownership
2.g. De-identified information
3. How long information is stored by Mobile Guardian
3.a Personal Student Information
4. Your rights and choices about this information
4.a School Profile Information
4.b School Information (except School Profile Information), Personal Student Information and Parent/Legal Guardian Information
5. How Mobile Guardian protects this information
6. Notice to EEA and other non-US residents
6.a. Mobile Guardian as a data processor
6.a. Mobile Guardian as a data controller
7. Cookies notice
7.a. What are cookies?
7.b. What type of cookies does Mobile Guardian collect?
8. Youtube API Services
9. Changes to this Product Privacy Policy
10. How to contact Mobile Guardian
11. Application
12. Personal information
12.a. Scope
12.b. Your obligations
13. Acceptance and changes
13.a. Acceptance
13.b. Changes
14. Collection
14.a. Automatically
14.b. On registration or submission
14.c. Through an order
14.d. Voluntarily
14.e. Consent to collection
14.f. Purpose for collection
15. Use
15.a. Processing
15.b. Website Cookies
15.c. Messages
15.d. Marketing
15.d.1. Email Marketing
15.d.2. Targeted content
16. Disclosure
16.a. Sharing
16.b. Honour this policy
16.c. Mandatory disclosure
16.d. Marketing purposes
16.e. Personnel
16.f. Change of ownership
17. Storage
17.a. Accuracy
17.b. Participation
17.c. Retention
17.d. Transfer
18. Your rights and control of personal information
18.a. Your rights
18.b. Control of your personal information
19. General
19.1. Updating or removing
19.2. Limitation
19.3. Enquiries
The information that we collect is broken down into four categories:
a. School Information
b. Personal Student Information
c. Parent/Legal Guardian Information
d. Log and Cookie Information
The specific information collected in each category can depend on which Product a School uses and which features are activated with the Product. The information collected may change if a School chooses to change their Product or the features used.
The information collectively labelled as “School Information” is a combination of details required when inquiring about and signing up to use a Mobile Guardian Product, and details required for the School to use the Product. This information is made up of the following:
How this information is used by Mobile Guardian
Mobile Guardian collects information directly from students using devices enrolled in the Product that is being deployed by their School. This information (referred to as “Personal Student Information”) is used to identify a current or former student enrolled in a K-12 School on behalf of the School and in order to assist with correct and full use of the Mobile Guardian Product deployed. Particular settings for Personal Student Information can be enabled or disabled by the School.
Mobile Guardian only collects Personal Student Information on School-managed devices and/or accounts where a School has already registered with Mobile Guardian and chosen to use Mobile Guardian Products. Schools in the United States must also provide appropriate consent and/or obtain consent to the extent required by applicable law, including the Children’s Online Privacy Protection Act (“COPPA”) and state laws on student privacy, unless a relevant legal exception applies.
Information collected includes:
How this information is used by Mobile Guardian
In accordance with our contractual obligations, we use Personal Student Information to:
At all times, Mobile Guardian considers Personal Student Information to be the property of and under the control of the School, or as required by applicable law, the property of and under the control of the applicable eligible student or Parent/Legal Guardian.
We do not sell Personal Student Information. We do not use Personal Student Information to target advertisements or market to students or anyone else, or to amass a profile about a K-12 educational student for a non-educational purpose. We do not use Personal Student Information for any purposes prohibited by the Family Educational and Privacy Rights Act (20 U.S.C. § 1232g; 34 CFR Part 99.3) (“FERPA”), California Business & Professions Code section 22584 (“SOPIPA”), and California Education Code section 49073.1. We will not use Personal Student Information for any purpose other than those required or specifically set forth in this Product Privacy Policy, our EULA, DPA, or any other agreement between a School and Mobile Guardian.
We will use Personal Student Information in accordance with applicable student privacy laws, including, as applicable, Connecticut’s “Act Concerning Student Privacy”.
If you are a Product user in the EEA, please see section 6 (Notice to EEA and other non-US residents) below for more information on how we use collected information and the legal bases for collecting information.
The linked Parent Dashboard is a feature that Schools can opt to enable as part of their Mobile Guardian Product. If they do so, Mobile Guardian may receive information about a student’s Parents/Legal Guardians, including:
Notice for Parents/Legal Guardians:
Schools use the Parent Dashboard feature to send important notifications to you directly about your child and activities at the School. To learn whether your child’s School is using this guardian feature or how to update a child’s Parent/Legal Guardian contact information, please contact your child’s School and follow the instructions below in section 4.b. (Requests from Parents/Legal Guardians, eligible students and Authorised School Personnel).
How this information is used by Mobile Guardian
In accordance with our contractual obligations, we use Personal Student Information to:
At all times, Mobile Guardian considers Parent/Legal Guardian Information to be the property of and under the control of the School, or as required by applicable law, the property of and under the control of the applicable Parent/Legal Guardian.
We do not sell Parent/Legal Guardian Information. We do not use Parent/Legal Guardian Information to target advertisements or market to students, Parents/Legal Guardians or anyone else, or to amass a profile about a Parent/Legal Guardian for purposes not related to the School. We will not use Parent/Legal Guardian Information for any purpose other than those required or specifically set forth in this Product Privacy Policy, our EULA, DPA, or any other agreement between a School and Mobile Guardian.
If you are a Product user in the EEA, please see section 6 (Notice to EEA and other non-US residents) below for more information on how we use collected information and the legal bases for collecting information.
Our Products automatically collect certain information (collectively referred to as “Log and Cookie Information”). This information includes:
How this information is used by Mobile Guardian
Mobile Guardian uses information gathered on analytics, events and logs to better understand how our Products are being used. This allows Mobile Guardian to update Products to ensure a better user experience. It also allows Mobile Guardian to provide full support to Schools using the Products.
Cookies are used to ensure ease of use by Authorised School Personnel and students.
Each School determines which Authorised School Personnel have access to the School’s account with Mobile Guardian’s Products and their permission levels.
We share necessary information with various third-party service providers that assist us in performing business-related functions. For example, we use hosting services and customer service tools to help support our Products. When we employ another company to perform a function of this nature, we provide them with only the information that they need to perform their specific function.
We may share or disclose information, including Personal Student Information, to third parties pursuant to a School’s instruction or with a School’s permission. For example, if a School chooses to integrate Mobile Guardian’s Products with another third party’s products or services, then we will share information as instructed. Additionally, we may ask for a School’s permission to share or disclose the School’s name and other content through a testimonial.
We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate in the following instances:
We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal or regulatory process, such as to respond to a warrant, subpoena, court order or other applicable laws and regulations.
We may share or disclose certain information in connection with or during negotiations for a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. If such transfer is subject to additional mandatory restrictions under applicable laws, Mobile Guardian will comply with such restrictions. The successor entity will be subject to all applicable federal and state laws, including student privacy laws. In connection with such a transaction, we will also work to ensure that the successor entity has a commitment to student privacy.
We may use, share, or disclose De-Identified Information for various purposes. This is information that has had names and contact details removed, as well as any other details that could be used to identify the person or the School. The reason for sharing such information include product development, research and marketing, and complying with relevant laws. For example, we may use aggregate, anonymous data to publish an e-Book on how Schools use our Products.
If you are a School or other Authorised School Personnel in the EEA, please see section 6 (Notice to EEA and other non-US residents) below.
We generally retain information for as long as it may be relevant to the purposes of maintaining our relationship with a School or as required or permitted by law. To dispose of any personal information, we may anonymise it, delete it or take other appropriate de-identifying steps. Please note that information may persist in copies made by Mobile Guardian for backup and business continuity purposes for an additional period of time.
When it comes to Personal Student Information, we retain it only as directed by the School.
In addition to the above rights, an individual has the right to lodge a complaint with the relevant supervisory authority. However, we encourage the individual to contact us first, and we will do our best to resolve the concern.
Mobile Guardian takes the security and privacy of your School’s data very seriously. For this reason, Mobile Guardian has implemented various technical, administrative and physical safeguards to protect your information, including specific training of our personnel authorised to access Personal Student Information and other information. These safeguards vary depending on the sensitivity of the information at issue.
Mobile Guardian is committed to preventing unauthorised access to our systems and data, and will investigate any possible occurrence. In the event of a breach of Personal Student Information, Mobile Guardian will comply with all relevant breach laws to assist the School or provide notification as required to the Schools, affected Parents/Legal Guardians, eligible students and regulators.
In the European Union (“EU”) data protection laws, there is a distinction between organisations that process personal data for their own purposes (known as “data controllers“) and organisations that process personal data on behalf of other organisations (known as “data processors“). The laws in some jurisdictions also require data controllers to share the legal ground that they rely upon to use or disclose personal information.
As there are several types of information collected and stored by Mobile Guardian, we act as both a data processor and a data controller in different circumstances.
Mobile Guardian is considered the processor of School Information (except for School Profile Information), Personal Student Information and Parent/Legal Guardian Information. Mobile Guardian collects, uses, shares and discloses this information as a processor on behalf of and at the instruction of the School (who acts as the controller in these instances), pursuant to our EULA and, if applicable, DPA.
If you have a question or complaint about how your personal data is handled, please contact your School directly.
Mobile Guardian is considered the controller of School Profile Information and School Log and Cookie Information. Mobile Guardian as the data controller collects, uses, shares and discloses this information as described in sections 1.a., 1.d and 2 above. We retain the personal data contained in the above-mentioned information categories for as long as necessary to provide you with Mobile Guardian Products, or for other important purposes such as complying with legal obligations, resolving disputes and enforcing our agreements.
Our legal grounds for using School Profile Information and School Log and Cookie Information are as follows:
Cookies are small text files stored on your computer that allow us to understand the usage of Mobile Guardian Products. Along with using cookies, we also use Internet server logs, tags, Software Development Kits/SDKs, tracking pixels, and other similar tracking technologies.
There are two kinds of cookies: those that last only for the duration of your session, expiring when your session ends (“session cookies“) and those that stay on your device for longer (“persistent cookies“).
At Mobile Guardian, we use a combination of both types of cookies in our Products. Some of the cookies used on our Mobile Guardian Products are set by us, and some are set by third parties that are delivering services on our behalf.
Session cookies are used to help us understand the usage of Mobile Guardian Products and to improve these Mobile Guardian Products.
Persistent cookies are used to help our systems authenticate your account and recognise you as a user when you return to your Mobile Guardian Products. They remember your settings and account information so that it is simple for you to login and continue working.
We do not use any advertising cookies in our Products and we do not place advertisements in Mobile Guardian Products.
We as an organisation make use of YouTube and other Google products. To review further details of the YouTube Terms of Service, please do so here.
In doing so, we make use of YouTube’s API Services in order to provide better user experiences. For more information, please review the Google Privacy Policy link.
We reserve the right to make changes to this Product Privacy Policy in order to reflect changes in the law, in our data collection and usage practices, and in the features of Mobile Guardian Products. At the top of this document, we indicate the date of the most recent update to this Product Privacy Policy.
We will notify all Schools using our Products of material changes to the Product Privacy Policy on our website, and make additional efforts to notify Schools of material changes that impact the treatment of data collected via Mobile Guardian Products and/or via email. We will also obtain a School’s consent before any material changes to our Product Privacy Policy apply to the School where required by applicable law.
Individuals who have questions or concerns regarding Mobile Guardian’s Product Privacy Policy or practices may direct a query or complaint via email to privacy@mobileguardian.com.
Within a reasonable time of receiving the written complaint, Mobile Guardian will review and address the complaint, as appropriate, and inform the individual of the results of such review and any steps taken to address the complaint.
This policy applies to you when you visit our website, use our application, or order our services as a customer.
Your personal information includes information we collect automatically when you visit our website or use our application;
It includes information about you or your organisation as a:
You may only send us your own personal information or someone else’s personal information if you have their permission to do so.
You may not order any of our services if you do not accept this policy or any changes to it.
We may change this policy at any time and will notify you of the changes on our website, through our application, or by email. The changed policy applies to you if you continue using our website, our application, or our services following the notification.
We collect your Internet usage information automatically when you visit our website, including your IP address, browser details, and usage information, which we may use to display our website correctly, track your activities on it, or for other necessary purposes.
We may ask you to provide us with certain identifying information when you register on or otherwise submit information through our website or application for the first time.
We ask you to provide us certain services information when you order our services.
We may ask you to provide us certain optional information on a voluntary basis.
We will get your consent to collect your personal information in accordance with applicable law when you provide us with it.
We may process your information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information.
We may process your personal information to fulfil our obligations to you.
We may place small text files on your device when you visit our website that allow us to provide you with a personalised experience by associating your personal information with your device. They let us remember your preferences, allow third parties to provide services to you, and otherwise serve useful purposes for you. Your internet browser generally accepts them automatically, but you can often change this setting or delete them manually. However, we won’t be able to provide you with access to certain aspects of our website where cookies are necessary if you do so. We have no access to or control over any cookies that our business partners use on our website and they have their own privacy polices that govern them. You can view our cookie policy here.
We may use your identifying information to send you administrative and update messages about the website. We may also sometimes send you promotional messages, but you may choose to opt-out of them.
When you give consent to receive marketing communications from Mobile Guardian, we use the data you have submitted, to email you about product updates, new products, or offers that may be of interest to you.
Unless you have given us permission to do so, your personal data is never used for marketing purposes.
You can opt-in to marketing and product communications when you:
We may use your personal information to provide you with targeted content on our website in a completely automated process.
We may share your personal information with third parties for the purposes of fulfilling our obligations to you, including with:
We will require anyone that we share your personal information with to honour this policy whenever possible in terms of applicable law.
We may disclose personal information to third parties if required for legal reasons, such as to regulators as required by law or governmental audit, law enforcement as required by a subpoena or court order, or third parties as required by applicable law.
We may disclose aggregate statistical information that we have derived from your and other people’s personal information to our advertisers or business partners.
We may need to disclose personal information to our personnel to do their jobs, but will not do so unnecessarily.
We may assign our rights to the personal information we process to our new owners if our ownership changes for any reason.
We will do our best to keep your personal information that we collect accurate, complete, and up to date.
We may ask you to update your personal information from time to time or give you a way to review it, but will take steps to verify your identity to prevent unauthorised access when doing so.
We will only keep your personal information for as long as is necessary to fulfill our obligations to you, unless you have given us permission to keep it longer or we are otherwise legally allowed to do so.
We may transfer your personal information outside of the country in which it was collected to a foreign country. You consent to us processing your personal information in a foreign country with less stringent data protection laws than the country in which it was collected.
Under the UK Data Protection Act and/or the European Data Protection Regulation (GDPR) and e-privacy laws, you have the right:
For more and detailed information on these rights, please view the guidance provided by the Information Commissioner’s Office.
The European Data Protection Regulation (GDPR) gives you the right to access information held about you. You can request to see this information and have it updated, or erased. You can exercise your right of access and erasure by contacting support@mobileguardian.com.
You may update or remove your personal information through our website or application or by contacting us at privacy@mobileguardian.com.
We are not responsible for anyone else’s privacy policies or practices.
Please contact us at privacy@mobileguardian.com if you have any questions about this privacy policy or how we handle your personal information.