1. Information that Mobile Guardian gathers through our Products

• 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.

1.a. School Information

• 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:

• School profile: From first contact, Mobile Guardian begins collecting information on the School. When a School Official enquires about Products on behalf of his/her School, we collect their relevant information, as well as information about his/her School relevant to purchasing and setting up the School’s account. This information includes the School Official’s name, email address and phone number, as well as the School’s name, physical address, billing address, number of devices, number of students and network configuration. If the School Official creates an account, the School Official must also create a password.
• Authorised School Personnel: Once the School has an account with Mobile Guardian, the School Official can add new member profiles, such as other School Officials, teachers, IT administrators, etc. These are collectively known as “Authorised School Personnel“. The names of each member are stored on the Mobile Guardian platform.
• Requests to our support centre: Whenever Authorised School Personnel make a request to the Mobile Guardian support centre (via their Product dashboard or the Mobile Guardian website), the individual’s contact details are collected. These are stored, along with the message thread about the support query.
• Additional information about Authorised School Personnel: The Mobile Guardian Products allow for various other pieces of information to be collected. Additional information that can be collected includes:
• Chat messages between students and teachers (via the Classroom Management tool)
• Unique account identifiers generated by the Mobile Guardian Product
• Relevant unique account identifiers generated by third-party applications (e.g. Google Classroom identifiers that can be integrated from the Google Classroom platform with Mobile Guardian Classroom Management)

• How this information is used by Mobile Guardian

• School profile: From first contact, Mobile Guardian begins collecting information on the School. When a School Official enquires about Products on behalf of his/her School, we collect their relevant information, as well as information about his/her School relevant to purchasing and setting up the School’s account. This information includes the School Official’s name, email address and phone number, as well as the School’s name, physical address, billing address, number of devices, number of students and network configuration. If the School Official creates an account, the School Official must also create a password.
• Authorised School Personnel: Once the School has an account with Mobile Guardian, the School Official can add new member profiles, such as other School Officials, teachers, IT administrators, etc. These are collectively known as “Authorised School Personnel“. The names of each member are stored on the Mobile Guardian platform.
• Requests to our support centre: Whenever Authorised School Personnel make a request to the Mobile Guardian support centre (via their Product dashboard or the Mobile Guardian website), the individual’s contact details are collected. These are stored, along with the message thread about the support query.
• Additional information about Authorised School Personnel: The Mobile Guardian Products allow for various other pieces of information to be collected. Additional information that can be collected includes:
• Chat messages between students and teachers (via the Classroom Management tool)
• Unique account identifiers generated by the Mobile Guardian Product
• Relevant unique account identifiers generated by third-party applications (e.g. Google Classroom identifiers that can be integrated from the Google Classroom platform with Mobile Guardian Classroom Management)

1.b. Personal Student Information

• 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:

• Student school-managed accounts: Each student using a School-managed device requires a personal account when a School deploys a Mobile Guardian Product. The account includes the student’s name, email address, their organisational unit and device identifiers. An optional extra for a School is to associate a student with a specific teacher or classroom. Unique identifiers from third-party platforms can also be included in a student’s account, such as their Google Profile ID, Google Image URL, and a Google Classroom identifier.
• Managed accounts: If a student logs into a personal device with a school-managed account, we will track location and browser history. Contact List information on the Student’s device is neither collected nor uploaded nor managed by Mobile Guardian.
• Device and activity history: Depending on a School’s selected Mobile Guardian Product and settings, Mobile Guardian may collect additional information about online accounts or activity, including chats (within Mobile Guardian Classroom Management), and browsing history (including IP address).
• Student performance: Depending on a School’s selected Mobile Guardian Product, features, integrations and settings, Mobile Guardian may receive grade and attendance information for each student.
• Social Account Information: Mobile Guardian collects Social Account information such as account name, user name, and user email address to enable application functionality. Mobile Guardian does not use the social account information for advertising nor share the information with third parties.
• Device location: All Products are able to track the geographic location of all enrolled devices. Mobile Guardian can also collect IP addresses while devices are active.

• How this information is used by Mobile Guardian
• In accordance with our contractual obligations, we use Personal Student Information to:

• Provide, improve and analyse our Products and for legitimate educational purposes of a School
• Enforce the legal terms that govern our Products
• Comply with applicable laws and protect our and others’ rights, safety and property
• Follow further instructions from a School
• 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 collect Contact List information from the Student’s Device or Account. Only information related to the Students School Managed Account is collected. 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.

1.c. Parent/Legal Guardian 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:

• Name
• Email address
• Phone number (optional)
• 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:

• Provide, improve and analyse our Products and for legitimate educational purposes of a School
• Enforce the legal terms that govern our Products
• Comply with applicable laws and protect our and others’ rights, safety and property
• Follow further instructions from a School
• 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.

1.d. Log and Cookie Information

• Our Products automatically collect certain information (collectively referred to as “Log and Cookie Information”). This information includes:

• Analytics and events: Our Products automatically collect information through analytics services providers, including IP address, Internet Service Provider (ISP), date and time stamp, browser language, browser type, and/or other general usage data. Similar to other software, we also collect event information regarding how users interact with our Products – how much time is spent on particular features for different users.
• Log information: We also collect service diagnostics and technical logging information. This may include IP address, login times, usage times of our Products, browser type, and browser configuration.
• Device specifics: We collect information about the devices that are enrolled by a School. This includes type of device, device settings, and operating system.
• Cookies: We use Cookies in our Products as described in our Cookies notice below (section 7).

• 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.

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