Privacy Policy

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.

Product Privacy Policy

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:

• Mobile Guardian Light
• Mobile Guardian Pro
• Mobile Guardian Elite
• Classroom Management
• Web Filtering
• Genius
• Campus
• Safer
• Learn
• Manage

Please note that this Product Privacy Policy does not apply to:

• Visitors and users of our general audience website and their information
• Organisations or third parties that Mobile Guardian does not own or manage
• Individuals that Mobile Guardian does not employ or manage

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.

The contents of this Product Privacy Policy:

1.Information that Mobile Guardian gathers through our Products
1.a. School Information

• School profile
• Authorised School Personnel
• Requests to our support centre
• Additional information about Authorised School Personnel
• How this information is used by Mobile Guardian

1.b. Personal Student Information

• Student school-managed accounts
• Device and activity history
• Student performance
• Device location
• How this information is used by Mobile Guardian

1.c. Parent/Legal Guardian Information

• Notice for Parents/Legal Guardians
• How this information is used by Mobile Guardian

1.d. Log and Cookie Information

• Analytics and events
• Log information
• Device specifics
• Cookies
• How this information is used

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

• School’s request for deletion or transfer of Personal Student Information
• Deactivated accounts

4. Your rights and choices about this information
4.a School Profile Information

• Promotional communications
• Cookies and analytics
• Californian regulations
• Legal rights under local laws

4.b School Information (except School Profile Information), Personal Student Information and Parent/Legal Guardian Information

• School requests for information
• Requests from Parents/Legal Guardians, eligible students and authorised School Personnel
  • Review, correction and deletion
  • Downloading of information
  • Transfer of student-generated content

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

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

• To set up and provide our Products
• To analyse and improve our Products
• To respond to a School’s and/or Authorised School Personnel’s requests and to provide related support
• To administer and troubleshoot our Products
• To send information to a School and Authorised School Personnel about how to use our Products
• To send information to a School and Authorised School Personnel about important updates
• To notify a School and all Authorised School Personnel about new features or Products that may be of interest to them (if they are residents of the United States or it is otherwise as permitted by law)
• To help prevent fraud and to enforce the legal terms that govern our Products
• To comply with applicable laws and protect our and others’ rights, safety and property
• To follow further instructions of a School

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.

2. How Mobile Guardian shares this information

2.a. Access within a School

Each School determines which Authorised School Personnel have access to the School’s account with Mobile Guardian’s Products and their permission levels.

2.b. Third-party access

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.

2.c. With School permission or instruction

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.

2.d. For the protection of Mobile Guardian and others

We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate in the following instances:

• To protect or defend the rights, safety, or property of Mobile Guardian or third parties, including to defend or enforce our Product Privacy Policy, EULA, or any other contractual arrangement
• To respond to claims that content violates the rights of third parties

2.e. When legally required to do so

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.

2.f. Should all or part of the business transfer to new ownership

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.

2.g. De-identified information

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.

3. How long information is stored by Mobile Guardian

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.

3.a. Personal Student Information

When it comes to Personal Student Information, we retain it only as directed by the School.

• School’s request for deletion or transfer of Personal Student Information: Mobile Guardian will act upon a School’s documented instructions to delete or transfer Personal Student Information while a School holds a licence with Mobile Guardian and after all School licences to Mobile Guardian have expired. This is unless we are required to retain such information to comply with our legal obligations with law enforcement, resolve disputes or enforce our agreements. Upon instruction to delete Personal Student Information, Mobile Guardian will take reasonable efforts to delete and/or de-identify such information in a commercially reasonable amount of time under applicable laws. At the termination of all of a School’s licences with Mobile Guardian, Mobile Guardian and the School may agree to transfer the School’s Personal Student Information back to the School. In that case, similar to deletion requests, Mobile Guardian will act upon a School’s documented instruction to transfer the School’s Personal Student Information to the School and take reasonable efforts to transfer such information in a commercially reasonable amount of time under applicable laws. This is unless we are required to retain such information to comply with our legal obligations or with law enforcement, to resolve disputes or enforce our agreements. For Schools in the EEA, Personal Student Information will be deleted and transferred/ported according to the terms of the DPA or other agreement between the School and Mobile Guardian.
• Deactivated accounts: We may consider a School’s account to be terminated 365 days (one full year) after all of a School’s Mobile Guardian licences expire without use, reactivation or renewal by the School. At that time, if the School has not requested deletion of Personal Student Information, we will automatically de-identify and/or delete the School’s Personal Student Information within a commercially reasonable period of time as long as that information is not necessary to comply with our legal obligations, resolve disputes or enforce our agreements. All Personal Student Information retained will remain subject to our Product Privacy Policy that was in effect at the time the information was obtained (even after the deactivation of an account or termination of a contract).

4. Your rights and choices about this information

4.a. School Profile Information:

• Promotional communications: You can decline promotional communications at the point information is requested or by following the unsubscribe instructions on communications sent to you. You can also contact us as described in section 9 below.
• Cookies and analytics: You can opt out of certain cookie-related and analytics processing. For more information on how we use cookies, please see section 7 below.
• Californian regulations: Under California law, residents may annually request a list of the third parties to which a company discloses personal information for marketing purposes, as well as the types of information disclosed. Please note that we do not disclose personal information to third parties for any direct marketing purposes.
• Legal rights under local laws: Local laws may permit an individual to request that we: (1) provide access to and/or a copy of certain information that we hold about that individual; (2) prevent the processing of that individual’s information for direct-marketing purposes (including any direct marketing processing based on profiling); (3) update an individual’s information that is out of date or incorrect; (4) delete certain information that we are holding about an individual; (5) restrict the way that we process and disclose certain aspects of the individual’s information; (6) transfer an individual’s information to a third party provider of services; and/or (7) revoke an individual’s consent for the processing of his/her information. If your local laws provide additional rights, we will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests due to specific circumstances, which may include the need to continue processing an individual’s information for our legitimate interests or to comply with a legal obligation. We may request that an individual and/or School provide us with information necessary to confirm the individual’s identity before responding to your request. To exercise any of these rights, please contact us as described section 9 below.

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.

4.b. School Information (except School Profile Information), Personal Student Information and Parent/Legal Guardian Information:

• School requests for information: We will assist any School using our Products (past and present) in facilitating requests relating to Authorised School Personnel Information and Personal Student Information pursuant to the School’s instruction. Please also see section 3 and section 4.a. above.
• Requests from Parents/Legal Guardians, eligible students and Authorised School Personnel:
  • Review, correction and deletion: If a Parent/Legal Guardian, eligible student or Authorised School Personnel wishes to request a review, correction or deletion of Personal Student Information or School Information, he/she should contact the appropriate School Official. Mobile Guardian will cooperate with the School to fulfil requests pursuant to the School’s verification and instruction within a commercially reasonable amount of time and in compliance with relevant law. Please note that we may be required to maintain certain School Information if directed to do so by your School Official on behalf of the School or as needed by Mobile Guardian to enforce our legal rights.
  • Downloading of information: Mobile Guardian Products allow Authorised School Personnel to download information on behalf of a Parent/Legal Guardian, eligible student or Authorised School Personnel. If Mobile Guardian Products do not cover the scope of the transfer request, Mobile Guardian will, following documented instructions from the School, honour the request from the Parent/Legal Guardian, eligible student or Authorised School Personnel for the transfer of Personal Student Information or the personal data of Authorised School Personnel. Transfer will be done using the same guidelines as described above in compliance with and as required by relevant law.
  • Transfer of student-generated content: There are several US states that have laws that require website operators to transfer student-generated content to the student’s personal account when requested by an eligible student or Parent/Legal Guardian. Mobile Guardian Products are not used as the primary platform for students to submit their own content. However, eligible students or their Parent/Legal Guardian may request any student-generated content that is submitted via Mobile Guardian be transferred to him/her. See section 9 below for contact details. Following verification of the requestor’s authorisation to receive the information (which may require verification by the requestor’s School), we will provide the student-generated content that we have in a commercially reasonable amount of time in either a CSV file or other mutually-agreeable format. Please note that we cannot guarantee retention of student-generated content.

5. How Mobile Guardian protects this information

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.

6. Notice to EEA and other non-US residents

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.

6.a. Mobile Guardian as a data processor

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.

6.b. Mobile Guardian as a data controller

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:

• Contractual commitments: We use, share and disclose information to honour our contractual commitments to a School.
• Legal compliance: We need to use, share and disclose information in certain ways to comply with our legal obligations.
• With your consent: Where required by law, and in some other cases, we use, share or disclose information on the basis of consent.
• Legitimate interests: In many cases, we use, share or disclose information on the grounds that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. These grounds include customer service, analysing and improving our business, promotional activities, providing security for our Mobile Guardian Products, preventing fraud and managing legal issues.

7. Cookies notice

7.a. What are cookies?

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“).

7.b. What types of cookies does Mobile Guardian use and what data do they collect?

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.

8. YouTube API Services

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.

The use of Mobile Guardian’s software involving YouTube content is subject to Google’s YouTube Terms of Service and in your using of Google Services, you agree to be bound by Google’s YouTube Terms of Service.

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.

9. Changes to this Product Privacy Policy

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.

10. How to contact Mobile Guardian

Individuals who have questions or concerns regarding Mobile Guardian’s Product Privacy Policy or practices may direct a query or complaint via email to support@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.

 

11. Application

This policy applies to you when you visit our website, use our application, or order our services as a customer.

12. Personal information

12.a. Scope

Your personal information includes information we collect automatically when you visit our website or use our application;

• accept on registration or submission;
• get through an order; or
• you provide voluntarily; but
• excludes anonymous, de-identified, statistical, and public information –
• excludes information of website visitors, product users and students.

It includes information about you or your organisation as a:

• student, where you may or may not be a child – a person attending and studying at a school, who may or may not be under the age of majority in the country where they live (such as younger than 18 years old);
• parent – the mother, father, or other legal guardian of a student;
• school – an institution for educating students; or
• teacher – a person who teaches in a school.

12.b. Your obligations

You may only send us your own personal information or someone else’s personal information if you have their permission to do so.

13. Acceptance and changes

13.a. Acceptance

You may not order any of our services if you do not accept this policy or any changes to it.

13.b. Changes

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.

14. Collection

14.a. Automatically

We collect your Internet usage information once granted permission 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.

14.b. On registration or submission

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.

14.c. Through an order

We ask you to provide us certain services information when you order our services.

14.d. Voluntarily

We may ask you to provide us certain optional information on a voluntary basis.

14.e. Consent to collection

We will get your consent to collect your personal information in accordance with applicable law when you provide us with it.

14.f. Purpose for collection

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.

15. Use

15.a. Processing

We may process your personal information to fulfil our obligations to you.

15.b. Website Cookies

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.

15.c. Messages

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.

15.d Marketing

15.d.1 Email Marketing

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:

• sign up to the Mobile Guardian platform
• update your preferences in your Mobile Guardian account settings
• sign up to receive a newsletter or new product announcement
• If you would like to withdraw your consent to marketing materials, or update your preferences, you can do so at any time in your Mobile Guardian profile.

15.d.2 Targeted content

We may use your personal information to provide you with targeted content on our website in a completely automated process.

16. Disclosure

16.a. Sharing

We may share your personal information with third parties for the purposes of fulfilling our obligations to you, including with:

• other companies or divisions within our group;
• our contractors who help provide part of our services; or
• third parties as required by applicable law.

16.b. Honour this policy

We will require anyone that we share your personal information with to honour this policy whenever possible in terms of applicable law.

16.c. Mandatory disclosure

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.

16.d. Marketing purposes

We may disclose aggregate statistical information that we have derived from your and other people’s personal information to our advertisers or business partners.

16.e. Personnel

We may need to disclose personal information to our personnel to do their jobs, but will not do so unnecessarily.

16.f. Change of ownership

We may assign our rights to the personal information we process to our new owners if our ownership changes for any reason.

17. Storage

17.a. Accuracy

We will do our best to keep your personal information that we collect accurate, complete, and up to date.

17.b. Participation

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.

17.c. Retention

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.

17.d. Transfer

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.

18. Your rights and control of personal information

18.a Your rights

Under the UK Data Protection Act and/or the European Data Protection Regulation (GDPR) and e-privacy laws, you have the right:

• to be informed
• of access
• to rectification
• to erasure
• to restrict processing
• to data portability
• to object
• in relation to automated decision making and profiling.

For more and detailed information on these rights, please view the guidance provided by the Information Commissioner’s Office.

18.b Control of your personal information

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.

19. General

19.a. Updating or removing

You may update or remove your personal information through our website or application or by contacting us at support@mobileguardian.com.

19.b. Limitation

We are not responsible for anyone else’s privacy policies or practices.

19.c. Enquiries

Please contact us at support@mobileguardian.com if you have any questions about this privacy policy or how we handle your personal information.