We at SmartPass understand that student privacy, data security, and school safety is of utmost importance to school districts, staff, and parents alike. That's why we continuously listen to and address district concerns to promote the safety of students.
SmartPass complies with both the Family Educational Rights and Privacy Act and the Children’s Online Privacy and Protection Act to ensure that student's rights are protected. We work with schools and parents with accessing information, and abide that school districts own and control "Personal Student Information." We work closely with customers to provide the ability to access, modify, and delete data in compliance with these laws.
Data security and safeguarding are top priorities at SmartPass. We adhere to ISO security standards and take extreme measures to ensure customer data is protected. Data in transit uses SSL encryption with a digital certificate, and data at rest is provided by Google Cloud.
When a School registers for our Services, they provide information regarding the School, students, and faculty. This includes data from Google’s G Suite for Education platform including email addresses, student names, student IDs, organizational units, and groups.
Users of the Site may submit information in accordance with our described Services, including pass creation, administrator room set-up, and other information that is inputted by users.
We have access to Student Data only for the purposes of performing Services on the School’s behalf.
We use the information we collect to operate and improve our Site, Services, and their functionality.
SmartPass uses the services of one or more third parties to create and maintain our Site and Services, and non-identifying and aggregated information which you submit may be shared with them and may be shared with other parties. We ensure that third parties used are consistent with principles listed in this policy, including security and data retention principles.
Student and School personal information will not be retained for longer than necessary to deliver services or for school purposes. This means that personal information cannot be kept in backups or not be deleted because of data commingling.
In accordance with the Children’s Online Privacy and Protection Act (“COPPA”), SmartPass does not and will not knowingly collect any information from children under the age of 13. We will never sell personal information, collect, use, or share such information for any purposes beyond the authorized educational or school purposes, or as authorized by the student or parent. In addition, we will never permit behavioral targeting of advertisements.
SmartPass maintains a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of student personal information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.
Data in-transit uses standard SSL encryption with a digital certificate. Data at rest is securely hosted by Google Cloud and is encrypted when it is stored on disk. User roles are clearly defined to manage the access level, restricted to administrators directly managing a customer’s registration for the use of Services and accessing the Site.
While SmartPass believes and intends that its information security practices reflect good practice, there is no such thing as perfect information security. As such, users assume the risk of security breaches and all consequences resulting from them. In furtherance of the foregoing, users must safeguard their credentials. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.
To learn more about our many safeguards to protect your information, please contact us at firstname.lastname@example.org.
We reserve the right to collect various information about you and your computer or mobile device, in accordance with other information collected, through the use of computer “cookies” or data files which recognize your computer when you return to our site or re-use our mobile application. You may instruct your computer to refuse these cookies, but this may impair or impede the Services we are able to provide you.
In the event that our business is acquired in whole or part by another company, your personal information may be disclosed to them, but that disclosure will be subject to this policy. Successor entities will contract with future companies that are consistent with our privacy principles or allow users a choice to send information to the future entity.
Our Site may contain links to other websites. We have no control over their operation and/or the accuracy of any statements made on them and assume no responsibility with respect to them.
Any disputes regarding this Policy shall be resolved in accordance with Pennsylvania law.
By using the Services or accessing the Site, you agree not to rent, lease, loan, sell, resell, sublicense, distribute or otherwise transfer the licenses granted in connection with using the Services or accessing the Site.
Users shall not itself or permit others to copy, decompile, reverse engineer or take comparable action regarding the Site and its object code. Users acknowledges that violation of this Paragraph shall lead to irrevocable harm to Licensor and, without prejudice to any other right or remedy available to Licensor, shall entitle Licensor to injunctive and other equitable relief.
Certain information users provide to SmartPass about students may be considered an education record (“Education Record”) under the Family Educational Rights and Privacy Act (“FERPA”). Additionally, certain information users provide to SmartPass about a student, such as student name, may be considered directory information under FERPA (“Directory Information”) and thus not an Education Record. A School may not generally disclose personally identifiable information from a student’s records without written consent of the parent and/or eligible student or without meeting one of the exemptions set forth in FERPA such as the Directory Information exemption (as defined by FERPA).
To the extent you provide information subject to FERPA, you represent, warrant and covenant to SmartPass that you have fully complied with all FERPA requirements including, without limitation, obtaining all necessary written consents to share the information with SmartPass for use by SmartPass to the fullest extent necessary to provide the Services;
Unless permitted by FERPA or an applicable exemption, SmartPass will never share an Education Record with third parties except as directed by a user or to our service providers that are necessary for us to provide the Service. We will also strive to make sure all third parties are consistent with our privacy principles.
The Children’s Online Privacy and Protection Act (“COPPA”) requires that online service providers obtain clear and verifiable parental consent before collecting personal information from children under 13. SmartPass does not and will not knowingly collect any information from children under the age of 13. To the extent you provide information related to a child under the age of 13, you are solely responsible for complying with COPPA and you represent and warrant that you have fully complied with COPPA by, among other things, receiving the appropriate consent from parents and/or having the requisite authority to provide such information to SmartPass, and for us to collect such information.
LICENSOR DISCLAIMS ALL WARRANTIES ASSOCIATED WITH THE SERVICES OR SITE AND ITS FUNCTION, PERFORMANCE AND USE, INCLUDING WITHOUT LIMITATION, WARRANTIES OF NON-INFRINGEMENT, MERCHANTABILITY AND FITNESS FOR ANY PARTICULAR PURPOSE, WHETHER OR NOT COMMUNICATED TO LICENSOR. IN NO EVENT SHALL THE USER BE ENTITLED TO DAMAGES THAT EXCEED THE AMOUNT ACTUALLY PAID BY THE USER TO THE LICENSOR PURSUANT TO THIS AGREEMENT DURING THE 12 MONTHS PRECEDING THE EVENT GIVING RISE TO SUCH LIABILITY. THE USER ACKNOWLEDGES THAT THE PROPER FUNCTIONING OF THE SERVICES AND THE SITE DEPEND UPON MANY FACTORS BEYOND THE CONTROL OF LICENSOR.
This Agreement and use of the website and App shall be governed by Pennsylvania law and any dispute associated herewith shall be resolved solely in the federal or state courts situated in the Eastern District of Pennsylvania. No class action claim may be brought with respect to this License or the Services and Site.
We may modify these Terms from time to time and such modifications shall immediately take effect upon posting to the Site. If you do not agree with any changes to these Terms, you may stop using the Services. Your continued use of the Site or Services indicates that you have read, understood and agreed to the current version of these Terms.
SmartPass reserves the right in its sole discretion to review, improve, modify, shut down, or discontinue, temporarily or permanently, the Services or Site.