DATA PRIVACY POLICY

We at SeQrd Technology Limited (“SeQrd”, “we”, “us”, “our”, “SchoolsMobile”), care deeply about privacy, security, and online safety, all of which are a significant part of our essential mission: to protect users (“you” and “your” and “your child”) of our products and services from the risks of theft, disruption, and unauthorized access to their online data.

This privacy policy is designed to inform you about how we treat your data when you use our services, web-based or mobile applications (collectively), or when you interact with us.
 

1. Controller

SeQrd is the controller and responsible for yours, or your children’s, personal data.

 

2. Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Privacy Manager via:

Email: info@seqrdtech.com

Postal Address: PO Box 64, Leighton Buzzard, Bedfordshire, UK LU7 6ER     

Note: the full name of the legal entity is SeQrd Technology Limited.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (http://www.ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us if there is an issue. We endeavour to respond to all contact within one business day of receipt.

 

3. What kind of data do we collect?

Direct interaction data – we collect certain data when you create an account, request customer service, or otherwise communicate with us. At all stages it is the minimum data needed to allow us to create and provide a service to or for you.

The type of data you may provide includes:

- Contact information (such as name and email address)

- Account log-in credentials (username and password)

- Your child’s name

- Financial data (bank account and payment card details)

- Transaction data (details about payments to and from you, and other details of products and services you purchase from us)

We do not collect any child’s personal data by asking a child to directly provide information themselves. We will never ask your child to provide us with personal data.

Data automatically processed as part of a SchoolsMobile service - In order to be effective and for us to meet our obligations to protect children, when you install a SchoolsMobile service we automatically collect certain data.

The type of data which may be automatically collected, as part of a SchoolsMobile service includes:

- Data required to detect, evaluate, and prevent malware and spam;

- Data required to ensure SchoolsMobile remains effective in the provision of the service including domain and traffic data.

- Your child’s internet, app, or network usage (including domain names of websites your child visits, information about applications installed on your child’s device, or traffic data); and

- Device performance information, crash logs, and other aggregate or statistical information.

NOTE: This data is not stored by us and any data which is retained is only retained for a maximum of 90 days to facilitate reporting and enable us to meet any other protection-related obligations.

Data received from third parties – If the SchoolsMobile service is being provided through your child’s school, or as a school-mandated policy, there is certain data we will collect to enable us to set up the service to meet School requirements. We may receive data about you or your child from your child’s school in order to deliver the Schools Mobile service.

The type of data which may be provided includes:

- Contact information (such as name and email address)

 

4.    How we use your or your child’s data

We will use only your data where the law allows us to and in the following circumstances:

- To meet the obligations and commitments we have made to protect your children, or

- To comply with a legal obligation.

The purposes for which we will use your data include:

- To help with protection: where you have installed the SchoolsMobile service on your child’s device, it runs in the background of the device to predict threats and protect your child.  It will use data to:

- Analyse, isolate and identify threats, vulnerabilities, viruses, suspicious activity, spam, and attacks, and communicate with you or your child about potential threats;

- Inform our authorised threat intelligence database provider(s) and threat research partners to help respond to new and emerging threats;

- Check for service updates and create performance reports to ensure the protection aspects of the service are performing properly.

Change of Purpose

Any change to this policy will be advised to you in advance of the change taking effect.

 

5.    Disclosures of your personal data

We may only disclose the data we collect to third party service providers who process the data on our behalf for the purposes set out above. These third parties include:

- hosting services providers such as threat intelligence database providers;

- third party payment service providers where you are paying directly to access the SchoolsMobile service.  Note: In this instance, we will only share the transactional data necessary to enable them to perform the function of billing or invoicing.  At no time will we store or access your personal financial data or transaction details except as required by law.

- Your child’s school, where the school is paying for the service.

- Other parties as you direct us, or as required by law.

6.    Data sovereignty and international transfer

We do not transfer any data outside the UK.

7.    How do we protect your data?

We have put in place appropriate security measures to prevent your data from unauthorised access, use, alteration or accidental loss or disclosure. Except as required by law, we limit access to your data to SeQrd personnel, agents, contractors or other third parties as detailed above. We demand that they only process your data on our instructions and they are subject to a duty of confidentiality and protection.

We have put in place processes and procedures to respond to a suspected data breach and will notify you and the relevant authorities of a breach as required by law.

8.    Your child’s privacy

The SchoolsMobile service provides security features that you may use, as a parent, guardian, or carer, to monitor your child’s online activity, or use of a registered, internet-connected device. SeQrd will always require parental consent to provide our service, and we do not use any data collected from your child’s device(s) (detailed above) for any purpose other than to deliver our service.

Our service also allows you to delete your child’s profile at any time. If you believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please contact us as detailed at paragraph 2 above.

If you are under the age of 18, you must have your parent, carer, or guardian’s permission to access the SchoolsMobile service.

At SeQrd, we encourage all parents to instruct their children never to give out their real names, addresses or phone numbers to anyone without parent, carer or guardian permission. 

9.    Data retention

We only make use of your data for as long as reasonably necessary to fulfil the purposes for which we collected it (detailed above) or for 90 days, whichever is sooner. We reserve the right to retain your or your child’s data for a longer period in the event of a complaint or if we reasonably believe there is the prospect of litigation or other potential legal requirement.
 

To determine the appropriate retention period for data, we consider the amount, nature and sensitivity of the data; the potential risk of harm from unauthorised use or disclosure of the data; the purposes for which we processed the data; whether we can achieve those purposes through other means; and, applicable legal, regulatory, tax, accounting, or other requirements.

10.    Your legal rights

Under UK data protection laws, you have rights in relation to your or your child’s data, including, under certain circumstances, the following:

- Request access to your personal data;

- Request correction of your personal data;

- Request erasure of your personal data;

- Object to processing your personal data;

- Request restriction of processing your personal data;

- Request transfer of your personal data; and

- Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at: info@seqrdtech.com