SPLAT Software Privacy Policy

SPLAT Software Privacy Policy

Updated 03/10/2021

RightSize Business Systems and RightSize Education Technologies, Inc. (collectively, “RightSize”) protects the personal information of everyone who uses, or whose data is stored in our SPLAT web applications and mobile apps. The use of the software is governed by the Terms of Use document which can be found at https://www.splat-ph.com/terms-of-use.

This privacy policy covers SPLAT Teacher, SPLAT Family and SPLAT Administrator applications for web and mobile devices (collectively “SPLAT”). SPLAT is offered in the USA and Philippines and there are significant differences in the data we collect and store although the web sites and the apps are universal. Data is stored exclusively in the same country as the school system.

Compliance with government laws and industry privacy standards

SPLAT is fully compliant with the following Acts in both the USA and Philippines (without consideration of the country of use):

• United States’ Privacy Policy Act of 1974
• Children’s Online Privacy Protection Act (COPPA)
• California Consumer Privacy Act (CCPA)
• Philippine Republic Act 10173 also known as the “Data Privacy Act of 2012”

We commit to:

• Not collect, maintain, use or share learner personal information beyond that needed for authorized educational/school purposes, or as authorized by the parent/learner
• Not sell, lease or share learner personal information except as required by law
• Not use or disclose learner information collected through an educational/school service (whether personal information or otherwise) for behavioral targeting of advertisements to learners
• Not build a personal profile of a learner other than for supporting authorized educational/school purposes or as authorized by the parent/guardian or the learner
• Not retain learner personal information beyond the time period required to support the authorized educational/school purposes, or as authorized by the parent/learner except as such data may exist in aggregate form on historical backup media or where we are required to preserve data to comply with applicable retention laws.

Overview

We receive foundational data from your school system about learners, teachers, school system personnel and parents/guardians. This is enriched by teachers and personnel who add information about learners’ progress and performance. Depending on your school’s use of SPLAT, this may include attendance, participation in classroom activities, grades, positive and unexpected behaviors, communications with families and limited health data.

Family members, including learners, can view most of this information. Families can communicate with the school system using SPLAT and learners can receive education materials and submit class requirements including graded activities. All of this data is linked to the learner, relevant school system personnel and family members.

SPLAT tracks and records usage of the systems which is linked to the user. Usage tracking may include course location data in the future to combat cheating, but this is not tracked as of the publish date of this policy.

Learners

For all learners, we receive roster data which may include Personally Identifiable Information (PII). This typically includes learner name, ID number, grade level, class schedule. For Philippine learners, we receive additional data, some of which may be Sensitive Personal Information (SPI). This includes information about date-of-birth, ethnicity, spoken language and contact information for parents and guardians. Depending on the school’s use of SPLAT, we may collect and store additional information such as attendance, classroom participation, grades, behavior data as well as height and weight health data.

School Personnel

School personnel may use SPLAT Teacher or SPLAT Administrator depending on their roles. For teachers and personnel, your school system usually provides name, ID number and email address. Depending on features selected, the school may also provide or we may collect information such as occupation, title, academic history, employment history, date-of-birth, gender / gender identity and contact information including phone numbers. Usage data, including time and date stamps for actions such as attendance entry, are tagged to the user. SPLAT may be used to route personnel’s personal information through approval cycles, such as Professional Development training requests. In these cases, additional PII and SPI may be collected and stored.

Family

SPLAT Family collects and stores different data depending on its use:

• SPLAT Family for parents / guardians of a learner enrolled in a SPLAT school may be used to view academic progress and proficiency. When used solely in this way, SPLAT does not collect any linked information about the person using SPLAT although general usage data is collected. SPLAT has features which allow a parent / guardian to communicate with the school and to request updates to contact details. If these features are used, the communications and data will be stored in SPLAT and linked to the content creator and recipients. Requests for data cleanup or removal should be sent to your school system. If a school system terminates the use of SPLAT, all learner, teacher and personnel data will be removed or anonymized.
• SPLAT Family may be used by a learner for Self Paced Learning to view learning materials and take assessment tests and quizzes. Data is collected about learner progress and performance when these materials are viewed and questions answered. A learner using self paced learning may compose written works such as essays and may take photos, record audio and / or videos to complete an assignment. These written works, pictures and recordings are associated with the learner and can be viewed by parents / guardians as well as members of the faculty who have a legitimate need to read, view, listen or watch to determine scholastic accomplishment. These works, as well as the learning content provided by the school, remain the intellectual property of the owner / creator.
• A family may elect to license SPLAT Home features. When enabled, these features allow a family to coordinate schedules, assign chores, redeem points for privileges and create behavior contracts. SPLAT Home may be used without PII or SPI data, but a family may choose to include such data and may add pictures of family members. A family may include members who are not part of a SPLAT school. SPLAT Home data is stored separately from school data on our servers and will be removed or anonymized upon termination of use.
• SPLAT Custody is an add-on product for SPLAT Home, which helps manage custody calendars and time swaps. If one parent discontinues use while the other remains enrolled, historical data for both parents will be retained to preserve database integrity. We will honor requests to remove or anonymize all PII and SPI about the parent who discontinues use. All data will be removed or anonymized upon termination of use by both parents.
• SPLAT After School is similar to SPLAT School except that we will honor individual data removal requests unless data retention is mandated by government laws.

Security Measures

We are committed to protecting the personal information used and stored by SPLAT. Data is restricted to only those with a “need to know” on a tiered basis. PII and SPI data is encrypted in all data stores: cloud, school servers and gadgets. All data “in motion” is encrypted. Secondary personnel see limited Learner data and only when explicitly allowed by school management. Gadgets require a Personal Identification Number (PIN) in addition to log-in. Only full-time, regularized employees of RightSize will have access to Learner or Employee data and these employees have signed a confidentiality agreement, which includes this data access. RightSize has documented processes for maintaining the confidentiality of data, which are incorporated into our Human Resources Policy.

SPLAT is designed with situational security. This security model restricts faculty and staff to only access the data they have justification to see. For example, a teacher can only see the learners in the classes they teach, and then only the data generated in those classes. Certain school personnel, for example a lunch-room monitor, can use SPLAT to reward a learner, but they cannot see any other information about the learner’s classes, schedule, etc.

We may use anonymized data for analytical purposes. We will assist your school to use the data we collect as they deem appropriate.

While we strive to protect user information, no server, computer, communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. We also do not have control over the security of computers, mobile devices, or electronic communication and transmission methods that you may use. By using our products or services on your own equipment, you agree that you are solely responsible for any information that you provide and transmit to us. You can help us maintain a secured community and protect your account against unauthorized access by keeping your password confidential at all times.

Information Collected Automatically

We use Google Analytics and Google Tag Manager for web, Android and iOS to learn about how people use SPLAT. This usage data is not tagged to the individual. We may use geo-location in the future to analyze usage patterns and to combat cheating, but these features have not been implemented as of the date of this document.

How We Communicate With You

We may contact you regarding your account, software updates and new features, security and privacy notices, customer service purposes, and other information regarding our products and services. We may communicate with you through email, SMS messages, social media updates and push notifications. You may opt-out of marketing messages in your SPLAT profile or by sending an email to Splat.info@rightsize.com.

Your Options

Your school maintains their data stored in SPLAT and determines which features of the software to enable. If you wish to know what is stored, or to correct or delete any information, you may contact the school directly. For data privacy reasons, we are unable to release any information directly. Your After School program may store data in SPLAT. Contact the after school program regarding this data.

If you subscribe to SPLAT Home or SPLAT Custody, your application data will be removed or anonymized upon termination of use. If you wish to remove your information from our marketing database, contact us by sending an email to Splat.info@rightsize.com.

Compliance with Laws

RightSize stores school and learner data exclusively on servers located physically in the same country as the school. We will work with any school system who wishes to audit or inspect our compliance with applicable laws, security protocols or physical locations.

Notification of Changes

This Privacy Policy may change from time to time and we will post all changes on SPLAT which will require your agreement. If at any point you do not agree to any portion of the Privacy Policy or Terms of Use, you must immediately stop using SPLAT and our services. Upon termination, we will delete or anonymize any data not maintained by the school system or that we may be required to maintain to be in compliance with applicable data retention laws.

In the event of a merger or acquisition by another entity, we will allow the successor entity to maintain the learner personal information provided they agree to these policies. Should the successor entity not agree to these policies, we will notify you so you can evaluate their policy. If you do not agree to their Privacy Policy or Terms of Use, we will delete or anonymize your data prior to the merger or acquisition.

SPLAT is a registered trademark of RightSize Business Systems