App Privacy Notice
We are Pro-Skool. We are based at Burgemeester Nilantlaan 42, 7475EB Markelo, The Netherlands. You can reach our Data Protection Officer at firstname.lastname@example.org if you have questions about data protection, or if you have any requests for resolving issues with your personal data.
In this privacy notice we describe:
- * The ways we collect personal data about you when you use our Pro-Skool app and why we do so
- * How we use your personal data, and
- * The choices you have about your personal data.
As a controller, we are committed to a lawful, fair and transparent processing of personal data, adhering to the EU General Data Protection Regulation (GDPR)
Pro-Skool is an app that helps in keeping children safe. It allows school principals to send alerts to teachers about important events that require immediate attention, for example a fire emergency. It also allows parents or care-takers to be aware of the whereabouts of their children and be alerted of anything out of the ordinary. It is not an emergency communications service, but it can help with awareness and reducing negative outcomes.
This Privacy and Cookie Notice covers all different users of our app. We have provided a separate policy for customers and data that we collect when you visit our website or send us a mail.
1. The data we process
If you are a school administrator, you will need to make an account to use the app and its broadcasting service, and provide us with your name, email address, and a billing address for your organization.
In addition, to make the app work, we collect your location data (approximate GPS coordinates) to determine your location.
If you are teacher or other school personnel, you will need to make an account to use the app and its broadcasting service and provide us with your name and email address (to confirm sign-up). If your school or institution already has an intranet, it is possible that your name and work email will be added automatically.
To make the app work, we collect your location data (GPS coordinates) to determine where you are, and if you are at your work location.
Parents / guards:
If you are a parent or guardian, you will need to make an account to use the app and provide us with your name and email address. We’ll also ask for your address and phone-number.
If the school or institution that your children or guards attend would like you to participate in Pro-Skool, they provided us with your name and email to be able to send you an invite. You can always decline the invitation and we will remove the link between you and the school or institution.
If you buy a subscription, we will process your payment details such as credit card information using third-party billing providers.
When you add children or guards, you can give their name (first and last) or an alias and upload a photo for easy identification.
To make the app work, we collect your location data (GPS coordinates) to determine your home location.
Students and children:
If you are a student or child, you don’t need to make an account to use the app. Your parent or guard will add you to their Pro-Skool account. You can then link your phone to their account using the username and password they gave you. When your parent or guard adds you to their account they may enter your name, but they can also use an alias like “My oldest”.
If you want to be able to change settings, you do need to make an account, in which case we ask you to give us your email address so that we can make your account.
After that, there is not any information that you can actively provide. But in order to make the app work, we will collect your location data (GPS coordinates) at a regular interval of about 30 seconds and your phone status (cell or Wi-Fi reception and battery level).
For each user, we capture analytics data using Google and Facebook services.
2. What do we use the data for, and on what legal basis?
We use the data to offer two services:
- Pro -Skool for Schools: With this service, school principals and teachers can send alerts to each other about important events that require immediate attention, in one of four categories: Medical Emergency, Natural Disaster, Gun, and Fire.
- Pro-Skool for Guardians and Children: This service allows guardians (such as parents or care-takers) to be aware of the whereabouts of their children and be alerted if one the following happens:
- – To show a live view of the child or guard on the map.
- – When a student on its way to a safe destination goes out of the pre-determined approved route.
- – When a student stops for more than 5 minutes in the same place in route to a safe destination.
- – When a student leaves or arrives at a safe destination.
- – When a student needs assistance, the app has an SOS button that the student can use to send a notification to the guard. The SOS message does not include the location of the student.
IMPORTANT: Pro-Skool is not a replacement for your phone and you cannot use it for alerting emergency services, like a doctor, first care or first aid assistance, police or the fire department. Pro- Skool is not connected to 911, 112 or any other police or medical assistance program or system. Pro-Skool is not a substitute for any pre-established protocol for emergencies in your school, university, office, etc.
If you have an account, we also send you a periodic newsletter to let you know about new features, how to use our app, and so on. We give you an opportunity to opt-out when you make the account, and with every newsletter email.
We base our processing on the consent of the data subject. For the students and children, this means that if they are younger than 16, their parent or guard gives consent on their behalf.
3. A note on the sensitive nature of your data
Pro-Skool is an app that is designed to help keep children safe. It allows school principals to send alerts to teachers about important events that require immediate attention, for example a fire emergency. It also allows parents or care-takers to be aware of the whereabouts of their children and be alerted of anything out of the ordinary. It is not an emergency communications service, but it can help with awareness and reducing negative outcomes.
Pro-Skool is not intended to be used as a tool to continuously follow the whereabouts of your children or guards.
We designed Pro-Skool in such a way to limit the possibility of continuous surveillance, while keeping the intended safety features. For example, with Pro-Skool parent and guardian app you can have a live location view and see the location history of your children or guards for 1 day or up to 10 days (the later requires a subscription). We are aware of the possibility for a parent or guard to use Pro-Skool in such a way to keep an eye on the whereabouts of their children and guards, even if they don’t need to be ensured about the safety of the child. But Pro-Skool would not work without offering a live location view and limited location history that does not require an action or active consent from the child at the time that the parent or guard needs to see the live view or history. But in the way that location information, map views, and notifications in Pro-Skool work, the app does not support or actively encourage continuous monitoring.
In short, when you want to use Pro-Skool in your school, university, organization or family unit, talk with your students, children and guards about using Pro-Skool, why it is important to you, what the app does and what the app doesn’t do, and how you will use the app.
4. Who we share data with
We do not actively share data with any third-parties, other than parties acting on our behalf. These are providers of technical services that act on our specific instructions. You can find a list of current data processors here: http://www.pro-skool.com/privacy/processors.
5. How long and where do we store data
- We store the data of app users for as long as they have an active account and for a limited amount of time of up to 3 months thereafter (to allow for automatic deletion and account recovery).
- For paying customers, we keep financial information for at least 7 years to be able to meet our obligations to keep accurate records for the tax authorities.
6. How do we protect data?
Taking into account the nature, scope, context and purpose of the processing, we have taken the following technical and organizational measures:
- Our database, and the information contained therein, is protected with access control and hardened against known attack vectors and vulnerabilities.
- Access to the database is limited, not all staff in our organization have full access.
- Data stored in the app is encrypted.
- Data transmitted to and from the app is encrypted. This protects you from someone intercepting data when you use public Wi-Fi hotspots.
- We use tokes for verification of credentials
- Other apps on your phone cannot access the Pro-Skool data.
We actively monitor the security of our database.
7. Transfer of your personal data
You should also know that your personal data may be transferred from your home country to third parties. If you are an EU resident, this could imply that we also transfer data to countries that do not offer an adequate level of protection for your personal data. When we transfer this data, we will do so only when we have put in place appropriate safeguards to protect your personal data. Please contact us to get a copy of the safeguards that we have put in place. Our contact details are at the bottom of this text.
8. Your Rights
You have the right to request access to your personal data that we process. You also have the right to:
- Rectify incorrect personal data or erase it in certain circumstances.
- Restrict or object to the processing of your personal data.
- Receive your data so that you can use it elsewhere (data portability).
Where we process data based on your consent, you also have the right to withdraw your consent at any time but we would like to point out that this does not affect the lawfulness of the processing before the date that you withdrew your consent.
If you wish to exercise any of the above rights, please write us at email@example.com. We will respond to all requests within a reasonable timeframe. You also have the right to lodge a complaint with your local EU data protection authority for unresolved complaints.
9. Version information
This policy was last updated on 7 December 2018.
It can be viewed on: http://www.pro-skool.com/privacy/app-notice.