Privacy notice

United States

Wonde Inc operates and provides software which comprises of its website, platforms and applications, including (but not limited to) our products and services which we operate through our website www.wonde.com and our school and applications portals (“Site”) for those that visit our Site and those that access our Site as an authorized user (“Authorized User”). Our Site is used pursuant to an agreement or with the permission of school districts or state agencies.

At Wonde, we take privacy very seriously. We have prepared this privacy notice (“Privacy Notice”) to ensure that we communicate to you, in the clearest way possible, how we treat your personal information. We encourage you to read this Privacy Notice carefully as it governs the use of our Site.

By engaging with us online and through other channels, you agree and acknowledge our collection, use, and disclosure practices, and other activities, as described in this Privacy Notice. If you do not agree with the practices disclosed in this Privacy Notice, please discontinue your use of the Site and our services.

This notice sets out how we look after your personal information if you are a:

Parent, guardian or student;
Member of staff of education establishment such as a school or college;
An Authorized User;
Visitor to our Site;
Supplier or business contact of Wonde;
Third party education application;

This Privacy Notice (together with our Data Processing Agreement, any License Terms and Conditions, Website Terms of Use and any other documents or terms incorporated by reference) describe the types of information that we collect from you, through the use of our products and services (“Services”), including the use of our Site, and how that information may be used or disclosed by us and the safeguards we use to protect it. We will not use or share your information with anyone except as described in this Privacy Notice.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

We may update this Privacy Notice from time to time, and you can find our latest notice on our Site or by asking us for a copy.

1. What does Wonde do?

We provide applications and platforms to help schools better manage and securely control their data. Our Wonde platform integrates with a school’s information systems (“SIS”), to allow schools to seamlessly transfer data to and from third party application providers.

In most cases, Wonde acts as a data processor. This means we assist the school and the application provided to transfer your personal data, and that of students, to and from each other. In these cases, the school will be the data controller and the entity responsible for deciding how and when your personal information is collected and used, whilst we follow the instructions of the school. The school, and, in some circumstances, the third party application provider, will be data controllers. The school should provide you with their privacy policy or privacy notice, setting out how the school uses your personal data and the lawful basis for doing so.

Where we act as a data processor, we have legally binding agreements in place with the applicable school district or state agency (and third party application provider) which restrict how we process your personal information, in accordance with the Data Protection Legislation. This includes personal information processed through our Site and any applications we supply.

When you log in to our platform through our Site, visit our Site generally, or contact Wonde support, we will receive certain information directly from you, such as your name and login details. For this limited information only, we will be the entity responsible for deciding how and when your data is used, and we will be the data controller. We are a data controller when we collect personal information from suppliers and other third parties who interact with us.

2. The information we collect and how we collect it

We collect, use, store and transfer some or all of the following information from the users of our Site or users of Wonde support:

Identity Data: this includes your name. Contact Data: this includes your email address, telephone number and postal address.
Cookies Data: like many websites, we may use some “cookies” to enhance your experience and gather information about the visitors and number of visits to our Site.
Technical Log Data: this includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services.

In certain circumstances, you may choose to withhold your personal information from us, but please know that this means that we may be unable to provide you with our Services

We may collect your personal information from different sources:

We collect all of the types of personal information listed above directly from you when you interact with us. This includes when you register with our Site, and when you login to our Site or use Wonde support or the Services.
We collect Student Data, Identity Data, and Contact Data from the school(s) you are connected to.
We collect Technical Log Data automatically when you interact with our Site, Services or platform, by using cookies and other similar technologies.

We consider Student Data to be confidential and we collect and use Student Data solely for educational purposes in connection with providing our products, as described in this Privacy Notice and our agreements with school districts or state agencies. We work to maintain the security and confidentiality of Student Data that we collect or store, and we enable our customers to control the use, access, sharing, and retention of Student Data.

3. How we use your personal information

We will only use your personal information when the law allows us to. We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:

Direct interactions

This is information (including Identity, Contact and Financial Data) you consent to giving us about you when you fill in forms through the Site or Services, or by corresponding with us (for example, by email or chat). It includes information you provide when you register or subscribe to any of our Services, visit or use the Site when you create an account with us, or when you report a problem with our Services, or the Site generally. If you contact us, we will keep a record of that correspondence.

Information we collect about you and your device either automated or otherwise

Each time you visit our Site or use our Services, we will automatically collect personal information including Technical Log Data. We collect this data using cookies and other similar technologies including server logs. We may also receive technical data about you if you visit other Sites employing our cookies.

Information we receive from other sources including third parties and publicly available sources

We may receive personal information about you from various third parties such as government bodies, local authorities or schools, but we will only use and process the personal information we receive from these sources where we are allowed to do so.

We do not allow our third-party service providers to use your personal information for their own purposes and we only permit them to process your personal information for specified purposes and in accordance with our instructions(which includes strict confidentiality and contractual terms). We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose for which it was collected. We will only use your personal information when the law allows us to.

Most commonly, we will use your personal information in the following circumstances:

Where you have consented before the processing.
Where we need to perform a contract we are about to enter into, or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where we are otherwise permitted to use your personal information, consistent with applicable law.

When we are acting as a data controller, we will use your personal information for the following purposes:

To allow you to access your account on our Site
To allow you to communicate with our school district or state agency customers, including your school/the school your children attend
To provide support to you when you contact us
To manage our relationship with you,
Where you are a third party application, to register you as a third party application and to facilitate the provision of such services to any school or education establishment.
Where you are a local authority or a government body, to facilitate the provision of any services through our Site and/or our applications.
To administer and protect our business and our Site, Services and/or our applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
To assess security controls, and conduct system audits, and to detect or prevent fraud or other harmful activities. To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences.
To create anonymous aggregated data, as set out below.
To comply with applicable laws and regulatory obligations.

We do not use Student Data for marketing purposes, but we may use certain personal information for marketing in limited circumstances, or as otherwise permitted by law or with your consent.

Aggregated Data

We may aggregate and use non-personally identifiable data we have collected from you and others. This data will in no way identify you or any other individual.

We may use this aggregated non-personally identifiable data to:

assist us to better understand how our users are using our Site and services;
provide users with further information regarding the uses and benefits of our Site and services;
enhance school productivity, including by creating useful school insights from that aggregated data and allowing benchmarking of performance against aggregated data; and
otherwise to improve our Site and services.

Cookies when using our Site

We use a Cookie consent management tool to manage your Cookie options. Upon visiting our site you will be asked to select your cookie preferences. If you would like more information on how we handle Cookies, please view our cookie policy at https://www.wonde.com/cookie-policy/.

4. Sharing your personal data

We may need to share your personal information when using your personal information as set out above. We may share your personal data with the following third parties:

Our school district or state agency customers in connection with the products we provide to you (pursuant to an agreement)
Our professional advisers, including lawyers, auditors and insurers.
Our service providers, subprocessors, vendors and associated companies who may provide IT, business and system administration services, or who store or manage data on our behalf.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

We may also share your personal information to comply with the law, respond to requests in legal or government enforcement proceedings (such as complying with a subpoena), protect our rights in a legal dispute, or seek assistance of law enforcement in the event of a threat to our rights, security, or property or that of our affiliates, customers, Authorized Users, or others.

Where any of your personal information is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under applicable privacy laws.

We will not:

sell Student Data to third parties
use or disclose Student Data to inform, influence, or enable targeted advertising to a student based on Student Data or information or data inferred over time from the student’s usage of the Site or related products
use Student Data to develop a profile of a student for any purpose other than providing the products to a school district or state agency customer or Authorized User, or as authorized by a parent or legal guardian
use Student Data for any commercial purpose other than to provide the Site or related products to a school district or state agency customer or Authorized User, or as permitted by applicable laws.

We may use de-identified Student Data to recommend educational products or services to our school district or state agency customers and Authorized Users (subject to exceptions permitted under applicable law), or to notify such users about new educational product updates, features, or services.

5. International transfers

Subject to us complying with applicable privacy laws and ensuring appropriate safeguards are in place, we may transfer your personal information to third parties providing services to us who are based outside of the United States without obtaining your specific written consent. This may include parties providing IT administration services and hosting services, and parties providing assistance with managing our marketing databases.

6. Retention period

We will only retain your personal information (including Student Data) for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, as described in this Privacy Policy.

We do not knowingly retain Student Data beyond the time period required to support a school district or state agency customer or Authorized User’s educational purpose, unless authorized by the applicable customer or Authorized User. Upon request, we will return, delete, or destroy Student Data stored by us in accordance with applicable law and customer requirements. We may not be able to delete all data in all circumstances, such as information retained in technical support records, customer service records, back-ups, and similar business records. Unless otherwise notified by our school district or state agency customer, we will delete or de-identify Student Data after termination of our agreement with the school district or state agency Customer.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. Data security

Data security is of great importance to us, and to protect your data we have put in place industry standard physical, electronic and managerial procedures to safeguard and secure data collected and processed through our Site and the Services. We have implemented significant security measures to maintain a commercially-reasonable level of security.

In the event we discover or are notified that Student Data within our possession or control was disclosed to, or acquired by, an unauthorized party, we will investigate the incident, take steps to mitigate the potential impact, and notify the relevant customer, in accordance with applicable laws.

Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

If we give you a password upon registration on our Site, you must keep it confidential. Please don’t share it.

8. Your privacy rights

You have the following rights, where provided under applicable state law, regarding your personal information (each of which are subject to various exceptions and limitations):

Access

You have the right to request that we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the categories of personal information sold or shared, the business or commercial purpose for collecting, selling, or sharing the personal information, the categories of third parties with whom personal information was shared, and the specific pieces of personal information collected about you.

Correction

You have the right to request that we correct inaccurate personal information collected from you.

Deletion

You have the right to request that we delete your personal information that we maintain about you.

Opt Out (Do Not Sell or Share My Personal Information)

You have the right to opt-out of the “sale” of your personal information and the “sharing” of personal information in connection with the display of “targeted advertising” across third party websites, as these terms are defined under applicable U.S. state privacy laws. These terms are defined broadly to include situations where we provide personal information to partners who provide advertising services to us. You can direct us not to sell or share your personal information by contacting us at [email protected].

No Discrimination

You have the right not to be discriminated against for exercising these rights.

Appeals

You have a right to appeal decisions concerning your ability to exercise your consumer rights.

Submission of Requests

We honor requests as and to the extent required under applicable laws, which may be based on where you live. You may request to exercise the above rights by emailing us at [email protected]. Note that we may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes.

Authorized Agent

You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent and can show written permission from you to represent you. We may contact you directly to confirm that you have authorized the agent to act on your behalf and confirm your identity.

Verification

Whether you submit a request directly on your own behalf, or through an authorized agent, we may take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and the nature of your request.

9. Children

We do not obtain any personal data relating to children when we act as a data controller through the provision of our Services. In the circumstances where we do collect and process personal data relating to children in our role as data processor (on behalf of our school district or state agency customers), we recognize that we need to have further justification for the collection, storing and use of this information. In those circumstances, a parent or guardian must authorize us to collect the information needed to use the Services, and we do so only on the careful instructions of our school district or state agency customer, and solely in accordance with applicable laws. If you are a parent or guardian and have questions about your child’s use of the Services and any personal information collected, please direct your questions to your child’s school.

We have in place appropriate policies and safeguards when processing such data as referred to in this Privacy Notice. 10.

10. Third-party Links

The Site and Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

11. Changes

We keep our privacy policy under regular review. This version was last updated as specified at the top of this page.