This Privacy Policy provides information on how ischool Inc. collects, uses, protects, and otherwise processes personal information when you visit our websites, including https://www.ischool.com.tw, (our “Websites”), or use our related software and online or mobile services provided on or in connection with our Websites (collectively, the “ischool Products”). ischool Products Users: How we collect information and how we use information may differ based on our relationship with you. In the ‘Our Relationship with You’ section below, we’ve detailed the different relationships we may have with you, and our respective use of information we collect. References to “us,” “we,” “our,” or “ischool” in this Privacy Policy, are referring to ischool Inc. and its affiliates.

Customer Data: ischool is committed to the protection of personal information. As a provider of education technologies, our customers, which are comprised of schools, school districts, and higher education institutions (collectively, “Customers”), entrust us with their data, which may include personal information of their employees, parents, and students (“Customer Data”). We collect and process Customer Data solely on behalf of our Customers, and in accordance with our agreements with the Customers. We do not use or disclose Customer Data except as authorized and required by our Customers and as provided for in our agreements with our Customers. Because ischool does not own or control Customer Data, any request for access, review, correction, or deletion of Customer Data must come directly from our Customers.

We support privacy rights and have developed and implemented policies, processes, procedures, and technologies to collect, use, protect and process Customer Data on behalf of our Customers with those privacy rights in mind. We are also a signatory of the Student Privacy Pledge.

1. Web Users: For users of our Websites, we offer details on how ischool collects and uses information from or about you.

2. ischool Products Users: For Customers and end users of our ischool Products, such as parents and students, we provide information on how we collect, process, use, and disclose your personal information through the provision of the ischool Products.

ischool Products Users: For Customers and end users of our ischool Products, such as parents and students, we provide information on how we collect, process, use, and disclose your personal information through the provision of the ischool Products.

1. CUSTOMERS

   When does a customer’s privacy policy govern? In connection with the ischool Products, we are considered a “data processor” with respect to any personal information or Student Data (as defined below) provided to us by our Customer about you. That means your school or school district’s or higher education institution’s privacy statement, privacy notice and consent form govern the collection and use of your personal information. Our Privacy Policy does not supersede the terms of any consent form, privacy notice or privacy statement from your school, school district or higher education institution, or stated alternatively, the terms of any agreements between you and your school or school district, or higher education institution (our Customer).

2. SECURITY

   How is customer data protected? Any data provided to us for processing in our applications by a Customer is Customer Data. ischool employs a variety of physical, administrative, and technological safeguards that are designed to protect Customer Data against loss, misuse, and unauthorized access or disclosure. We strive to continuously maintain reasonable physical, administrative, and technical security measures. Our measures consider the type and sensitivity of the data being collected, used, and stored, and the current state of technology and threats to data.

3. VENDORS, PARTNERS, AND OTHER DISCLOSURES

   Why would my data need to be shared with any 3rd parties? ischool works with vendors or partners engaged directly by us to fulfill our obligations to our Customers. Customers may also contract directly with a 3rd party requiring that we share access to Customer Data with a 3rd party. Some disclosures may also be required by law.

   1. Vendors. We engage directly with certain third-party companies to help us provide the ischool functionality to our Customers, or to you, or to perform work on our behalf (“Vendors”). Our Vendors are required to abide by our privacy and security instructions and are contractually restricted from using any Customer Data accessed or received through us for any purposes other than as needed to perform such services. We may use Vendors to help us conduct marketing campaigns or events and disclose Customer contact information necessary for those activities.

   2. Partners. An educational institution may work with third-party companies to provide additional content and functionality which requires access to ischool Products (“Partners”). Only with your educational institution’s permission, ischool will share information about you (such as your name, email, or student ID), that is required to provide you with access to the ischool Products that have been requested by your educational institution. In these cases, these Partners will enter into an agreement directly with your educational institution regarding the processing of any provided data.

   3. Other Types of Disclosures. We may also need to share certain portions of Customer Data under the following circumstances:

      1. We may need to disclose Customer Data to comply with legal or regulatory requirements and to respond to lawful requests, such as court orders and subpoenas within a legal proceeding. Where such disclosures relate to personal information we hold as a data processor on behalf of our customers, we will refer such requests to our customers where permissible.

      2. We may need to disclose Customer Data to protect and defend the rights, property, or safety of our customers, including enforcing contracts or policies, or in connection with investigating and preventing fraud or other misuse of our systems.

      3. Where permitted by applicable law, we may utilize aggregated or de-identified (anonymized) information that is no longer associated with a person for internal purposes, such as to enhance and promote the ischool Products. ischool does not rent, sell, or otherwise provide access to student personal information to third parties for marketing or advertising purposes.

From the moment you first interact with one of the Websites, we or the districts who offer the ischool Products may collect personal information. Sometimes we collect personal information automatically when you interact with our Websites and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.

Note that if you are on an ischool application website to access a service or product, you may need to log in to make use of the functionality of the particular product.

1. ischool’S RELATIONSHIP TO YOU.

   1. ischool as a “data controller” for Public Website Users. With respect to the personal information of users received through our Websites, such as when you visit our Websites or fill out one of our contact forms, ischool acts as a “data controller” in relation to that information. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed.

   2. ischool as a Data “Processor” for ischool Applications. ischool’s business is in the licensing of access to applications for our Customers to support their educational activities. Our Customers provide data on students collected from parents or the students (“Student Data”). In connection with the Student Data ischool receives from our Customers as part of the services, ischool acts as a “data processor.” A “data processor” is an entity that processes personal information on behalf and at the direction of the data controller.

2. INFORMATION WE COLLECT

   1. Directly from you. You may voluntarily provide us information when you complete a form or survey on our public website or subscribe to our blogs or newsletters. You may also provide information when you register for an account through a Website to log in to use a ischool Product.

   2. Indirectly from you. We collect information about the pages your device’s browser visits and how you access and use the Websites using cookies, tracking technologies and other third-party analytics tools. Specifically, We and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags on our Websites. This includes information about the devices you use to access the Websites including, but not limited to, unique device identifiers, IP address, operating system, browser, and cookies. Depending on your device settings, we may also collect information about your approximate geographical location.

3. HOW WE USE THIS INFORMATION.

   1. Product Improvements/ Requested Communications. We use the information collected to provide and improve our Websites and ischool Products, and to analyze usage information for sales and marketing purposes. We also use the information collected to communicate with you in any manner that you have requested. This analysis is necessary to further our legitimate interest in understanding our users and their interactions with us and our websites in order to best iterate and improve our public websites and communications, including marketing purposes, and to provide you with content that you have requested.

   2. Marketing. We conduct marketing to promote the ischool Products, but do not use or disclose student information (whether personal information or otherwise) provided by customers into our platforms for targeting of advertisements to students. When we conduct (or sponsor) events, conferences, and webinars, we will collect information about attendees, such as the session they attend and their contact information to provide them information about ischool Products and other ischool information.

   3. Interest-based Advertising. We use third party advertising tools to collect information about your device browser’s visits to the Websites to provide targeted advertisements to you based on your browsing history on other websites or on other devices you may use. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to receive advertisements, but they will no longer be tailored to your interests.

   Please note that we avoid the use of Student Data for targeted advertising purposes, for example, by inhibiting these third-party advertising networks from collecting information for targeted advertising purposes when a student logs into the service through their student Account. Additionally, we do not knowingly direct targeted advertising to individuals we know to be students on our service or on any other website or online service.

4. HOW WE SHARE THIS INFORMATION.

   We use third-party analytics tools to help us understand how the Websites are used, these parties will have access to some of your personal information. This includes analytics tools such as Google Analytics.

This section of our Privacy Policy describes how Customer Data, which may include parent and student personal information, is used when ischool Products are provided through our Customers. How that information is used depends on our Customer (school, school district or higher education institution), which is the “data controller.” Please consult your school or institution’s privacy statement for more information on how your personal information is processed.

Why would ischool receive and use data about you? If you are a user of ischool Products, your information has been provided to us by our Customers. We provide the ischool Products directly to our Customers (your school, school district or higher education institution). These institutions act as a “data controller” for purposes of any of the personal information provided to ischool. Under an agreement with your institution, ischool acts as a “data processor” on behalf of and at the direction of our Customer. This also means that our Customer’s privacy policy governs the use of student personal information. ischool’s Customers determine what information we process through the ischool Products (which may include Student Data), how it is used, and provide us instructions for how we process that information under the terms of our contract with our Customer.

Who Owns Student Data? All Student Data is solely owned, and thereby controlled, by our Customers (school, school districts or higher education institutions). Our Customers are responsible for obtaining from students (or their parents, as applicable) a right to collect, use, and share Student Data for legitimate educational purposes. Our Customers license ischool Products for the purpose of providing, maintaining, and supporting such data for those legitimate educational purposes. ischool will only use Student Data for the purposes of providing the ischool Products that our Customers (school or school districts) have contracted with us to provide, and we will process such Student Data according to instructions and the terms of our contract with our Customers.

1. WHAT INFORMATION DO WE COLLECT

   The information collected from you depends on the specific product and what is needed to integrate with the educational institutions’ systems, set up and maintain your accounts. This includes information in the following data categories:

   1. Student records. Typically, the information would include pupil records of students and parents of students enrolled in your school or district, such as directory information, email addresses, student IDs, account credentials, courses students are enrolled in, health information kept in student records. The exact elements will depend on the product.

   2. Customer employee records For our enterprise resource planning (“ERP”) products and human resources/talent products, we also collect employee account information of our Customers including usernames, email addresses and titles to initially set up products and services for you.

2. HOW INFORMATION IS COLLECTED OR PROCESSED

   1. Directly from you. We collect information necessary to provide the educational technology services as directed by you.

   2. Indirectly from you. We collect device and usage information when you access and use the ischool Products, including information that your browser or the mobile app sends when you are using our products. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service and cookie data.

   3. From third parties. With our Customer’s consent, we may receive information from other third parties and combine that information with Customer Data. For example, we may receive limited personal information from third-party services that integrate with or complement the ischool Products in order to provide you with the best possible user experience.

3. HOW WE USE INFORMATION.

   We use your information in accordance with the agreements with our Customers, and which may include providing the features and functionality of the ischool Products, as well as to communicate directly with our Customers and allow our Customers to communicate with other ischool users. It is necessary for us to use information in this manner to provide our Customers with the services requested pursuant to its agreement with ischool.

   We may also use your information to provide you with news and information about upcoming new products and services. Any such marketing communications from us may be discontinued at any time. We may also use de-identified and aggregated information to understand and improve the ischool Products. Any information that may be de-identified will not be ‘re-identified.’ We may share general customer contact information with certain Partners as is necessary to offer and provide the ischool Products to our current and prospective customers. No customer data other than general institution contact information is provided for these purposes.

   We do not provide any Student Data to any third parties for marketing purposes.

4. HOW WE SHARE INFORMATION

   We share information to provide the ischool Products to you and further improve them. Within ischool, your information will be accessed only by those who have a need to know as they support the provision of the ischool Products. We use vendors to help us provide the ischool Products to your school or school district.

5. DATA RETENTION

   We keep information collected on behalf of our Customers for as long as necessary and pursuant to contractual terms or as otherwise required by applicable law. We dispose of information that is not held pursuant to contractual terms in a commercially reasonable time period or at the request of a customer.

We may update this Privacy Policy and its last updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions or concerns about your privacy or this Privacy Policy, please Contact us at support@ischool.com.tw