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• • Definitions
    You - the school using Connect (data controller) 
    Us - School Apps Ltd (the data processor)

    This Privacy Policy (the “Policy”) applies to your use of the School Apps Ltd transactional email services (the “Services”), included the Connect platform (the “Platform”) hosted from within your school, made available by School Apps Ltd. It applies to information we, or third parties collect about staff, parents, students, and other relevant users at the school. In this document, “we” refers to School Apps Ltd, and “you” refers to you, the user or customer to whom this Policy applies. The use of information processed through this service shall be limited to the purpose of providing the service for which you have engaged School Apps Ltd.

    In order to offer our Services to you, we must collect certain information about your users. Because we respect your privacy, we have documented our policies regarding this information here, and we will not collect or use information about you except in the ways we describe.

     

    1. Your use of the Services

    1.1 Bulk email Provider

    Emails are processed by a trusted third party provider, MailGun LLC. MailGun does not permanently store the content of emails you send with the Platform and does not mine your messages for contextual advertising. Emails are temporarily stored for purely for the purposes of outbound reputation systems, (ensuring they comply with MailGun’s Terms of Service - https://www.mailgun.com/privacy ), re-attempting the delivery of emails that were previously unsuccessfully delivered, and for providing log data. While you should keep in mind that email, by its nature, is not a reliably private means of communication, MailGun supports TLS and SSL which the Platform uses, to limit these risks. A minority of email addresses are stored on a permanent basis where the user has reported emails sent using this service as spam, in order to prevent further emails from being sent to that address. The same applies to emails that have bounced in the past.

    School Apps Ltd has access to delivery logs provided by MailGun to assist in support requests.

     

    1.2 Delivery & Filtering

    MailGun will use commercially reasonable efforts to deliver your email messages, but do not guarantee delivery. Third party filtering services and other policies of recipient email services may prevent successful delivery of your messages. While the MailGun Services will reattempt to deliver email according to their policies. If you use the Service for incoming email, you should note that while the MailGun Service does provide some email filtering services designed to filter spam it does not provide virus scanning and School Apps Ltd recommends that you employ additional security measures to protect against spam, email phishing attempts and email infected with viruses. You acknowledge that the limitations of the filtering service will likely result in the capture of some legitimate email and the failure to capture some unwanted email, including email infected with viruses. You hereby release School Apps Ltd and its employees, agents, affiliates, and third party suppliers from any liability for damages arising from the failure of the MailGun Service’s filtering facilities to filter unwanted email or from the capture of legitimate email, or from a failure of your email to reach its intended recipient. We also recommend that you take measures to protect client devices that may be used to send email via The Platform.

     

    1.3 Message Size Limitations

    An individual email message may not exceed the per-message size limit (including attachments) of 25MB or it may be permanently lost.

     

    1.4 Content Privacy

    You acknowledge and understand that the MailGun Services can include the transmission of unencrypted email in plain text over the public internet. The Platform securely transmits emails to MailGun. You are responsible for encrypting any sensitive data you use in conjunction with the Services. Although MailGun Services include support for TLS, content may be transmitted even if the recipient does not also support TLS, resulting in an unencrypted transmission, and may be intercepted by other users of the public internet, and stored and disclosed by third parties (such as a recipient’s email service provider).

     

    1.5 Routing Data.

    Your email messages and other items sent or received via the mail service will include information that is created by the systems and networks that are used to create and transmit the message including information such as server hostnames, IP addresses, timestamps, mail queue file identifiers, and spam filtering information (“message routing data”). You agree that MailGun may view and use the message routing data for their general business purposes, including maintaining and improving security, improving our services, and developing products. In addition, you agree that MailGun may disclose message routing data to third parties in aggregate statistical form, provided that they do not include any information that could be used to identify you.

     

    2. What information we, or third party providers collect

    MailGun collect two types of information about your users: Personally Identifiable Information and Non-personally Identifiable Information.

    “Personally Identifiable Information” is information that lets us, or MailGun know who your users are, specifically. Information in this category includes email addresses, and email content. Both of which are only temporally stored.

    “Non-personally Identifiable Information” is information that doesn’t let us determine identity. Non-personally Identifiable Information includes information that could personally identify you in its original form, but has been modified to remove or hide (for instance, by aggregation) any Personally Identifiable Information. This collection of information occurs automatically when you use the Services.

     

    3. How MailGun uses your information

    MailGun use the information you collect about your users only to provide these Services to you. As part of that purpose, MailGun may use your Personally Identifiable Information and Non-personally Identifiable Information:

    to provide School Apps Ltd with real-time logs of your use of the Platform;

    to respond to any requests School Apps Ltd may submit for support;

    to carry out other purposes that are disclosed to you and to which you consent; and

    to comply with the law.

     

    4. Third parties

    Except for the limited circumstances described in this Policy, MailGun do not provide your information to third parties. When MailGun need to provide your Personally Identifiable Information to third parties, they will only share it to the extent reasonably necessary. MailGun and School Apps Ltd may also share your Personally Identifiable Information as required or permitted by law and as described below.

    MailGun operate the Service using third parties, including AWS®, SoftLayer® and Rackspace® (the “Hosting Providers”). The Hosting Providers will host these services from its data centres throughout the United States.

    While MailGun provide these third parties with no more information than is necessary to enable these third-parties to provide the services to them, any information that MailGun provide these services independently is subject to their respective privacy policies and practices.

    In certain situations, MailGun may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

    MailGun may be required by law or court order to provide Personally Identifiable Information or Non-personally Identifiable Information to government authorities or private parties. MailGun fully cooperate with law enforcement agencies in identifying those who use the Services for illegal activities, and may report to law enforcement any activities that are believed in good faith to be unlawful. MailGun may need to release the information collected to third parties when they believe it is appropriate to comply with the law, to enforce their legal rights, to protect the rights, safety or property of their business and others, or to assist with industry efforts to control fraud, spam or other undesirable conduct and as needed to support auditing, compliance, and corporate governance functions.

    Additionally, MailGun will provide information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of their business, assets or stock (including in connection with any bankruptcy or similar proceedings).

     

    5. Your choices

    You must note that the users MailGun email on your behalf may opt out from any future communications from you by unsubscribing within The Platform, or by following unsubscribe links in any emails they receive. We will honour their opt-out request immediately. If you would like us to cease all of the described uses of your Personally Identifiable Information, you may configure your own SMPT server from within The Platform and ask us to remove any stored email addresses on MailGun’s suppression lists by emailing gdpr@connectvle.com. We will delete your Personally Identifiable Information from MailGun’s records, and we, nor MailGun will make any further use of it. MailGun may, however, retain copies of your Personally Identifiable Information in backups. Please note that MailGun may be required to retain certain information by law and/or for own legitimate business purposes.

    Upon request, we, and MailGun will provide you with information about whether we hold any of your personal information.  To request this information please contact us at gdpr@connectvle.com and we will process the request on your behalf.

    An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to School Apps Ltd. If requested to remove data we will respond within a reasonable timeframe.

    You may request deletion or request a copy of any or all of your Personally Identifiable Information in our possession by emailing us at gdpr@connectvle.com and we will honour your request within 30 days of passing on the request to MailGun if required. If we, or MailGun must incur expenses to comply with your request, we may charge you a reasonable fee to cover these expenses if permitted by law. If you believe any of the Personally Identifiable Information we have collected from you is inaccurate, you can email gdpr@connectvle.com with a request to update this information. We will honour your requests within reasonable time frame.

     

    6. Web beacons

    Emails sent from The Platform may use web beacons (single, invisible 1x1 pixel images that are downloaded when emails are opened). The web beacon itself does not contain any personal data but allows us to monitor whether emails have been correctly received, opened and clicked on, and to improve the overall email experience MailGun provide. This behaviour can be disabled upon request, although it will restrict our ability to troubleshoot email deliverability issues.

     

    7. Security

    The security of your personal information is important to us. MailGun follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at gdpr@connectvle.com.

    Remember, though, that some parts of the Services are public and that email, by its nature, is not a reliably private means of communication.

     

    8. EU-U.S. Privacy Shield and Swiss Safe Harbor

    MailGun (and its parent company, Rackspace US, Inc.) participates and has certified its compliance with the EU-U.S. Privacy Shield Framework. MailGun is committed to subjecting all personal data received from the European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List https://www.privacyshield.gov/list/.

    MailGun is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. MailGun complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

    With respect to personal data received or transferred pursuant to the Privacy Shield Framework, MailGun is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

    Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

    U.S. - Swiss Safe Harbor Framework

    MailGun complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. MailGun has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view MailGun’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.

     

    9. Modification

    We may need to modify this Policy to address new issues or changes to our policies. We will post changes here, so you should check this page regularly. If we make significant changes to this Policy, we may notify you in other ways (for instance, by email or with a banner on our website) prior to the change becoming effective. Any changes we make will take effect 30 days after the update date noted above. If you object to the changes, email us at gdpr@connectvle.com before the new effective date to delete your information from our records, and we will do so. Your continued use of the Services after the new effective date will constitute your acceptance of the changed Policy.

     

    10. Miscellaneous

    MailGun will retain personal data they process on behalf of our Clients for as long as needed to provide services to our Client. MailGun will retain the personal information as necessary to comply with their legal obligations, resolve disputes, and enforce our agreements.

     

    11. Contact

    If you have questions about this Policy, or if you’re concerned that we are using your information improperly, please contact us by mail:

    School Apps Ltd, Office 1, Arun Business Centre, Littlehampton Marina, Littlehampton, West Sussex, BN17 5DS, United Kingdom

    Or by email:

    gdpr@connectvle.com