Lightspeed Systems’ Commitment to Your Privacy
Lightspeed Systems provides a variety of services (“Services”) to securely manage technology users, internet-enabled devices, and internet access. We understand the importance of privacy to our online visitors, to schools who register for our Services, (“Schools”) and to students and staff (“End User”) whose information we may access on behalf of a School.
- We will always be transparent in the data we collect and how it is used.
- We will practice data minimization and only collect the data that is necessary for the solutions and functions that the school has purchased/contracted.
- We will always treat that data with the utmost security and privacy.
- We will never sell student personal information; we will never share it without the software license holders written authorization, and we will never use it to attempt to sell advertising to students.
Click on the links below to jump to each section:
- Your Data: How We Collect and Use Information
- Cookies & Other Technologies
- Student Safety
- Third Parties: How We May Share Your Data
- Your Rights Regarding Your Data
- California Privacy Rights Under CCPA
- Security: How We Store and Protect Your Information
- Data Retention: How Long We Retain Your Information
- International Data Transfers – Privacy Shield
- European Union and United Kingdom Data Protection
- Legal Basis for Processing Information
- How to Contact Lightspeed Systems
As you are navigating between school and related sites, please be aware that other parties’ privacy policies may come into play. If you are using any of the Services through a customer of Lightspeed Systems this policy does not supersede the terms of any agreements between Lightspeed Systems and any other party, nor does it affect the terms of any agreement between any End User of the Services and their employer, their educational institution, or any third party. Please make sure that you read the terms of any privacy policies that you enter into with parties other than Lightspeed Systems including your employer or educational institution, as those policies may also explain how your personal information is used by those parties. If you are accessing Lightspeed Systems through a third-party, public, or unsecured internet provider, please be advised that any information you disclose or publish during the course of such access may be collected by any such provider and that Lightspeed Systems has no control and makes no representation as to the possible use of this information by any such provider.
2. Your Data: How We Collect and Use Information
We collect the following types of information:
Information about Schools: Schools decide which data is integrated with our Services. When a School administrator registers a School with Lightspeed Systems or corresponds with us online, we ask for certain information including a contact name, school name, school district, school email address and/or account name, phone number, message content, and information relating to the School’s information systems. We may also retain information provided by a School if the School sends us a message, posts content to our website or through our Service, or responds to emails or surveys. Once a School begins using a Service provided by Lightspeed Systems, we will keep records of activities related to the Service. We use this information to operate, maintain, and provide the features and functionality of the Service. Including customer service, support, and billing; to analyze our Service offerings and functionality; to communicate with our Schools and website visitors; to exchange information, and to offer related services such as user group membership and event registration.
Student Data: Lightspeed Systems may have access to personally identifiable information about students (“Student Data”) in the course of providing Service(s) to a School. We recognize Student Data is confidential and do not use such data for any purpose other than to provide the Service(s) on the School’s behalf. Lightspeed Systems receives Student Data only from the School and never interacts with the Student directly. The School confirms that it has obtained appropriate parental consent, as needed before the student is permitted to access the Service(s). Lightspeed Systems has access to Student Data only as requested by the School and only for the purposes of performing Services on the School’s behalf.
We may also generate a login ID for the child that is different than the child’s actual name or under the School’s direction, collect login/authentication data via a student information system identification number or other system designated by Customer.
Parents should consult the school’s acceptable/responsible use, social media, personnel, and instructional policies for more information about the school’s policies and practices for protecting children on the internet. Teachers are reminded to also be aware of their obligations under the ethical standards for educators in their state and to be conscious of their role as a model for students while interacting with students using Services provided by Lightspeed Systems.
See “Student Safety” below for further explanation of our commitment to online student safety.
Non-Personally Identifiable Information: We may collect certain non-personally identifiable information from visitors to our sites and users of our Services, such as the date and time of their visit, the type of browser used (e.g., Chrome, Firefox, Internet Explorer), the type of operating system used (e.g., Windows 7 or Mac OS), the internet service provider from which the visitor receives internet access, and aggregate information regarding what pages users of the site access or visit. We may collect data for Schools to monitor and generate reports of their users’ online search queries, websites visited or blocked from visiting recorded web activity, and device geolocation for purpose of asset recovery. In addition, we may monitor Schools’ onboarding tasks completed, search queries on our sites, number of users’ sessions on our websites, city and state/province where last accessing our Services, responses to our survey questions, and content provided on managed devices via customizable fields.
We may also match non-personally identifiable information from registered members with personally identifiable information (such as the member’s name, title) in our database to track deployment progress, troubleshoot Services issues, analyze usage, and otherwise monitor Services to make improvements.
Employment Applications: In connection with a job application or inquiry, we may collect data about you, including your educational background, résumé or curriculum vitae, and other information, including your ethnicity or criminal background information where required or permitted by law. We may use this information throughout Lightspeed Systems for the purpose of employment consideration. We will keep the information for future consideration unless you direct us not to do so.
3. Cookies & Other Technologies
Clear GIFs, pixel tags, and other technologies: Clear GIFs (also known as web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs, in connection with Services provided by Lightspeed Systems to, among other things, track the activities of visitors, help us manage content, and compile statistics about site usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
We use or may use the data collected through cookies, log files, device identifiers, and clear GIFs to (a) remember information so in subsequent visits a user will not have to re-enter it; (b) provide custom, personalized content, and information; (c) monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Services; (e) diagnose or fix technology problems; and (f) help users efficiently access information after signing in.
Do-Not-Track: Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Data Controller: By providing Lightspeed Systems information via our website, tradeshow, Lightspeed Systems event, Partner event, e-mail, phone, chat or support case, you authorize Lightspeed Systems to serve as the Data Controller.
Data Processor: By licensing to use Lightspeed Systems services, you authorize Lightspeed Systems to serve as the Data Processor for the licensed services.
4. Student Safety
Lightspeed Systems complies with the Children’s Online Privacy Protection Act (COPPA, see www.ftc.gov/privacy/coppafaqs.shtm) and the Student Privacy Pledge (studentprivacypledge.org) to ensure the online safety of children. Student accounts are provided only through a verified educator, school, or educational organization. Educators agree to obtain parental permission before issuing accounts to students. Please read Lightspeed’s COPPA Notice here.
We meet the following guidelines listed below and agree to:
- NOT collect online contact information without the consent of either a parent or a qualified educator or educational institution.
- NOT collect personally identifiable offline contact information.
- NOT distribute to third parties any personally identifiable information without prior parental consent.
- NOT entice by the prospect of a special game, prize, or other activity or to divulge more information than is needed to participate in the activity.
- NOT use or disclose student information for behavioral targeting of advertisements to students.
- NOT build a personal profile of a student other than for supporting authorized educational/school purposes.
5. Third Parties: How We May Share Your Information
Personal information is only shared in a few limited circumstances as described below. Lightspeed Systems will not give, sell, rent, loan, or otherwise disclose to any third parties outside of Lightspeed Systems and its agents, except when we have your permission or as required:
- With those that provide us with technology services (e.g. web hosting and analytics services), but only with entities with comparably strict privacy policies and strictly for the purpose of carrying out their work for us.
Aggregated personal information is used to determine the demographic composition of our user base and to distribute statistics and general marketplace information about Lightspeed Systems. We may disclose aggregated user statistics to describe the Services to prospective partners and other third parties and for other lawful purposes. This aggregated information does not identify specific users.
We do not use personal information for any other commercial purpose.
Further, Lightspeed Systems recognizes its potential liability when onward transferring EU individuals’ data received pursuant to the EU-US Privacy Shield. An individual has the ability, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. Please refer to Annex I of the Privacy Shield for additional information.
In certain areas of the Services, Lightspeed Systems makes announcements, email, chat, polls, forums, discussions, and/or news groups available. Please remember that any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose any of your personal or other information in these or any other publicly available site. And if you see inappropriate content posted by any other user, please report that information to us so we can review the post and respond accordingly.
6. Your Rights Regarding Your Data
For Data, We Collect Via Our Products;
Adult End Users of Services provided by Lightspeed Systems have a right to access their data collected and used by Lightspeed Systems. Schools may access and update account information and modify Services by signing into an administrator account. Adult End Users may access and change their information collected during account creation at any time and as often as necessary by choosing the “edit account information” option or other similar functionality offered in the Services. To access or change your personal information, log into your account through the Services. For data, not available through such an account, please contact us via the contact information below. End Users and visitors may opt out of receiving future promotional electronic mailings from Lightspeed Systems by following the unsubscribe procedures indicated in the mailing. Adult End Users of Services provided by Lightspeed Systems should contact their educational institution or other organization providing the Service about access requests to be forgotten, electronic copies of data, requests for data deletion, and/or data depersonalization.
Student Data: Student End Users of Services provided by Lightspeed Systems and their parents should contact their educational institution or other organization providing the Service about access to the personal information collected by that institution including requests to be forgotten, requests for data, requests for data deletion, and/or data depersonalization.
Deleting or Disabling Cookies: Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. End Users of Services provided by Lightspeed Systems who disable cookies will be able to browse certain areas of our sites, but some features may not function.
Data Portability: License holders of Lightspeed Systems products may request in writing that the data they provided be returned to them in electronic format. Within a reasonable time Lightspeed Systems will return the data provided by the license holder for the products they have licensed.
Individuals who provided information via our websites, Tradeshow, Lightspeed Systems event, Partner event, e-mail or phone call may request in writing that the data they provided be returned to them in electronic format. Within a reasonable time Lightspeed Systems will return the data provided.
For Data, We Collect From Visitors Of Our Websites;
Account Information and Settings: Adult End Users and visitors of the Lightspeed Systems websites have a right to access the data collected and used by Lightspeed Systems To make requests to access or change account information, be forgotten, electronic copies of data, data deletion, and/or data depersonalization, please contact us via the contact information below. End Users and visitors may opt out of receiving future promotional electronic mailings from Lightspeed Systems by following the unsubscribe procedures indicated in the mailing.
Children’s Data: Lightspeed Systems does not knowingly solicit or attempt to collect information from children via its websites. We ask that anyone under the age of 13 not use our websites or submit information to us. Please contact us via the contact information below if you have any questions, concerns, need to access, change, or delete the Personal Information that has been submitted by a child.
Please contact us at the address below if you have any other questions or concerns about the information you receive from us or the information that we collect from you.
7. California Privacy Rights Under CCPA
Subject to certain limitations, the California Consumer Privacy Act (CCPA) provides California consumers the following rights:
- Right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information),
- Right to delete their personal information,
- Right to opt out of any “sales” that may be occurring – we DO NOT sell personal information; hence this option is not available on our site.
- Right to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at email@example.com
8. Security: How We Store and Protect Your Data
Storage: All of your personal information is stored on servers at locations designed specifically to ensure that only authorized individuals have access to the server or its data. Lightspeed Systems maintains strict administrative, technical, and physical procedures to protect information stored on our servers. Access to information is limited through login credentials to those employees who require it to perform their job functions.
Processing: Industry-standard Secure Socket Layer (SSL) encryption technology is used to safeguard the account registration process. Other security safeguards include but are not limited to data encryption, firewalls, two-factor authentication, and physical-access controls.
Practices: We have in place and maintain procedures and practices to ensure data security. These include a Data Governance Team, Security Policy, Privacy Inquiry Policy, Incident Response Plan, Privacy/Security by Design, Vendor Assessments, Security Assessments and regular specific Security Training.
Please be aware, that despite our efforts, no security measures are perfect or impenetrable. We have implemented best practices to protect both your and our data however we do not warrant or guarantee these measures are perfect.
If we learn of a security breach, we will notify you according to our Incident Response Plan or according to Data Processing/Sharing Agreements in place. Depending on where you live, you may have a legal right to receive a notice of a security breach in writing.
9. Data Retention: How Long We Retain Your Data
We retain data for as long as necessary to fulfill the purposes for which it was collected for. Following termination or deactivation of a School account, Lightspeed Systems may retain profile information and content for a commercially reasonable time for backup, archival, or audit purposes, but all Student Data associated with the School will be deleted in accordance with Lightspeed Systems Data Deletion policy, or in accordance with active DPA, DSA or SLA. We may maintain anonymized or aggregated data, including usage data, for analytics purposes.
If you have any questions about data retention or deletion, please contact us via the contact information below.
10. International Data Transfers – Privacy Shield
We are aware of the July 16, 2020 decision from the European Union Court of Justice, which invalidated the EU-U.S. Privacy Shield. Lightspeed Systems will work with its customers and update appropriate contracts to incorporate Standard Contractual Clauses (documents approved by the European Commission for use in cross-border data transfer situations) with Lightspeed Systems. We will abide by our obligations under the Standard Contractual Clauses we have signed with our customers. In some cases, customers also may transfer personal data to Lightspeed Systems from the UK or European Economic Area on the basis of derogations under GDPR Article 49. As legally required, Lightspeed Systems will continue to comply with its obligations with respect to data received under the EU-U.S. Privacy Shield.
Lightspeed Systems Privacy Department
℅ John Genter, DPO
2500 Bee Cave Road, Suite 350
Austin, TX 78746
Lightspeed Systems has committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. BBB has committed to respond to complaints and to provide appropriate recourse at no cost to you. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/bbb-privacy-shield/eu-dispute-resolution for more information and to file a complaint.
Lightspeed Systems is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
11. European Union & United Kingdom Data Protection
Residents in the European Union and the United Kingdom are entitled to certain rights with respect to personal information that we hold about them. Subject to any exemptions provided by the law, their rights are as follows:
- Right of access and portability:The right to obtain access to your personal information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller;
- Right to rectification:The right to obtain rectification of your personal information where that personal information is inaccurate or incomplete;
- Right to erasure:The right to obtain the erasure of your personal information, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed;
- Right to restriction:The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information;
- Right to object:The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing; and
- Right to lodge a complaint with the supervisory data protection authority in your jurisdiction.
12. Legal Basis for Processing Information
We rely on several legal bases to process data:
- Consent to process data in any enquiry you submit to us to supply relevant, requested services to you, as our customer/potential customer. You may withdraw your consent as outlined in the “How To Contact Lightspeed Systems” section at which time we will verify your request.
- Legitimate interest for the proper administration and monitoring of our products and website.
- To fulfill a contract with our customers to provide them with the services they have subscribed to for a specified period of time.
14. How to Contact Lightspeed Systems
If you have any questions about this privacy statement, the information that we collect from you, or the Services, please contact us at firstname.lastname@example.org or write to:
Lightspeed Systems Privacy Department
℅ John Genter, DPO
2500 Bee Cave Road, Suite 350
Austin, TX 78746
In the event that you are concerned about how data you have provided Lightspeed Systems through the Services has been used, please contact us at the address listed above. Lightspeed Systems takes all concerns about privacy and use of data very seriously and shall endeavor to reply to you within two business days to commence its investigation of your concerns.
For more information, see Protecting Privacy, Lightspeed Systems Overview.
We have signed the Student Privacy Pledge!