Notice: Collection, Use, and Disclosure of Student Personal Information
Lightspeed Systems complies with the Children’s Online Privacy Protection Act, otherwise known as “COPPA.”
This notice describes our practices concerning the collection, use, and disclosure of personal information from children under the age of 13. Our limited use of this information is described here and in detail in the Lightspeed Systems Privacy Policy and Terms of Use that describes our commitment to each school and school district (“School”) with which we partner. We are providing this notice to you as an official authorized to act on behalf of your School.
By registering for an account, agreeing to the Terms of Use and other binding agreements, or submitting payment to Lightspeed Systems, your School consents to our collection of this information so that we can deliver the Lightspeed Systems service. COPPA allows for educational institutions to act as a parent’s agent in certain educational contexts. This is outlined in the Federal Trade Commission’s document titled “Complying with COPPA: Frequently Asked Questions” (covered in Section N on “COPPA and Schools”).
1. Student Personal Information We Collect
Lightspeed Systems may collect student personal information provided by Schools and parents/guardians, including:
- Information that identifies the student’s account and contact information, like a Unique SIS User ID, username, first and last name, or email address; and
- Information that identifies the student’s school and district, grade level, classroom, group, and parents/guardians.
Lightspeed Systems may also collect student personal information when a student utilizes school-managed accounts and devices provided by the School, including:
- Information that relates to the student’s school-managed account, which may include (depending on a School’s currently selected Lightspeed System services) identifiers and other information necessary to associate a student with a certain device, account, settings, classroom, group, and/or parents/guardians;
- Information that relates to the student’s activity, which may include (depending on a School’s currently selected Lightspeed System services) chats, video conferencing recordings (including videos of participating students and chats included in a video conference), IP address, browsing history, search history, application usage, and online content;
- Information that identifies the geographic location of devices if enabled by the School; and
- Information that facilitates the integration of the Lightspeed System services with other School software (if the School offers such integrations), such as unique identifiers (e.g., Google classroom identifier to connect a student to his/her classroom) and other integration information.
Please note that the information collected may change if your School starts utilizing new features and Lightspeed Systems services.
2. Use of Student Information We Collect
We may use a student’s personal information to:
- Provide, analyze, and improve the services and for legitimate educational purposes requested by the School as per the contractual agreement in place and as stated in our Privacy Policy, which may include restricting access to certain websites and alerting schools to online content viewed by students;
- Operate, maintain, and provide the features and functionality of the Lightspeed System services, including customer service, support, and billing;
- Communicate with Schools and parents/guardians, send notifications, and respond to inquiries; and
- Exchange information and to offer related services such as user group membership and event registration.
We may use, transfer, and disclose non-personal information (information that does not, on its own, permit direct association with students’ identities) for any lawful purpose. For example, we may aggregate and use information regarding usage of the Lightspeed Systems services to help us understand which parts of our services that are of most interest to an School. Aggregated data is considered non-personal information.
Lightspeed Systems will not sell student personal information or seek to profit directly from such information. We will not use personally identifiable student information to target advertisements or market to students or anyone else, to amass a profile about a student for a non-educational purpose, or for any purposes prohibited by the Family Educational and Privacy Rights Act (“FERPA”) or applicable state law.
3. Who We Disclose Student Information to
Lightspeed Systems may share student personal information with:
- Businesses or third parties Lightspeed Systems is affiliated with in order to facilitate a transaction or service that the School has initiated or requested;
- Agents and service providers that act on our behalf to support our services, such as technology services (e.g. web hosting and analytics services). We contractually prohibit our service providers from retaining, using, or disclosing Student information for any purpose other than performing the services for us. Please note strict access controls are in place and these providers have no access to sensitive student data;
- Others, such as parents, teachers, administrators, or other School personnel at the direction of the School or in order to facilitate the service that the School has initiated or requested (depending on a School’s currently selected Lightspeed System services);
- Consent of (or at the direction of) a parent, guardian, or eligible student provided through the School;
- A third party entity in connection with or during negotiations of a business transfer, in which case the recipient will be subject to the same commitments; and
- Third parties, such as law enforcement, first responders, state or federal reporting agencies, such as the National Center for Missing and Exploited Children, or other officials (“Government Officials”) when required by law or when doing so is mandated by our internal escalation policy, which is subject to change in our sole discretion, or when we believe in good faith that it is necessary to comply with any legal, law enforcement, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations; take action in connection with a health or safety emergency; enforce or apply our agreements, including our Terms of Use; or protect Lightspeed Systems, our users, customers, or others.
4. Consent
As stated in Lightspeed Systems’ Terms of Use, Lightspeed relies on consent obtained from the School, acting as an agent of the parent or legal guardian of the School’s students, as permitted by COPPA, for using the Lightspeed Systems services in connection with students under 13 years of age. By registering for an account, agreeing to the Terms of Use and other binding agreements, or submitting payment to Lightspeed Systems, the School represented and warranted that it has obtained all consents required under applicable law. The School must keep all consents on file and provide them to us if we request them.
5. Data Security
Lightspeed Systems has implemented a formal written information security program designed to protect the confidentiality, security, and integrity of children’s personal information. This program includes:
- Annual risk assessments and risk management procedures.
- Regular testing and monitoring of security measures.
- Vendor due diligence procedures to ensure third-party compliance.
- Annual evaluations and modifications to address new or efficient technical or operational risks.
- Annual 3rd party SOC 2 Type 2 audits
We have designated our Chief Information Security Officer (CISO) to coordinate this security program and oversee its implementation.
For more detailed information on our data security practices: please review our Trust Page.
6. Data Storage
Data is stored in secure Amazon Web Services (AWS) data centers located in the United States, which hold SOC 2 and ISO 27001/27017/27018 certifications.
7. Data Retention Policy
Lightspeed Systems retains data for as long as necessary to achieve the purposes for which it was collected and to meet our contractual obligations with the School. If a School terminates its Lightspeed Systems license, data is deleted within 90 days in accordance with our Product Data Deletion Policy. However, upon receipt of a verified data deletion request from the School, data will be deleted within the timeframe specified in the executed Contract with the School, typically ranging from 30 to 90 days.
8. Access, Correction, and Deletion of Student Information, and How to Contact Us
Lightspeed Systems supports Schools’ ability to access, correct, and delete personally identifiable information of students. In many cases, the School can fulfil the request itself using the services. Alternatively, if you have any questions or concerns regarding this Notice, or if the School would like to access, correct, or delete student information on behalf of the School or pursuant to parent/guardian requests in accordance with COPPA (or in accordance with FERPA, or other applicable laws), please contact us at [email protected]. You can also contact us by mail or phone.
Lightspeed Systems
Attention: Privacy Department
12013 Fitzhugh Rd.
Austin, TX 78736, USA
Phone: 1-737-205-2500
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