Privacy Policy for Shule Plus

Last Updated: July 17, 2025

1. Our Role and the Scope of This Policy

Welcome to Shule Plus. This Privacy Policy explains how Shule Plus ("we," "us," or "our") handles information in connection with our school transportation tracking and digital learning platform (the "Service").

It is important to understand that our mobile application (the "App") is a tool for you to access the Service. The App itself does not collect personal information from your device. Instead, it securely downloads and displays information that has been provided to our Service by your child's school via a separate administrative web portal.

In this relationship, the School is the Data Controller that decides what information to collect. Shule Plus is the Data Processor that processes this information on the school's behalf. This policy outlines our commitments as a Data Processor.

2. Information We Process on Behalf of Schools

We do not collect personal data directly from app users, except for what is necessary for login. All other student and parent information is provided to us by the school administration, which is responsible for obtaining the necessary parental consent.

A. Information Provided by Your School

To enable our services, your school's administrators upload the following information to our secure server:

• Student Information: Full name, school name, and grade/class.
• Parent/Guardian Information: Full name and association with the student.
• Transportation Data: Designated pickup and drop-off locations for students.
• Educational Content: The digital curriculum and learning materials relevant to the student's class.

B. Information You Provide Directly to Us

• Phone Number for Login: To use the App, you must register with your phone number. We use this number solely to verify your identity and secure your account via a One-Time Password (OTP) sent via SMS.

C. Information Processed Automatically for Service Operation

To ensure the App functions correctly and securely, our servers automatically log certain information:

• Bus Location Data: The real-time GPS location of the school bus (not your personal device) is sent to our server to enable the tracking feature.
• Service Usage Data: We record events like student check-in/out on the bus (as recorded by the driver or attendant), login timestamps, and which features are used. This is for operational and security purposes.
• Device and Technical Information: We may log the device type, operating system, and IP address when the App connects to our servers. This is used strictly for technical support, troubleshooting, and maintaining the security of our Service.

3. How We Use the Information

We use the information exclusively to provide the services requested by your school:

• To Deliver Core Functionality: To display real-time bus locations, show digital curriculum, and send notifications to parents about their child's transportation status (e.g., "boarded" or "alighted").
• To Authenticate Users: To securely log you into the App using your phone number and an OTP.
• To Ensure Student Safety: To provide a transparent and accountable record of student transportation for parents and school administrators.
• To Maintain and Improve the Service: To monitor system performance, diagnose technical issues, and ensure our infrastructure is secure and reliable.

4. Data Sharing and Disclosure

Information is shared only when necessary to operate the Service:

• With Your School: Your school's authorized administrators have access to all data related to their students.
• With Other Authorized Users: A bus driver, for example, will see the names of students on their assigned route in their version of the App to manage check-ins and check-outs.
• With Our Service Providers: We use third-party vendors for essential services like cloud hosting. These vendors are bound by strict confidentiality agreements and are only permitted to use the data to provide services to us.
• For Legal Reasons: We may disclose information if required by law or in the good-faith belief that such action is necessary to comply with a legal obligation or to protect the safety of our users.

5. International Data Transfer and Storage

All data processed by the Shule Plus service is securely stored on servers located in Belgium (europe-west1). By using our Service, you consent to your information being transferred to and processed within the European Union. Data stored in the EU benefits from the high standards of data protection afforded by the General Data Protection Regulation (GDPR).

6. Data Security

We are deeply committed to protecting the data entrusted to us. We implement robust technical and organizational measures, including:

• Encryption: Data is encrypted both in transit (using TLS/SSL) and at rest.
• Access Controls: Strict, role-based access ensures that users can only view information relevant to their role.
• Secure Authentication: Account access is protected by OTP verification.

7. Your Data Protection Rights and How to Exercise Them

Because your school is the Data Controller, they are the primary point of contact for managing your data.

• Access, Correction, and Deletion: To review, correct, or request the deletion of your or your child's information, please contact your school's administration directly. They have the tools within our system to manage this data. We will assist your school in fulfilling these requests.
• Data Portability: You can request your data from your school.

8. Data Retention

We retain personal information for as long as your school maintains its service contract with us and as long as the student is enrolled. When a school terminates its service, we will work with them to securely delete or return their data in accordance with our agreement and applicable laws.

9. Children's Privacy

We process information about children under the age of 13 only at the direction of and on behalf of our school clients. Schools are responsible for obtaining parental consent as required by laws like the Children's Online Privacy Protection Act (COPPA).

10. Changes to This Privacy Policy

We may update this policy to reflect changes in our practices or for legal reasons. We will notify you of any material changes through an in-app notification or by informing your school administration.

11. Contact Us

If you have questions about this Privacy Policy or our role as a Data Processor, please contact us. For questions about your specific data, please contact your school.