1. What information do we collect, and how is it used and shared?
We explain here what categories of personal information we collect, the purpose of collection, and how we share it:
|Category of Personal Information Collected||Source||Purpose for Collection||Categories of Recipients|
|Contact and profile information: such as name, phone number, email address and, as applicable, family member and teacher names||From you (or on your behalf, such as via a school, parent/guardian, or intermediary platform) when you register for, receive access to, or use the Services||To provide, manage, support, improve, and personalize the Services (and, as applicable, any related transactions), and to communicate with and respond to you about the Services, including to validate your identity or to meet legal obligations||Our agents and successors; to the extent relevant, select service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, a school through which you are registered or otherwise participating|
|Credential information (as applicable): such as photo, identification number, driver’s license (or other identification card), and background check inputs and results||From you (or on your behalf, such as via a school, parent/guardian, or intermediary platform) when you register for, receive access to, or use the Services||To provide, manage, support, improve, and personalize the Services (and, as applicable, any related transactions), and to communicate with and respond to you about the Services, including to validate your identity or to meet legal obligations||School administrators (or other authorized school personnel, including the school’s relevant background check or similar service providers) to whom such information is communicated or designated; our agents and successors; to the extent relevant, select service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, your parent/guardian or other designated recipient|
|Screening information (as applicable): such as symptom information (e.g., fever), vaccination information, and recent travel and exposure information||From you (or on your behalf, such as via a school, parent/guardian, or intermediary platform) when you register for, receive access to, or use the Services||To provide, manage, support, improve, and personalize the Services (and, as applicable, any related transactions), and to communicate with and respond to you about the Services, including to facilitate the administration of screening procedures or to meet legal obligations||Our agents and successors; to the extent relevant, select service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, a school through which you are registered or otherwise participating|
|Communication and submission information (as applicable): such as information you enter into any communication environment or tool available on or through the Services||From you, as applicable, when you input information into any such environment or tool||To submit information, questions, or requests (or to otherwise communicate), as contemplated by such environment or tool||School administrators (or other authorized school personnel) to whom such information is communicated or designated; our agents and successors; and, to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations)|
|Payment verification (as applicable): such as name, payment amount, payment method, payment date, and billing address||From you or your payment card issuer or payment processor, as applicable||To verify the payment of amounts owed, as applicable||Our agents and successors; to the extent relevant, select service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable and relevant, a school through which you are registered or otherwise participating|
|GPS information (as applicable): such as real-time Global Positioning System (“GPS”) latitude/longitude coordinates||From, but remaining on, your device when you have chosen to activate GPS-based Services on your device, where processing of such GPS information occurs directly on your device and is not stored on our servers||To implement the functionality of the applicable location-based Services you are using in order to determine attendance, among other purposes directed by our customers||School administrators (or other authorized school personnel) to whom the results of such Services are communicated or designated; and, to the extent relevant for processing, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations)|
|Emergency-related information: such as details of your identity, appearance, or location||From you or, as applicable, school or emergency personnel (or other authorized users) or your parent/relative||To provide, manage, support, and improve relevant emergency-related Services, including to facilitate the monitoring and coordination of the safety of you or others, and to communicate with and respond to you about such Services||School or emergency personnel who reasonably need to know such information in connection with relevant emergency-related Services; to the extent relevant, select service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, your parent/guardian or other designated recipient|
|Legal process-related information: such as details of your identity, or suspected or alleged criminal, dangerous, impermissible, unlawful, or other relevant behavior or records||From crime and fraud prevention agencies, you, witnesses, or law enforcement agencies||To protect users, the public, and our business against risks and crime; or to comply with legal requirements||Law enforcement and other governmental authorities in accordance with applicable law; our technical and other service providers; and our professional advisors|
We will only use personal information to the extent it is reasonably necessary to deliver, manage, support, improve, or personalize the Services. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights, some of which are detailed in the “Access, objection, deletion, and correction” and “Your California and Other State Privacy Rights” sections below. In all cases, our service providers will be contractually limited in the way they may use personal information maintained by us, including requirements that such information be maintained in a confidential and secure manner.
Student Data: Personal information related to students that is provided to us by a school or collected by us during the provision of Services to a school (collectively, “Student Data”) is subject to our written agreement(s) with the school (each, a “School Agreement”). In this manner, we operate under the “school official” exception for FERPA. We do not (a) use or disclose Student Data for targeted advertising purposes, or (b) sell Student Data (other than in connection with the transfer of our business, as discussed below).
Location Data: As noted in the summary above, certain location-based Services may utilize GPS information when you have chosen to activate those Services on your device. But we will not transfer that GPS information to our servers; instead, we will process that information on your device as reasonably necessary to provide information to our customers, such as attendance verification. If you want to limit the collection or use of GPS information, you can (a) adjust your device settings, (b) close the Services when not in use, or (c) avoid using GPS-based Services. If you change the settings on your device to block the use of GPS information, please note that GPS-based Services may not be available or function properly.
To Comply with Laws: We may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry, or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers, and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our users or others, in accordance with or as authorized by law.
2. What are cookies and how do we use them and other technologies?
A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer’s hard drive for use in subsequent visits to the website or online application. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. We do not control, or guarantee the effectiveness of, browser-based tools for managing cookies.
We do not currently participate in interest-based or behavioral online advertising, and information automatically collected from the Services (other than our public website) is not used by us for that purpose.
We may use Google Analytics to evaluate use of our public website (www.ruvna.com) for our internal purposes such as evaluating usages of our site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.
Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognizable DNT signals, and therefore we and the Services do not recognize DNT.
3. How do we protect personal information?
Where applicable, we use industry-standard technology in connection with the Services to help protect personal information within our control from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please note that school and emergency personnel are responsible for their own secure storage and use of any personal information they collect or receive.
4. How long do we retain personal information?
Personal information that we collect, access, or process will be retained only as long as reasonably necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided for under services contracts with clients or as required or authorized by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased, or de-identified.
5. What are your choices concerning your personal information?
Our clients (e.g., schools) are responsible for notification of purpose and for obtaining appropriate consent, to the extent required by law, when they collect personal information that is transferred to us.
If we are instructed by our clients to transmit communications on their behalf, clients remain responsible for ensuring that recipients have consented to receiving such communications and that the information contained in the communications are accurate and complete.
We do not sell, rent, or share the personal information of our users with third parties for such third parties’ own marketing purposes.
We may, subject to applicable laws, use personal information from our users to contact them about the Services, including to provide them with information on additional products from us that may be of interest to them. Our users may exercise choices regarding these communications as follows:
- Mail marketing, Telephone marketing, Surveys, and Quality control communications (as applicable). You may decide that you prefer that we not use your personal information to promote new or additional products or services that may be of interest to you, and you may refuse that we contact you by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us as described in the “Contact us” section below or by following any opt out (e.g., “STOP”) instructions you receive in connection with the Services.
- Emails/Commercial Electronic Communications. You can always limit the communications that we send to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. For clarity, students and parents/guardians are automatically opted out of commercial electronic communications that do not specifically relate to the provision or support of the Services. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account.
7. What is our policy on kids’ privacy?
The privacy of children is important to Ruvna. We do not knowingly intend to collect personal information from children under 13 years of age. If we learn that a child under the age of 13 has submitted personal information through the Services, we will take all reasonable measures to delete that information from our databases and to not use that information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information that we have collected from children under age 13, please contact us as described in the “Contact us” section below. See also above regarding how we protect Student Data.
8. Access, objection, deletion, and correction
We support, and we will reasonably cooperate with users (and, as applicable, their parents/guardians or schools) regarding, users’ access to and correction of their personal information. Registered users can review and modify their registration information at any time through their account. You can also request that we remove or correct your personal information. To make such a request, or if you have questions about your rights, please feel free to contact us as described in the “Contact us” section below.
In certain jurisdictions, you may have the right to obtain confirmation as to whether your personal information is being processed, information about the purposes of that processing, and information about the recipients to whom your personal information has been or will be disclosed. If you have any questions about reviewing, modifying, or deleting Student Data, please contact the applicable school directly.
9. Your California and Other State Privacy Rights
Important: As described above, we often collect personal information primarily as a service provider acting pursuant to School Agreements. You should contact the particular school (or other client) that provides such personal information to us if you have any questions about your rights under California or other state law described below.
If you are a California resident, a Virginia resident (starting January 1, 2023), or Colorado Resident (starting July 1, 2023), the law in those jurisdictions provides you with the following rights with respect to your personal information:
- The right to know what personal information we have collected, used, and disclosed about you. To submit a request to know, you may contact us as described in the “Contact us” section below (with “REQUEST FOR INFORMATION” in the subject line). You may designate an authorized agent to make a request for information on your behalf.
- The right to ask that we correct information that we have collected, used, and disclosed about you. To submit a request to correct, you may contact us as described in the “Contact us” section below (with “REQUEST FOR CORRECTION” in the subject line). You may designate an authorized agent to make a request for correction on your behalf.
- The right to request that we delete any personal information we have collected about you. To submit a request to delete, you may contact us as described in the “Contact us” section below (with “REQUEST FOR DELETION” in the subject line). You may designate an authorized agent to make a request for deletion on your behalf.
When you exercise these rights and submit a request to us, we may verify your identity. We may use a third party verification provider to verify your identity. Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.
10. Transfer or process of personal information outside of your country of residence
In some cases, personal information that we process may be processed or stored in, or transferred to, countries that may not have data privacy laws that provide the same protection as the country where you reside. You understand that your personal information may therefore be transferred, processed, and stored, as applicable, outside of your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable in such jurisdictions.
11. Right to lodge complaints
We are transparent about the ways in which we collect and use personal information, and we welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described in the “Contact us” section below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or in the United States. For information on how you can file a privacy complaint with the Federal Trade Commission, please visit: https://www.ftccomplaintassistant.gov/
12. Contact us