4MATIV is a strategic partner and service provider to public and private schools with which we contract by providing transportation management solutions to those schools. 4MATIV’s technology and performance management platforms enable multi-modal transportation of students to and from school more efficiently, for less cost, with less hassle. In the process of doing our work, we receive, maintain and protect some Personal Information (defined below) regarding the students we transport and staff at our school and vendor partners. Most of the Personal Information is provided by the schools we serve. Some of that Personal Information is provided by parents, but may also be provided by authorized school staff, subcontracted vendors (including IT partners, etc..), other authorized school vendor-partners, authorized 4mativ staff, etc…
Personally Identifiable Information, also known simply as “Personal Information” or “PII”, includes but is not limited to a student’s name, the name of his or her parent(s), caregiver(s) or other family members, the address(es) of the student or his family, a student’s personal identifier (social security number, student number or other identifying number given or assigned to the student), date or place of birth, a parent’s maiden or former name and other information of any kind that, alone or in combination with other information, identifies that student or allows a reasonable person in the school community, without specific knowledge of the student, to identify the student with a degree of certainty. It may also include information requested of us regarding a student or his or her family that a school we serve or a vendor with which we contract already knows. Other PII may include identifying information (names, phone numbers, job title) of school staff, subcontracted vendor staff, or other school vendor-partners, 4mativ staff, etc…
Customer Data: 4MATIV is committed to the protection of Personal Information. As a provider of student transportation management technologies and management services (“Services”) our customers, which are comprised of schools, school districts, and other education institutions (collectively, “School(s)” or “Customers”), entrust us with their data, which may include personal information of their employees, students, their parents or other caregivers (“Customer Data”). We collect and process Customer Data solely on behalf of our Customers, and in accordance with our agreements with the them. We do not use or disclose Customer Data except as authorized and required by our Customers and as provided for in our agreements with our Customers. Because 4MATIV and its partner vendors do not own or control Customer Data, any request for access, review, correction, or deletion of Customer Data must come directly from our Customers.
- COLLECTION OF PERSONAL INFORMATION
In the course of providing our Services to the school your student attends or in the course of you communicating with 4MATIV at a website, by telephone, email or in any other manner of communication, we may collect or receive Personal Information about you or your student to provide our services and operate our business. The types of Personal Information that we may collect and how we use it are:
- Student, Parent, Vehicle Operator Profile Information: In general, the Personal Information we receive from schools with which we contract, vendors who contract with us to provide transportation and vehicle operators who directly provide transportation, enables us to provide the Services we contract with the School to provide. Certain Personal Information, including you and your student’s full name, email address, phone number, home address, and gender (students and vehicle operators only). The School or you also may provide emergency contact information with respect to your student, including such contact’s full name, phone number, and relationship. Consistent with legal requirements and in order to determine eligibility as vehicle operators, vehicle operators are required to provide government identification documents, including driver’s license numbers and images, birthdate, signature (in some instances) and vehicle and insurance information.
- Demographic Data: We may collect general demographic data about students we transport through surveys. You may provide this information on a voluntary basis. This information is used to improve our services and to provide the data to the School with which we contract to the extent required by our contract with the School.
- Communications: When you communicate with 4MATIV through email, phone, text, chat, or otherwise, or the School with which we contract provides that communication to us, we retain those communications in order to process your inquiries, respond to your requests, and improve our Services. Consistent with legal requirements, we may record calls placed or received and such calls may be recorded and stored by us or a third-party vendor. We use this information to facilitate the Services, investigate complaints and claims, and otherwise provide and improve the Services.
- Transport Information: We collect Personal Information that you provide when you make or accept requests for Rides and otherwise use our Services, such as ride pick-up and drop-off locations, ride times, and ride notes. The information collected is necessary to provide the Services.
- Location-Based Information: We automatically collect location-based information through our software, including, but not limited to geographic areas and other traffic and transportation-related data. For Vendors and Vehicle Operators only, we may collect this data when they are operating in connection with our Services. For all other Users, location information is only collected on an as-needed basis. Your location information is necessary for the provision of Services. For example, it is used to route service providers. Additionally, Vehicle Operators’ location information and distance travelled is necessary to manage the efficient and cost-effective implementation of student transportation.
- Anonymous Information Provided by Third Parties. Like all developers, we use data collection systems such as Apple Analytics and Google Analytics services to monitor app usage i.e. number of installations, types of devices, geographies, number of crashes etc. All these data are anonymous and help us build better apps.
How is Personal Information protected? Any data provided to us by a School, including PII, for processing in our software systems is protected. 4MATIV employs a variety of physical, administrative, and technological safeguards that are designed to protect data it receives and uses against loss, misuse, and unauthorized access or disclosure. While no technology can guarantee 100% protection against security breaches, we strive to continuously maintain reasonable physical, administrative, and technical security measures and to align our privacy and security operations to best practices and relevant national and international regulations.
- USE OF PERSONAL INFORMATION.
The Personal Information or PII we collect is used by us to provide the Services and for no other reason. The Personal Information is shared with third parties (for example, authorized technology or development subcontractors) ONLY for the purpose of delivering those Services. Why would PII need to be shared with any third parties? 4MATIV works with student transportation vendors and their Vehicle Operators who are engaged directly by us to provide student transportation to and from the School. We also work closely with the staffs of the Schools to both meet our contractual commitments and effectively coordinate the Services with the Schools, and authorized subcontractors to develop our products and ensure safety and security of our systems. Some disclosures may also be required by law.
- Student Transportation Vendors and Vehicle Operators. As part of our Services, we engage directly with certain third-party companies on behalf of the Schools to provide student transportation to and from the Schools (“Vendors”). Our Vendors and their Vehicle Operators are required to abide by our privacy and security instructions and are contractually restricted from using any Personal Information accessed or received through us for any purposes other than as needed to perform such services. We DO NOT use any Personal Information to advertise, conduct marketing campaigns or events or disclose Customer contact information related to those activities.
- Schools. Because our Services require us to work closely with Schools and their staffs, Personal Information we may receive from a parent or Vendor or Vehicle Operator directly may be shared with the School. A School may also work with third-party companies to provide additional content and functionality which requires access to 4MATIV technologies and data. Only with your School’s permission, 4MATIV will share information about you (such as your name, email, or student ID), that is required to provide you with limited access to information, including PII, that has been requested by your School. In these cases, these third-parties will enter into an agreement directly with your student’s School regarding the processing of any provided data.
- Other Types of Disclosures. We may also need to share certain PII under certain circumstances. We may need to disclose PII to comply with legal or regulatory requirements and to respond to lawful requests, such as court orders and subpoenas within a legal proceeding. Where such disclosures relate to Personal Information we hold as a data processor on behalf of our customers, we will refer such requests to our customers where permissible. We may need to disclose PII to protect and defend the rights, property, or safety of our customers, including enforcing contracts or policies, or in connection with investigating and preventing fraud or other misuse of our systems. Where permitted by applicable law, we may utilize aggregated or de-identified (anonymized) information that is no longer associated with a person for internal purposes, such as to enhance and promote the 4MATIV’s technologies and services. Again, 4MATIV DOES NOT rent, sell, or otherwise provide access to Personal Information to third parties for marketing or advertising purposes.
- OTHER USES OF COLLECTED INFORMATION
In addition to the foregoing, we may use Personal Information to:
- Investigate violations by Vendors or Vehicle Operators;
- Prevent potentially prohibited or illegal activities;
- Respond to Legal and Regulatory Compliance. 4MATIV is required to share Personal Information to the extent required by law or regulation. This includes the following:
- Sharing Operator information as required by local regulatory agencies;
- Comply with data reporting requirements and other official inquiries; and
- Investigating or addressing claims or disputes relating to the use of the Services.
- Improve our technologies and services. We are always looking for ways to improve the 4MATIV technologies. Your data may be used to:
- Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems;
- Conduct data analysis, testing, and research; and
- Monitor and analyze usage and activity trends.
We may also use Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you or your student. If information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any legitimate business purpose.
- STUDENT PRIVACY PLEDGE
It is important to emphasize that, consistent with the Student Privacy Pledge, we do not collect, maintain, use or share student Personal Information beyond that needed for authorized educational/school purposes, or as authorized by the parent/student. We do not sell student personal information. We do not use or disclose student information collected through an educational/school service (whether personal information or otherwise) for behavioral targeting of advertisements to students. We do not build a personal profile of a student other than for supporting authorized educational/school purposes or as authorized by the parent/student. We do not make material changes to school service provider consumer privacy policies without first providing prominent notice to the account holder(s) (i.e., the educational institution/agency, or the parent/student when the information is collected directly from the student with student/parent consent) and allowing them choices before data is used in any manner inconsistent with terms they were initially provided; and we do not make material changes to other policies or practices governing the use of student personal information that are inconsistent with our contractual requirements. We do not knowingly retain student personal information beyond the time period required to support the authorized educational/school purposes, or as authorized by the parent/student.
We do support access to and correction of student PII by their authorized parent, either by assisting the educational institution in meeting its requirements or directly when the information is collected directly from the student with student/parent consent. Maintain a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of student personal information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. We require that our Vendors with whom student personal information is shared in order to deliver the transportation services implement these same commitments for the given student personal information.
Some school service providers may be subject to additional legal obligations, contractual commitments, or requests from educational institutions or parents/students that direct or otherwise authorize additional uses of student data, other than those specified above. Nothing in this pledge is intended to prohibit the use of student personal information for authorized purposes of adaptive learning or customized education. For more information, visit http://studentprivacypledge.org.
- DATA RETENTION AND STORAGE
- Retention. We retain Personal Information for as long as a student attends a School and is transported as part of our Services and, thereafter, as long as our contract with the School requires that we retain it. We retain transaction information for at least three years to ensure we can perform legitimate business functions and to comply with our contractual requirements. For Vendors and Vehicle Operators, 4MATIV may retain certain information to the extent required by law or regulation.
- Changing Personal Information. You may review, update, or correct the Personal Information in our possession to the extent the School’s privacy policies and our contract with the School permits. 4MATIV will be fully cooperative with the efforts made to update or correct PII.
- YOUR RIGHTS REGARDING YOUR DATA
You have the right to know what information we have collected about you in the last 12 months, including: the categories of Personal Information we have collected about you; the categories of sources from which the Personal Information is collected; the business or commercial purpose for collecting your Personal Information; the categories of third parties with whom we have shared your personal information; and the specific pieces of Personal Information we have collected about you. For more information about the Personal Information we have collected over the last 12 months, including the categories of sources and the business purposes for collecting your Personal Information, please see the Collection and Use of Personal Information and Other Uses of Personal Information sections above. We share this information with the categories of third parties described in the How We Share Information section above.
- NOTIFICATION OF CHANGES
- ADDITIONAL INFORMATION