Effective date: December 3, 2019
Last update: December 3, 2019
Via Mobility LLC (“Via” or “we”), has licensed its software to the Washington Unified School District (“WUSD” or the “LEA,” as defined below) so that WUSD could provide parents and guardians with additional information regarding the WUSD bus transportation services that your child uses. Via’s services (“Services,” defined below) are limited exclusively to the provision of these software and tools.
All of Via’s systems, procedures, use of data, and Services are in accordance with the Family Education Rights and Privacy Act of 1974 (“FERPA”) governing the use of student data.
Capitalized terms not defined in this Definitions section below shall have the meaning set forth by applicable law when a citation is present.
“Agreement” means the underlying Service Agreement and related agreements between Via and the LEA.
“App” means the “WUSD Bus App,” which is provided by the LEA to the Users.
“LEA” means the local education institution, school, or school district that has purchased and is using Services pursuant to an Agreement with Via.
“Services” means Via’s cloud-based software tools, as provided to LEAs, which include the software that enables WUSD to provide real-time school bus tracking and student boarding information, a real-time notification system, and an automated and dynamic vehicle routing system.
“Student Data” means the personally identifiable information Via receives regarding a student of an LEA.
“User” means an authenticated user of the App. Users are parents, guardians, or caretakers who are verified by the LEA. The LEA is in full control over the authorization and verification process.
WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?
Personal Information. Personal Information means information that alone or when in combination with other information may be used to readily identify, contact, or locate you or members of your household, including but not limited to names, addresses, email addresses, or phone numbers. We collect Personal Information when you use the App or when you communicate with WUSD through the App, including to amend or supplement the information that is already available in WUSD’s records. You may receive email, text messages, or phone calls to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.
Aggregated and De-Identified Information. We receive certain types of Aggregated Information about general rider activity. We do not consider information that has been anonymized so that it does not allow a third party to easily identify a specific individual to be “personal information.” Aggregated and De-Identified Information is gathered and compiled into an aggregate form for statistical analysis and reporting, including to third parties.
Location Information from Your Mobile Device. We collect and store your location information if you enable your mobile device to send it to us. We may also collect information that identifies the mobile device you are using. Collection of this information improves the provision of the Services. You may opt-out of location-based services at any time by editing the setting at the device level, but this may impact the quality or functionality of the Application.
COLLECTION & USE OF STUDENT DATA:
Via receives Student Data from LEAs in order to provide Services under its Agreement with the LEA. In addition, Via receives information provided by Users as they use the Services. By using the Services, you are authorizing us to gather, parse, and retain data related to the provision of the Services.
User Support. We may collect Student Data and personally identifiable information when Users communicate with User support services, whether provided by the LEA or Via.
Internal and Service-Related Usage. We use information, including Student Data, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Services. We may use and retain data we collect to provide and improve the Services.
Aggregate Data. We may anonymize and aggregate data collected pursuant to the Agreement and use it for the purposes of providing Services under the Agreement and to improve our Services.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Services. We may share information, including Student Data, with third-party transportation providers as necessary to provide the Services. If we transfer personal information to a third party, we will take reasonable and appropriate steps to ensure that the third party collects, processes and discloses personal information only for limited and specified purposes in order to provide Services under the Agreement.
Cookies and Internet Tags. We may collect and process information, such as anonymous usage statistics, by using “cookies,” server logs, and other similar technology as you use the Services in order to help us improve the Services and to compile aggregate statistics about the use of Services for internal purposes. Cookies enable you to sign in to use the Services and access your stored preferences and settings. If you choose to block this function, it may impair required functionality and therefore your use of the Services.
Do Not Track Disclosure. Currently, various browsers offer a Do Not Track option that send a signal to websites visited by the browser about the user’s Do Not Track preference. You can usually access your browser’s Do Not Track options in the browser’s preferences. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time as there is not yet a common accepted standard for how to interpret and respond to Do Not Track signals.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred as part of such a transaction as permitted by law and/or contract.
“As Required by Law” and Similar Disclosures. We may access, preserve, and disclose Student Data if we believe doing so is required or permitted by law or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena or to meet national security requirements; respond to your requests; or protect your, our or others’ rights, property, or safety.
No Marketing and No Ownership. We do not: (1) rent or sell Student Data to third parties; (2) share Student Data with third parties for the purpose of targeted advertising; (3) use Student Data for marketing purposes; (4) claim ownership of Student Data.
SECURITY OF STUDENT DATA:
Via stores and processes Student Data in accordance with industry standards and applicable law. In this regard, Via protects Student Data from unauthorized access, use, and disclosure. In the event that Via learns that the security of Student Data has been compromised, Via will notify you pursuant to the terms of the Agreement and as required by applicable law. Via will attempt to notify you as promptly as possible under the circumstances of any security breach affecting Student Data that Via believes may pose a material risk of harm.
If Via receives notice from an LEA or a parent to delete or destroy Student Data, we will take steps to make sure that the deletion of Student Data complies with FERPA standards.
To protect Student Data, Via maintains a comprehensive information security program that implements appropriate physical, administrative, and technical safeguards. Via conducts risk assessments of its information security program and remediates potential security vulnerabilities if identified.
Our Services comply with all applicable provisions of the Children’s Online Privacy Protection Act (COPPA) (15 U.S.C. 6501 et seq.). To the extent COPPA applies to the information we collect, we process such information for educational purposes only, at the direction of the partnering LEA, and on the basis of educational institution consent.
CHANGES TO THE POLICY:
Via Transportation, Inc.
160 Varick Street, 4th Floor
New York, New York 10013