BanqO! - A platform to help you create, manage and review Individualized Education Programs (IEP) or Transition Programs

Introduction

Banqo! takes the privacy of its users seriously, including children, young people, students, adults, education and health professionals, social services, and parents or guardians of children. eduplan solutions is committed to protecting the privacy of its users in the context of offering personalized and enriching experiences through its clinical or educational technological products (the "Product").

As the Products or Services are designed to be used in educational, clinical, and pedagogical environments, and these Products or Services are intended to be used by adults, young adults, teenagers, and children, eduplan solutions has committed to the 2020 version of the Student Privacy Pledge for all of its Products or Services, to respect the privacy of students. The Student Privacy Pledge is a public commitment to the responsible collection and use of student data by organizations or companies that provide services to students.

The 2020 Student Privacy Pledge is the result of a collaborative public effort to update the Pledge. Since the creation of the Legacy Pledge in 2014, considering the use of student data, technology, and US laws. Finally, edtech companies, civil society groups, student privacy experts, and the general public were asked to comment on how the commitment could be improved to effectively protect student information in 2020 and beyond.

In essence, the entities involved are responsible for both supporting the effective use of student information and protecting the privacy and security of student information.

We are committed to responsible management and appropriate use of confidential data in accordance with the commitments outlined in the Student Privacy Pledge and in compliance with all applicable laws as service providers in the education sector.

This commitment includes, among others:

• We only collect, store, process, and share student-related information that is necessary for educational or school purposes and authorized by the parent or student.
• We do not sell personal information about students.
• We do not use or disclose student information for targeted behavioral advertising.
• We do not retain personal information about students beyond the period required for the educational or school purposes in question.

You can read the full 2020 version of the Student Privacy Pledge here.

Users with questions about this privacy policy (the "Policy") can contact eduplan solutions by writing to info@Banqo.net.

Educational, Clinical, or Pedagogical Environment

The term "Educational Environment" refers, in this Policy, to the classroom, rooms that offer specialized, individualized, or subgroup services, where non-teaching professionals or intervenors, teaching professionals, and school or school center administration meet.

The term "Clinical or Pedagogical Environment" refers, in this Policy, to centers, clinics, or different organizations in the health and social services sector where non-teaching professionals or intervenors and the administration of said environment meet.

The term "Client" refers to a person receiving the services of an Intervenor using our Products or Services.

The term "Intervenor" refers to a person who offers specialized or helping relationship services, such as integration assistant, guidance counselor, special education teacher, special educator, occupational therapist, speech therapist, orthopedagogue, neuropsychologist, resource person, physiotherapist, attendant for people with disabilities, psychoeducator, psychologist, psychotherapist, specialized education technician, tutor, social worker, etc.

The term "Student" refers to a child enrolled in preschool, primary, or secondary school under the age of 18, or a student over 18 enrolled in a special school.

The term "Parent" refers to the parent(s) or guardian(s) of a child enrolled in preschool, primary, or secondary school under the age of 18, a child over 18 enrolled in a special school, or an adult with a disability whose parent or guardian has been appointed by a judge as a guardian who can assume the guardianship of the person with a disability.

The term "Teaching Professional" refers to preschool, primary, and secondary teachers, alternative, special, or other class teachers.

The term "Non-Teaching Professional" refers to any other professional such as educational counselors, service coordinators, middle managers, or administrators.

The term "Users" refers to different types of users: client, intervenor, student, parent, teaching professional, and non-teaching professional.

As the Products or Services are designed to be used in educational, clinical, and pedagogical environments, a significant portion of the collected information is intended to be communicated within the Educational, Clinical, or Pedagogical Environment. Therefore, activities, information, or communications regarding the student through the Products or Services may be visible to people present (under certain conditions and with the consent of the student's parents or guardians) in their educational, clinical, or pedagogical environment, meaning anyone who is called upon to provide services to the student.

In addition, certain information will be accessible to other non-teaching professionals, teaching professionals, and school, school center, clinic, pedagogical center, or organization administrators or employees (see the "Access to Banqo! Product User Data" section below).

The sharing of the aforementioned information is subject to this Policy and the privacy policies of the education, health, and social services institutions in question. If users have questions about sharing this information under these policies, Banqo! suggests that they contact the relevant educational or health and social services institution.

Banqo! has implemented security measures to ensure that this data is not shared outside the Educational, Clinical, or Pedagogical Environment or that such data is shared outside the Educational, Clinical, or Pedagogical Environment in accordance with the conditions established by this Policy and the policy of the school, center, clinic, or organization.

Collected Personal Information

In general, the collected information includes the following:
for banqo, smartplan, or proplan Products or Services

• Last Name
• First Name
• Portrait
• Priority Needs
• Permanent Code
• School Year
• School
• Form of Differentiation
• Adaptation Measure
• Personalized Objectives
• Means
• Strategies
• Resources
• Services
• Progress

For the edpro Product or Services:

• Last Name
• First Name
• Chronological Age

For all Banqo! Products or Services, the specific information collected depends on the type of user.

Banqo! Products or Services DO NOT COLLECT the following data:

• Physiological biometric data;
• Data concerning the student's status regarding free or reduced-price meals;
• Lists of users' contacts or friends;
• Addresses of students or parents.

Cookies

Login cookies are small data files commonly stored on your device when you visit websites and use online services. They are typically used to make websites work or to enhance their functionality, as well as to provide information and assist with personalization. Other technologies similar to cookies (referred to as "local storage technologies") can also store small amounts of data on your device.

Banqo! Products or Services use the following types of cookies and local storage technologies (both technologies collectively referred to as "cookies" here):

Performance and Functionality Cookies: These cookies are not essential but help us personalize and enhance the user experience. For example, they can help us remember your preferences, or your username and password, so you don't have to enter them again each time you use our services.

The Product does not use cookies for advertising purposes.

If you wish to disable the use of cookies on your device, please go to your browser's preferences menu and disable cookies or use private mode when using our services.

Purpose of Collected Information

Banqo! Products or Services collect and use only the necessary information to fulfill their obligations and to provide or improve their services. Specifically, information is collected for the following main reasons:

• Operate the Product(s) or Services;
• Allow users to log into the Product(s);
• Allow teaching or non-teaching professionals to manage the Product(s) and interact with the Product(s);
• Allow administrators and managers of the Product(s) or Services to assign roles and permissions in relation to the Product(s);
• Allow parents or guardians of the student to use the Product(s);
• Allow students to use the Product(s);
• Allow users to share educational files for use;
• Allow users to see the student's progress in relation to targeted skills or goals set for them;
• Provide analytical data to Product(s) or Services administrators or managers; for administrative statistical analysis, software support, customer support, sales, and billing purposes.

Banqo! Products or Services do not conduct advertising or marketing to students or their parents.

No personal information about a student will be used for marketing purposes.

Banqo! Products or Services do not disclose personal information outside the Educational Environment, Clinical Environment, or Pedagogical Environment, except for the purposes established in this Policy, without having obtained the prior written consent of the individuals concerned.

• Parents who log into the Product(s) only have access to personal information about their child.
• Students who log into the Product(s) only have access to personal information about themselves.
• Teaching or non-teaching professionals who log into the Product(s) only have access to personal information about their student or client.

Aggregated data, meaning data that does not allow the identification of users ("anonymized data"), is used for the following purposes:

• Improvement of the Product(s) or Services;
• Research and statistical analysis;
• Product(s)-related marketing;
• and, customer support.

To create anonymized data, all direct and indirect identifiers are removed. These identifiers include, but are not limited to, name, user ID, date of birth, and location information. Additionally, Banqo! commits not to attempt to re-identify this data and not to transfer these anonymized data to any other party that does not commit to this approach.

Regarding anonymized data, all information will be irreversibly destroyed after the collection and use of such data. No precautions related to user anonymity preservation are necessary. Since no personal information is associated with the data, no precautions related to anonymity are necessary.

Data Access

All user access to the Product(s) or Services, as well as all interactions between them within the Product(s) or through the Services, take place within the Educational Environment, Clinical Environment, or Pedagogical Environment and between users.

The various involved users have access to student or client records and are required to abide by eduplan solutions' policies as well as the terms of use.

Student records belong to the school, the school center, the center, and/or the clinic and are under their control, if applicable. Students can access their records if they have been invited by an administrator by logging into their student account. Parents of students under the age of 18 can access their child's information through the parent account by logging in with their account, contacting the account administrator, or writing to Banqo! at the address info@banqo.net.

If incorrect information needs to be corrected, the matter should first be brought to the attention of the record administrator. If the teacher or school is unable to make the correction, parents should notify Banqo! by writing to info@Banqo.net, after which Banqo! will collaborate with the record administrator to correct the inaccurate information.

Third parties do not have access to personal information, student records, except as provided for in this Policy, or after obtaining the written consent of the parent of the student in question, or the student themselves if they are at least 18 years old.

If Banqo! discovers that a student's record has been disclosed without authorization, it must, within three days, notify the school, clinic, or educational center by email, as well as the account administrator, the parent, and, if applicable, the student.

No marketing is conducted with students and parents.

Banqo! does not disclose personal information to third parties for marketing purposes. To learn more about our privacy practices in the operation of our corporate website, please refer to the Banqo! Website Privacy Policy here.

Deletion of Student or Client Records

Student or client records are deleted based on user needs. In general, these types of records are archived for educational and student or client utility purposes by the user, or deleted when no longer needed.

Parents and students over 18 years old can request Banqo! to delete their child's account or their own account, along with all related information, by writing to the address info@Banqo.net.

Regulatory Compliance by Territory

United States of America
FERPA

The acronym FERPA refers to the U.S. federal law Family Education Rights and Privacy Act, which aims to protect the privacy of students' educational records. The FERPA law grants parents certain rights with respect to the educational records of their minor children. These rights include the right to review the student's educational records held by the school, as well as the right to request that a school correct any educational record believed to be inaccurate or misleading.

Additionally, under the FERPA law, schools generally must obtain written permission from a parent before disclosing any information from a student's educational record, which includes all records, files, and documents containing information directly related to the student and maintained by an educational agency or institution, as well as personal information contained in those records. However, the FERPA law allows schools to disclose such records without consent to certain parties under specific circumstances, including these (see 34 CFR § 99.31):

• to school officials with legitimate educational interests;
• to another school to which the student is transferring;
• to specified officials for audit or evaluation purposes;
• to appropriate parties in connection with financial aid to a student;
• to organizations conducting certain studies for or on behalf of the school;
• to accrediting organizations;
• to comply with a judicial order or lawfully issued subpoena;
• to appropriate officials in cases of health or safety emergencies;
• and to state and local authorities within a juvenile justice system, pursuant to specific state law.

While the FERPA law primarily targets educational institutions, Banqo! Products or Services act as a "school official" with a legitimate educational interest under FERPA; our privacy policy is designed to obtain student data in compliance with the FERPA law and to enable educational institutions using Banqo! Products or Services to comply with the FERPA law when using the Products or Services to process student data.

Banqo! Products or Services are designed to operate within the educational, clinical, and pedagogical environments and be used by educational institutions that have access to student data under FERPA. Banqo! considers itself a provider of services to these institutions and their educational communities. Banqo! commits to maintaining the privacy of student data under its control and not using, disclosing, or allowing the use or disclosure of student data in violation of the FERPA law.

Contact

If you have any questions about this privacy policy, you can contact us by writing to info@Banqo.net.

For all communications related to Banqo! Products or Services or to eduplan solutions' practices in relation to student data and privacy, the following contact information is available:

eduplan solutions
info@Banqo.net

Last update: November 2020

Changes to this Privacy Policy

Any changes to this privacy policy will be communicated by email to all authorized account administrators, and will also be available through the Product(s) or Services. If we make changes that significantly impact your rights or how we use your data, we will notify you before these changes take effect. We encourage you to review this policy frequently to stay informed about how we are protecting your information.