Privacy Policy

Introduction

This Privacy Statement provides information on how SpotBus collects, uses, and protects personal information. SpotBus supports the most critical processes of managing student, class, and school data, and we are committed to the highest standards of protection for personal data at all times. When we refer to “us,” “we,” “our,” or “SpotBus” in this Privacy Statement, we are referring to SpotBus and its affiliates. Privacy is a fundamental right for all individuals. Our clients entrust us with the personal information of both employees and parents, and students. On this basis, we take the responsibility attached to this information very seriously. We are EU -U.S. and Swiss-U.S. Privacy Shield certified and a signatory of the Student Privacy Pledge.

This Privacy Statement governs all the manners in which SpotBus collects personal information directly from you as an individual. Whether you are a visitor to our websites, request a trial of our products or a whitepaper, or any other communication with us (such as attendance at a conference or trade show), this Privacy Statement governs our use of personal information for products and services that we provide directly to you as what is known as a “data controller.” How we collect information and how we use information may differ based on our relationship with you as an individual. We have identified below the different relationships we may have with you, and our respective use of information we collect.

When a customer’s privacy statement/policy governs. If you are an end-user (parent or student, applicant or employee) of our customer (a school or school district) and you are using SpotBus products and services through our customer (your school or school district), we are considered a “data processor.” In these cases, your school or school district’s privacy statement or privacy notice governs the use of any personal information. Our Privacy Statement does not supersede the terms of any agreements between us and your school or school district (our customer), nor does it affect the terms of any agreement between the student and the student’s school or school district.

  1. What Information We Collect and How We Use It

The nature of the personal information we collect and how we use it depends on the context in which we collect that personal information. Please see the section below that applies to you.

  1. Website Users.

You may visit any SpotBus website without having to log in or provide any personal information. If you are on a SpotBus website to access a service or product, you may need to log in to make use of the functionality of the particular product

  1. Information We Collect
    1. Directly from you. You may voluntarily provide us information when you complete a form or survey on our website or subscribe to our blog or newsletters. This may include some or all of the following categories of information: Name and Role; Job title; Signature; Profession; Social media account name; User name; Telephone Number; Street Address; and Email address.
      • You may also provide information when you register for an account through a SpotBus website to log in to use a product or service.
      • You may also submit a resume or other information through our Careers.

If you submit an application or resume, SpotBus will collect and retain the submission, including your personal information and use this information to evaluate you for an employment position at SpotBus as detailed per the Candidate Privacy Notice.  All information is submitted through our third party provider, HireBridge, and is subject to their privacy policy.

      • Our sites offer publicly accessible community forums.  You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely.  To request removal of your personal information from our community forums, contact [email protected].  In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.  We encourage all users to exercise caution when providing personal information in community forums.  If you provide information when you communicate through our SpotBus community forums, we may link this information with your personal information.
    1. Indirectly from you. We collect information about the pages you visit and how you access and use the SpotBus websites using cookies, tracking technologies and other third party analytics tools. Specifically, We and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags on our websites. This information includes information about the devices you use to access the SpotBus website including unique device identifiers, IP address, operating system, browser, and cookies. Depending on your device settings, we may also collect information about your geographical location and what websites you may travel from to our website. We use this information to better understand our customers and users, so that we may provide more effective advertising and products. You can learn about our use of cookies, and set your preferences, in our Cookie Statement.
    2. Information from third parties. We may supplement the information we collect with information from the SpotBus Group affiliates and other third parties that we use to promote our products and services. For example, we may receive information from a third party about how well an online marketing or email campaign performed, or from conference and trade show organizers.
  1. How We Use This Information
    We use the information collected to provide and improve our website services and our products and to analyze usage information for sales and marketing purposes. We also use the information collected to communicate with you in any manner that you have requested. This analysis is necessary to further our legitimate interest in understanding our users and their interactions with us and our websites to best iterate and improve on our websites and communications, including marketing purposes, and to provide you with content that you have requested.Third party information that we collect from social media may be used to provide you with requested information or our newsletter or contact you regarding our services, opportunities, products, and/or events.
  2. How We Share This Information
    Where we use third-party analytics tools to help us understand how the SpotBus websites are used, these parties will have access to some of your personal information. This includes analytics tools such as Google Analytics and LinkedIn Lead Gen. Learn more about our use of cookies in our Cookie Statement.We also share information with our vendors and service providers and other third parties for legal or business purposes, but only as permitted and subject to required limitations. See Vendors, Partners, & Other Disclosures.
  1. Customers (Schools and School Districts).

If you are a customer of SpotBus, we are providing our products and services directly to your school or school district and we are a “data controller” for purposes of the personal information collected in connection with the customer accounts.

  1. Information We Collect
    1. Directly from you. We collect information necessary to provide the educational technology services as directed by you. The information collected from you depends on the specific product and what is needed to integrate with your systems and to set up and maintain accounts. This includes information in the following data categories:
      • Account information: The exact elements will depend on the product and what specific information you as a customer provide us, but often we receive from you include pupil records of students and parents of students enrolled in your school or district, such as directory information, email addresses, student IDs, account credentials, courses students are enrolled in, health information kept in student records.
      • We also collect employee account information including user names, email addresses and titles to initially set up products and services for you.
      • Depending on your needs as a customer, we may also collect financial information of students and parents of students as you make available to us in order to provide services.
    2. Indirectly from you. We collect device and usage information when you access and use our products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service and cookie data. Specifically, we and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags. The purpose of collecting such information is for improvement of our products and services to better meet the needs of our customers and their users. Learn more about our use of cookies in our Cookie Statement.
    3. From third parties. We may receive information from affiliates in our SpotBus Group of companies and other third parties. For example, we may receive limited personal information from third-party services that integrate with or complement the SpotBus products or services in order to provide you with the best possible user experience.
  2. How We Use This Information
    We use your information to provide you the features and functionality of the SpotBus products and services, as well as to communicate directly with you and allow you to communicate with other SpotBus users. It is necessary for us to use your information in this manner in order to provide you with the services your school district has requested pursuant to its agreement with SpotBus.We will use your information to provide you with news and information about new products and services. Any such marketing communications from us may be discontinued at any time. See Marketing. We may also use de-identified and aggregated information to understand and improve our products and services. We may share general customer contact information with certain Partners as is necessary to offer and provide our products and services to our current and prospective clients. No customer data other than general institution contact information is provided for these purposes. For absolute clarity, we do not provide any student data or personally identifiable information to any Partners for marketing purposes.
  3. How We Share This Information
    We share information to provide the SpotBus products and services to you and further improve them. Within SpotBus, your information will be accessed only by those who have a need to provide the SpotBus products and services. We use vendors to help us provide the SpotBus products and services to your school or school district. For example, if your school or school district has a hosted SpotBus product or service, Amazon Web Services and Azure provide our cloud hosting facilities. Third-party analytics tools may also have access to your personal information to help us understand how the SpotBus products and services are being used. Learn more about our use of cookies and analytic tools in our Cookie Statement.
  4. Student Personal Information
    SpotBus is a data processor with respect to student personal information and the SpotBus customer (school or school district) is the data controller. Where a SpotBus customer enters into an agreement with SpotBus to provide products and services, that SpotBus customer acknowledges that SpotBus is a data processor with respect to personal information received from that SpotBus customer or from a student/parent in connection with the SpotBus products and services.

    1. Student Personal Data Ownership All student personal data remains the property of and is solely owned, and thereby controlled, by our SpotBus customers. You grant SpotBus a non-exclusive, royalty free license, to use equipment, software, your data or other material of yours solely for the purpose of providing, maintaining, and supporting you and other licensees with SpotBus products and services.SpotBus will only use student personal data for the purposes of providing the products and services that our customers (school or school districts) have contracted with us to provide and we will process student personal data according to instructions and the terms of our contract with our customers.Student personal data will not be used for targeted Advertising by SpotBus or any of its affiliates.
  1. Parents and Students

The school or school district decides how your personal information is used.
SpotBus provides learning and registration products and services to end-users of a school or school district (our customers) as a “data processor.” The main responsibility of what is known as a “data controller” lies with the school or school district. This also means that the school or school district’s own privacy statement governs the use of student personal information. SpotBus’s customers determine what information we collect through the SpotBus products and services and how it is used, and we process that information according to our customer’s instructions and the terms of our contract with our customer.

This section of our Privacy Statement is provided for informational purposes and describes how parent and student personal information is used when SpotBus products and services are provided through a school or school district. How that information is used depends on the school or school district, so please consult your institution’s privacy statement.

  1. Information We Collect
    1. Information provided to us by a school or school district. The SpotBus products and services integrate with our customer’s systems. The specific information that is collected from the school or school district depends upon the SpotBus product or service, but in general, this information includes but is not limited to:name, age, email address, student ID, account credentials, academic and student records, certain health information kept in student records, courses a student is enrolled in when we initially set up the products, and additional records as requested by the school or school district. Depending on the school or school district’s request, we may also collect financial information of students and parents of students as is made available to us in order to provide services. SpotBus will receive regular updated information to keep account information accurate and up to date.
    2. Directly from a parent or student: Depending on the SpotBus products and services your school (or your child’s school) uses, we will collect the following data categories directly:name, age, email address, student ID, account credentials, academic and student records, certain health records, courses a student is enrolled in when we initially set up the products and services for your institution, and additional records as requested by the school or school district. Depending on the school or school district’s request, we may also collect financial information of students and parents of students in order to provide services. SpotBus will receive regular updated information to keep account information accurate and up to date.
    3. Indirectly from a parent or student: We collect device and usage information when you access and use SpotBus products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service, and cookie data. Specifically, We and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags. The purpose of collecting such information is for improvement of our products and services to better meet the needs of our customers and their users. Learn more about our use of cookies in our Cookie Statement.
  2. How We Use This Information
    1. On behalf of your school or school district. We use your information on behalf of and under the instruction of your child’s school or school district, which is the data controller. We use the information in accordance with our agreement with your child’s school or school district to operate, maintain, and provide the features and functionality of the SpotBus products and services. Your child’s school or school district determines how the personal information is used.
  3. How We Share This Information
    We share student information in accordance with our agreement with your (or your child’s) school or school district. Generally, this includes the sharing of such information inside and outside SpotBus under certain terms. Student information will be accessed inside SpotBus only by those have a need to know to provide the SpotBus products and services and improve them. For example, our technical and client support teams may have access to personal information when the SpotBus products and services are implemented for your school or school district or when software or other changes are required for support and maintenance purposes. We use vendors to help us provide the SpotBus products and services to you (or to your child) on behalf of our school or school district customer.
  1. Users of our Products, not including Students or Parents.

SpotBus provides applicant and job candidate tracking services to end-users of schools, school districts, and higher education agencies (our customers) as a “data processor.” The main responsibility of what is known as a “data controller” lies with the customer. This also means that the customer’s own privacy statement governs the use of personal information collected through our products. SpotBus’s customers determine what information we collect through the SpotBus products and services and how it is used, and we process that information according to our customer’s instructions and the terms of our contract with our customer.

This section of our Privacy Statement is provided for informational purposes and describes how applicant personal information is used when SpotBus products and services are provided through a school or school district. How that information is used depends on the school or school district, so please consult your institution’s privacy statement.

  1. Information We Collect
    1. Information provided to us by a school, district, or education agency. The SpotBus applicant tracking products and services integrate with our customer’s systems. The specific information that is collected from our customer depends upon the SpotBus product or service, but in general, this information includes but is not limited to: name, age, email address, social security number, account credentials, academic and student records, background check information, and additional records as requested by the customer. SpotBus will receive regular updated information to keep account information accurate and up to date.
    2. Directly from a customer’s applicant: SpotBus will collect the following data categories directly from a customer’s applicant-user: name, age, email address, social security number, account credentials, academic and student records, background check information, and additional records as requested by the customer. SpotBus will receive regular updated information to keep account information accurate and up to date.
    3. Indirectly from customer’s applicant: We collect device and usage information when you access and use SpotBus products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service, and cookie data. Specifically, We and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags. The purpose of collecting such information is for improvement of our products and services to better meet the needs of our customers and their users. Learn more about our use of cookies in our Cookie Statement
  2. How We Use This Information
    1. On behalf of the customer. We use your information on behalf of and under the instruction of the customer education agency, which is the data controller. We use the information in accordance with our agreement with our customer to operate, maintain, and provide the features and functionality of the SpotBus products and services. The school, district, or education agency determines how the personal information is used.
  3. How We Share This Information
    We share student information in accordance with our agreement with a customer. Generally, this includes the sharing of such information inside and outside SpotBus under certain terms. Applicant information will be accessed inside SpotBus only by those have a need to know to provide the SpotBus products and services and improve them. For example, our technical and client support teams may have access to personal information when the SpotBus products and services are implemented for a customer or when software or other changes are required for support and maintenance purposes. We use vendors to help us provide the SpotBus products and services to you on behalf of our customers.
  1. Sharing with Vendors, Partners, and Other Disclosures
  1. Vendors. We engage directly with certain third-party companies to help us provide the SpotBus products and services to our customers or to you or to perform work on our behalf (“Vendors”). Our vendors are required to abide by our privacy and security instructions and are contractually restricted from using any personal information they access or receive from us for any purposes other than as needed to perform such services. We may use vendors to help us conduct marketing campaigns or events and disclose customer contact information necessary for those activities.
  2. Partners. Your institution may work with third-party companies to provide additional content and functionality which requires access to SpotBus products and services (“Partners”) Only with your institution’s permission, will we share information about you, such as your name, email, or student ID, that is required to provide you with access to the products and services that have been requested by your institution. In these cases, these Partners will enter into an agreement directly with your institution regarding the processing of any data at the direction of your institution.
  3. Other Types of Disclosures. We may also share your information where required under the following circumstances:
    1. Where permitted by applicable law and by contracts with our customers, we may disclose your information in the course of a corporate transaction such as a merger, acquisition, sale of assets, or a financing, or pursuant to a bankruptcy, dissolution proceeding or reorganization.
    2. We may need to disclose your information to comply with legal or regulatory requirements and to respond to lawful requests, court orders, and legal processes. Where such disclosures relate to personal data we hold as a data processor on behalf of our customers, we will refer such requests to our customers where permissible.
    3. We may need to disclose your information to protect and defend the rights, property, or safety of SpotBus, our customers, or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or other misuse of our systems.
    4. We may utilize aggregated or de-identified (anonymized) information that is no longer associated with a person to enhance and promote the SpotBus products and services. SpotBus does not rent, sell, or otherwise provide access to student personal data to third parties for marketing or advertising purposes.
  4. Marketing. We conduct marketing to promote the SpotBus products and services, but do not use or disclose information (whether personal information or otherwise) about students that we collect through the provision of SpotBus products and services for targeting of advertisements to students.When we conduct (or sponsor) events, conferences, and webinars, we will collect information about attendees, such as the session they attend and their contact information to provide them information about SpotBus products and services and other SpotBus information.
    1. Marketing Preferences and Opt-Out. Our marketing emails will always include an “unsubscribe” link so that you can change your preferences and opt-out of receiving marketing emails or communications from SpotBus. You can also send us email at [email protected] to unsubscribe.Please note that even if you opt-out of marketing emails, we may still need to contact you with important information about your SpotBus account.
  5. Interest-based Advertising. We use third party advertising tools to collect information about your visits to the SpotBus websites to provide targeted advertisements to you based on your browsing history on other websites or on other devices you may use. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.To learn more or opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:
    1. Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices)
    2. European Interactive Digital Advertising Alliiance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu)
    3. Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).
  6. Google Analytics and Advertising. We also use Google Analytics and other third-party cookies to collect certain information about your visits to our SpotBus websites.  You can opt-out of third-party cookies from Google Analytics using the Google Analytics opt-out browser setting add-on or other ad management tools.You can learn more about our use of cookies in our Cookie Statement and you can learn about managing your preferences.
  7. “Do Not Track” Signals. Without a common industry or legal standard for interpreting so-called “Do Not Track” (DNT) signals, SpotBus does not respond to browser DNT signals.  We will continue to monitor further development of a DNT standard by the privacy community and industry.

III. Data Retention

  1. Website Users

We keep website usage information for as long as necessary for the purposes described above. Account information is retained until you delete the account and for a limited period thereafter. Where you have provided information in forms, we retain the information as long as it is required, depending on the nature of the request. If you unsubscribe from receiving marketing communications from us, we will keep a record of this to ensure that you do not receive such communications in the future.

  1. Customers (Schools and School Districts)

We keep information collected on behalf of our customers for as long as necessary and pursuant to contractual terms. We dispose of information that is not held pursuant to contractual terms in a commercially reasonable time period or at the request of a customer.

  1. Children’s Privacy

We do not knowingly collect any information from children under the age of 16 unless and until the SpotBus customer (school or school district) has provided authorization for a student under 16 to use the SpotBus products and services and for us to collect personal information from such student.

Please contact us at [email protected] if you believe that we have inadvertently collected personal information from a child under 16 without proper consent.  This will allow us to delete such information as soon as possible.

  1. Security

SpotBus employs a variety of physical, administrative, and technological safeguards that are designed to protect personal information against loss, misuse, and unauthorized access or disclosure. We strive to continuously enhance our technical and operational security measures. Our measures consider the type and sensitivity of the data being collected, used, and stored, and the current state of technology and threats to information. SpotBus’s security measures include data encryption, firewalls, data use and access limitations for personnel and vendors, and physical access controls to our facilities. SpotBus independently verifies its security management system to the internationally recognized standard for security management and holds ISO 27001 certification. SpotBus also aligns its privacy and security operations to best practices and relevant international regulations.

  1. International Data Transfers: EU-U.S., Swiss-U.S. Privacy Shield

SpotBus is headquartered in the United States, and data is transferred to the United States for processing for the purposes of providing SpotBus products and services to customers outside the United States. This subsection is only applicable to customers that have contracted with SpotBus and reside in the European Union or Switzerland.

SpotBus participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. SpotBus is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List. (https://www.privacyshield.gov/list)

SpotBus is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. SpotBus complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, SpotBus is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, SpotBus may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

We encourage you to contact us at [email protected] should you have a Privacy Shield-related question, concern, and/or complaint. SpotBus takes all concerns about privacy and use of personal information seriously and shall endeavor to reply to you within 45 days of receiving a complaint.

VII. Access (INCLUDING IF YOU ARE LOCATED IN THE EUROPEAN ECONOMIC AREA (EEA), UNITED KINGDOM, OR SWITZERLAND)

THIS SECTION APPLIES TO USERS OF OUR PRODUCTS AND SERVICES THAT ARE LOCATED IN THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM OR SWITZERLAND AT THE TIME OF DATA COLLECTION. WE MAY ASK YOU TO IDENTIFY WHICH COUNTRY YOU ARE LOCATED IN WHEN YOU USE SOME OF OUR PRODUCTS OR SERVICES, OR WE MAY RELY ON YOUR IP ADDRESS TO IDENTIFY YOUR COUNTRY LOCATION.

  1. SpotBus’s relationship to you.
  1. Data Controller for Website Users – A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions. With respect to the personal data of our customers or received through our SpotBus websites, SpotBus is a controller in relation to the information that you enter directly into the website about yourself or when you register for an account through your school or school district.
  2. Data Processor for Schools and School Districts – To the extent that SpotBus receives personal information through its customers’ (school or school district) use of SpotBus products or services, SpotBus is a processor and the SpotBus customer is the data controller.
  1. Individual data subject rights. 

In many of the SpotBus products and services, you will be able to access student information as well as change and delete some of the information by logging into the parent/student account. If you cannot access, correct, or delete the required information on your own, please follow these steps:

For parents/students: SpotBus does not control your personal information. We provide our products and services on behalf of your school or school district. Please contact your institution to exercise your rights of access, rectification, erasure, or restriction of use of personal information. The institution needs to manage your request under applicable laws and SpotBus will support our schools and school districts with such requests.

  1. For all access requests:

Please email SpotBus at [email protected] or contact us using the information in the “CONTACT US” section if you want to exercise any of these rights.

When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways: (i) where denial of access is required or authorized by law; (ii) when granting access would have a negative impact on other’s privacy; (iii) to protect our rights and properties; and (iv) where the request is frivolous or burdensome.

In many jurisdictions, you also have the right to lodge a complaint with the local data protection authority.   A listing of EEA data protection authorities can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.   But, please contact us at SpotBus first, so we can address your concerns.

For information regarding how to contact our EU Representative, please contact us at [email protected]

VIII. United States Federal and State Education Privacy Laws

SpotBus, in its role as a vendor to educational agencies and institutions, both public and private entities (“Educational Agencies”), receives disclosures from the Educational Agencies, which include the personal information and other data (“Student Data”) contained in student records as well as directly from students and parents of students. Only information that is needed for SpotBus to perform services, which are outsourced to SpotBus by the Educational Agencies, is disclosed to SpotBus. These disclosures are authorized by the federal Family Educational Rights and Privacy Act (FERPA). SpotBus considers Student Data to be strictly confidential and do not use Student Data for any purpose other than improving and providing our products and services to the Educational Agencies or on the Educational Agencies’ behalf. Our collection, use, and sharing of Student Data is governed by our contracts with the Educational Agencies, the provisions of FERPA, the Children’s Online Privacy Protection Act (COPPA), and other applicable state and federal laws and regulations that relate to the collection and use of personal information of students. If you have questions about reviewing, modifying, or deleting personal information of a student, please contact the relevant Educational Agency(ies) directly.

  1. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 allows you to request information on how we disclose personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at [email protected] or writing to us (see address below in “CONTACT US”).

Please see HERE for our privacy notice regarding the California Consumer Protection Act (CCPA).

  1. Links to Other Sites

Our SpotBus websites may provide links to third party websites or resources. The information practices of those websites are not covered by this Privacy Statement or any other policies or terms applicable to the SpotBus websites or the SpotBus products or services. We recommend that you review any terms of use and privacy policy of any linked third-party website before providing any information.

  1. Changes to This Privacy Statement

We may update this Privacy Statement and its last updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

XII. For U.S. Educational Agency Customers

Pursuant to state law, the following state specific language is hereby incorporated into this Privacy Statement, provided that SpotBus is providing and/or offering you SpotBus products or services in one of the following states (capitalized terms below which are not otherwise defined in this Privacy Statement are as defined either in the applicable state law or in your SpotBus agreement):

California – SpotBus will not use your data for any purpose beyond the indicated purposes in the Terms of Use, which includes this Privacy Statement. This includes, but is not limited to, SpotBus’s policy to never use PII from a Pupil’s Records to engage in targeted advertising.

Please see HERE for our privacy notice regarding the California Consumer Protection Act (CCPA).

Colorado – SpotBus will not use your data for any purpose beyond the indicated purposes in the Terms of Use, which includes this Privacy Statement. Only the SpotBus employees that have a legitimate interest in accessing your data, will be granted authorization by SpotBus.

Connecticut – SpotBus will not use your data for any purpose beyond the indicated purposes in the Terms of Use, which includes this Privacy Statement. This includes, but is not limited to, SpotBus’s policy to never use any student’s PII to engage in targeted advertising. SpotBus also avers to utilize industry standard security, or better, to ensure the protection of said student PII. Connecticut law shall govern this agreement between you and SpotBus. All terms herein are defined in accordance with Public Act No. 16-189, and in case of any ambiguity or conflict between the terms herein and Public Act No. 16-189, then Public Act No. 16-189 will govern.

Florida – SpotBus will provide notification of a security breach pursuant to requirements as mandated in the Florida Information Protection Act of 2014.

Maryland – SpotBus will not use Covered Information to engage in targeted advertising.

New York – In accordance with New York Education Law § 2-d, SpotBus will comply with and attach to your contract the Parents’ Bill of Rights for Data Privacy and Security, as applicable.

Pennsylvania – SpotBus will provide notification of a security breach pursuant to the requirements of Pennsylvania’s Breach of Personal Information Notification Act.

Washington – SpotBus will provide notice before making material changes to this Privacy Statement.

XIII. Canada

The Personal Information Protection and Electronic Documents Act (PIPEDA) is a Canadian federal law that applies to the collection, use, and disclosure of personal information in the course of commercial activities in all Canadian provinces as supplemented by substantially similar provincial privacy laws in Alberta, British Columbia and Québec. PIPEDA also applies to international and interprovincial transfers of personal information. This policy is designed to comply with PIPEDA.

Disclosure and/or sharing of Personal Information

SpotBus, Inc reserves full ownership over the information collected on this domain www.SpotBus.us and its subsidiaries. The said information is collected from reputed sources (Section 1.2) and from different points in the said domain and its sub-domains. We will not sell, share, and/or rent the said data to third-party vendor(s) in other ways than disclosed as below:

  • In reasonable need to offer similar services
  • When you have provided us consent for the purpose
  • When we are legally obliged to do so

Usage of Personal Data

We lawfully process subject data in abiding to fulfill our “legitimate interests”. The following includes a non-exhaustive list of “legitimate interests” under which we operate:

  • Betterment of our Services by providing easily accessible and usable technology(ies) that enable our clients to execute their business objectives with more certainty.
  • When prior consent is asked from and provided by subjects through the same channel of communication, and the objective of such communication is in line with clause a).
  • Where processing in necessary to comply with our legal obligations, and on demand from regulatory authorities.

The data and content provided or made available to us by users across our Services is used in the collection, compilation and collation of data of respective subjects. Subject data is also used in conducting research and development programs to improve user experiences across our digital spectrum, and for the overall improvement of our Services.

We notify subjects about the usage of their data in writing, through emails or other media as available (SMS, push notifications etc.) and agreed by both parties. Our communications may also include:

  • Service Messages:to acknowledge ongoing and concluded transactions and interactions. Examples include: welcome messages, meeting schedules etc. There are no opt-out options for service messages.
  • When prior consent is asked from and provided by subjects through the same channel of communication, and the objective of such communication is in line with clause a).
  • Marketing Communications:on our own behalf or on behalf of known third parties. Such communications maybe sent when subjects have shown interest in receiving so – even when they do not have an account with us. Each of our marketing communications has an opt-out option at the footer of the messaging, in case subjects desire to stop receiving future mails in the same regard.

we do not use personal data to engage in automated decision-making about subjects.

Sharing of Personal Data

We share subject data with:

  • Our Affiliates (legal entities controlled by us, controlling us, or share a common authority of control with us) within reasonable limits, with the sole purpose of providing our Services.
  • Selected Third Parties, including our business partners, vendors/suppliers, and sub-contractors, for the performance of the contract we are in with them.
  • Analytics and Search Engine Providers who assist us in improving our digital presence from time to time.

Under special circumstances, we may disclose your data to other third parties too. Such circumstances may include and not be limited to:

  • Selling or buying of business assets
  • Business acquisition by third party (data may become a transferred asset)

We ensure maximum contractual and operational safeguards in the instance of third-party processing of subject data.

Subject Rights for Data Security, Accuracy & Retention

Under applicable data privacy regulations, subjects may:

  • Request for access to the data we have about them
  • Request for the same to be updated, rectified, deleted, or blocked
  • Request to abstain from using the said data
  • Revoke their consent on processing their data (for consent-based processing)
  • Request for a machine-readable copy of the data we have of them.

To exercise any of the rights listed above, please email us at [email protected] or write to us at the following address:

SpotBus Inc

114 Turnpike RD STE 106

Westborough MA 01581, USA

Please note: We cannot always delete records of all historical data, and this is in compliance to legal audits and financial reporting purposes.

Opt-out Policy:

Upon your request, SpotBus, Inc will:

  • Allow any subscriber to “opt out” of further promotional contacts/li>
  • Use reasonable efforts to allow subscriber to update/correct personal information previously submitted which he/she states is erroneous to the extent such activities will not compromise privacy or security interests
  • Initiate reasonable efforts to functionally delete the subscriber and his/her personal information from its database. Visitors should be aware that it might be impossible to completely delete erroneous information or a visitor’s personal information without some residual information remaining in its database because of backups and records of deletions.

In case of breaches or any other data-related concerns (subject to this privacy statement), subjects may lodge complaints with their regional data privacy regulator. For UK citizens, it is the Information Commissioner’s Office. Concerns can be directly reported at http://www.ico.org.uk/concerns.

We retain subject data for as long as it is reasonably necessary, for providing our Services. Such data is anonymized in a reasonably practical time-frame after the subject stops using our Services.

Sufficient safeguards are taken while transferring subject data to other countries. We are obliged to provide a copy of said safeguards and related privacy rights on request by the subjects in concern.

Data Security & Confidentiality

At SpotBus, Inc we give utmost importance to safeguard your privacy, at every step of processing or storing your personal information. We take every step to protect the confidentiality and security of the said data. We apply a state-of-the-art server with the latest encryption. To provide you better services, without causing any disruption to your experience with us, we may share your personal information only with partners whose products/services are relevant to you.

3.1. SpotBus, Inc ensures that all customer data remains the property of the respective customers. We also do not use, rent, sell, transfer, or otherwise expose the contents of the tracking information resulting from click-through, messages opened, messages read, or eCommerce conversions. SpotBus, Inc provides an SSL encrypted, password-protected mechanism for viewing and extracting customer data.

3.2. We maintain all customer data in a carrier-class secure facility protected by firewalls and other security devices. These measures are designed to protect visitor and client information from loss, misuse, or unauthorized alteration.

3.3. We use a third party for credit card processing. This intermediary is solely a link in the distribution chain and is not permitted to store, retain, or use the information provided expect for the sole purpose of credit card processing. We restrict access to this information to only those employees who require the information for business purposes

Contact Us

If you have any questions or concerns about your privacy or this Privacy Statement, please contact us at [email protected]

You may also write to us at:

SpotBus Inc

114 Turnpike RD STE 106

Westborough MA 01581, USA
ATTN:  Privacy

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.