Privacy Policy for School Monitor WhatsApp Bot

Last Updated: [23th-October-2024]

1. Introduction

Welcome to the Privacy Policy for School Monitor WhatsApp Bot (“the Bot”), a service provided by NugSoft Technologies (“we,” “our,” or “us”). This Privacy Policy is designed to help you understand how we collect, use, share, and protect your personal information when you use our Bot.
School Monitor WhatsApp Bot is a Software as a Service (SaaS) product that allows parents to access school-related information of their children enrolled in Schools using the School Monitor software through their WhatsApp account. In the future, we may expand our services to include features for other categories as well.

2. Owner and Data Controller

NugSoft Technologies
Kyanja, 1km off Gayaza road,
P.O Box 134866, Kampala, Uganda
Owner contact email: in**@nu*****.com

3. Types of Data Collected and Processed

We collect and process the following personal data:

WhatsApp phone number and the inferred country based on the WhatsApp number country code.
Usage statistics, including timestamps, length, and type (video, audio, image, document, location, text) of messages sent to the Bot. These statistics are associated with a Database ID rather than the actual phone number.
Temporary storage of messages sent to the Bot to ensure proper conversation flow and appropriate responses.
Message tracking to determine the appropriate response based on the user’s request.
For parents who have added their numbers to schools using the School Monitor software, we periodically request information from the School Monitor software when you need data from that source. This data is only made available to the Bot if your child’s school has enabled this feature to be accessed through the WhatsApp Bot.

4. Purpose of Data Processing

The primary purposes for collecting and processing this data are:

To provide you with the requested services through the Bot.
To improve and optimize the Bot’s performance and user experience.
To authenticate users and ensure data security.
To comply with legal obligations and enforce our terms of service.

5. Legal Basis for Processing

We process your personal data based on the following legal grounds:

Consent: When you agree to our terms of service and privacy policy.
Contract performance: To fulfill our obligations in providing the Bot service.
Legitimate interests: To improve our services and protect our legal rights.
Legal obligation: To comply with applicable laws and regulations including data privacy of WhatsApp for developers building products off the WhatsApp Cloud API.

6. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide the Bot service to you.
Whether there is a legal obligation to which we are subject.
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

7. Data Sharing and Third-Party Access

We do not share your personal details with any third-party services. However, to provide the School Monitor service, we query the details you’re requesting from the School Monitor software after ensuring you’re authorized to access such information in a manner permitted by the School which grants access to such information through the bot.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include:

Encryption of data in transit and at rest.
Regular security assessments and audits.
Access controls and authentication procedures.
Employee training on data protection and security.

9. Your Rights

As a user of our Bot, you have certain rights regarding your personal data:

Right to access: You can request a copy of the personal data we hold about you.
Right to rectification: You can ask us to correct any inaccurate or incomplete data.
Right to erasure: In certain circumstances, you can ask us to delete your data.
Right to restrict processing: You can ask us to limit how we use the limited data we get on your account.
Right to object: You can object to our processing of your data in certain circumstances.
Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time.
To exercise these rights, please contact us using the information provided in Section 2.

10. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes through the Bot or other means including showing the last update of this privacy policy at the top of the page for your convenience.

11. Contact Us

If you have any questions, concerns, or requests regarding this privacy policy or our data practices, please contact us at:
Email: in**@nu*****.com
Address: NugSoft Technologies, Kyanja, 1km off Gayaza road, P.O Box 134866, Kampala, Uganda

12. Consent

By using the School Monitor WhatsApp Bot, you consent to the collection, use, and processing of your personal data as described in this privacy policy. If you do not agree with these terms, please do not use our Bot, or reject the prompt to accept it on sending your first message to the Bot which ensures you’re comfortable with our privacy policy that governs your use of the service.

13. Definitions

Personal Data: Any information relating to an identified or identifiable natural person.
Processing: Any operation performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
User: The individual using our Bot, which coincides with the Data Subject, who is the subject of Personal Data.
Data Controller: The natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processor: A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

14. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of Uganda, without regard to its conflict of law provisions.