Smart Campus | Sveosoft, licensed dealer no. 336065909, of 24 Shai Agnon Blvd., Jerusalem, Israel, phone 050-350-3250, email: info@smart-campus.co.il, operates the Smart Campus system — a software-as-a-service (SaaS) system for managing educational institutions, boarding schools, youth villages, pre-military academies, non-profits, educational organizations and other educational frameworks.
This privacy policy explains what personal information is collected or processed through the website, the Smart Campus system, support services, training services, implementation services, communication services and related activities; for what purposes it is used; to whom it may be disclosed; how we protect it; and what the rights of data subjects are.
This policy is written in the masculine form for convenience only and applies to all genders, singular and plural, as the context requires.
1.General
1.1.This privacy policy applies to the use of the Smart Campus website, the Smart Campus system, applications, interfaces, SaaS services, support services, training, forms, inquiries, email, messages and any other service provided by Smart Campus or on its behalf.
1.2.Using the website or the system, opening an account, receiving permissions, submitting details, making contact, entering information or using the services constitutes confirmation that you have read this privacy policy and that information will be processed in accordance with it.
1.3.When the system is used by an educational institution, boarding school, youth village, non-profit, pre-military academy, organization or other customer, this policy applies alongside the service agreement, order form, data processing addendum, terms of use and any other contractual document signed with that customer.
1.4.In the event of a conflict between this privacy policy and a signed agreement with a customer regarding the processing of personal information, the signed agreement shall prevail between the parties, unless the law requires otherwise.
1.5.Smart Campus does not sell personal information of students, participants, parents, guardians, staff or users to third parties.
2.Roles of the parties under privacy law
2.1.With respect to personal information entered into the system by an institution, organization, customer or its users, including information about students, participants, minors, parents, guardians, employees and staff, the institution or customer is generally the database controller, while Smart Campus acts as the database holder and/or processor on behalf of the customer, in accordance with the customer's instructions, the service agreement and the law.
2.2.With respect to information that Smart Campus collects itself for managing the website, business inquiries, demonstrations, support, bookkeeping, information security, customer relations, marketing permitted by law and managing its business, Smart Campus may act as the controller of the information.
2.3.When an inquiry concerns information entered into the system by an institution or customer, Smart Campus may refer the person to the relevant institution or customer, or act according to its instructions, unless the law requires it to act otherwise.
3.Types of information we may collect and process
The information collected or processed varies according to the type of user, the type of customer, the modules activated, the nature of use and the information actually entered into the system.
3.1Information provided when contacting us, requesting a demo or making a business inquiry
We may collect details such as:
- aFull name;
- bName of institution, organization or company;
- cRole;
- dPhone number;
- eEmail address;
- fContent of the inquiry;
- gInformation provided during a call, meeting, demonstration, contact form or correspondence.
3.2Information about system users
In the course of using the system, information such as the following may be collected or generated:
- aUsername;
- bFull name;
- cRole and permissions in the system;
- dEmail address and phone;
- eLogin details and permissions;
- fActivity data in the system;
- gIP address, browser type, device type, operating system and security data;
- hLogs of actions, logins, login attempts, changes, updates, viewing of information and administrative actions.
3.3Information that institutions and customers may enter into the system
Depending on the customer's actual use of the system, information may be entered or processed about:
- aStudents, participants and minors;
- bParents and guardians;
- cStaff, counselors, managers, employees and suppliers;
- dContact details;
- eAttendance data;
- fEntry and exit data;
- gPermission data;
- hPedagogical, educational or operational notes;
- iDocuments, files, images and forms;
- jActivity data in the system;
- kTherapeutic, emotional, health or other sensitive data, insofar as the institution chose to enter it into the system and in accordance with the law;
- lAny other information that the customer or its users enter into the system.
3.4Technical, security and operational information
We may collect and process technical and security information, including:
- aIP addresses;
- bBrowser and device details;
- cOperating system;
- dUsage data;
- eError data;
- fLogs;
- gSecurity data;
- hLogin attempts;
- iPerformance data;
- jInformation required to detect faults, prevent misuse, protect against cyber threats, monitor and improve the service.
3.5Information for payments and bookkeeping
When the service is paid, we may process information required for issuing invoices, collection, bookkeeping, order management, payments, commercial adjustments and compliance with legal obligations.
4.Is providing information mandatory?
4.1.As a rule, there is no legal obligation to provide personal information to Smart Campus; however, without certain information it may not be possible to make contact, receive a demonstration, open an account, operate the system, receive support, make a payment or use some of the services.
4.2.When an institution or organization uses the system for its activities, it is responsible for ensuring that the collection of information, its entry into the system and its use are carried out in accordance with the law, Ministry of Education directives where applicable, privacy notices provided to data subjects and consents required by law.
5.Purposes of processing
Smart Campus will process personal information for the following purposes, in whole or in part:
- aSetting up, operating, maintaining and providing access to the system;
- bProviding SaaS services to institutions and customers;
- cManaging users and permissions;
- dTechnical support, training, implementation and troubleshooting;
- eInformation security, monitoring, permission control, prevention of misuse, fraud prevention and cyber protection;
- fBackup, recovery, availability, maintenance and operational improvement of the service;
- gProducing reports, operating modules and providing functions ordered by the customer;
- hSending system messages, SMS, WhatsApp, email or other messages, insofar as these services were activated or ordered by the customer;
- iManaging relationships with customers, users and suppliers;
- jIssuing invoices, collection, bookkeeping and commercial management;
- kComplying with legal and regulatory requirements, orders, demands of a competent authority or legal proceedings;
- lExercising legal rights, defending against claims and managing risk;
- mImproving the service, measurement, internal control, performance analysis and product development, insofar as this is done in accordance with the law;
- nUse of anonymous, statistical or aggregate data that does not identify a person and does not allow reasonable identification of a person, for security, measurement, service improvement, product development and performance analysis.
6.Information about minors, students, participants and health information
6.1.The Smart Campus system may be used by educational institutions, boarding schools, youth villages, pre-military academies, non-profits and organizations that care for or work with minors.
6.2.Information about minors, students and participants shall be treated as sensitive information or information requiring heightened care, even where the law does not define every detail in it as information of special sensitivity.
6.3.Smart Campus does not approach minors directly for advertising purposes, does not sell information about minors, and does not use information about minors for marketing purposes unrelated to providing the service to the institution.
6.4.The institution or customer is responsible for providing students, participants, parents, guardians, employees and end users with an appropriate privacy notice regarding the use of the system, the types of information to be collected, the purposes of use, the parties authorized to access the information, the rights of data subjects and any other detail required by law.
6.5.Where consent is required by law, including with respect to photographs, medical information, therapeutic information, emotional information, information of special sensitivity, uses that are not a necessary part of the educational or operational service, or use of information about minors, the institution or customer is responsible for obtaining the appropriate consent from the parent, guardian or data subject, as applicable.
6.6.Smart Campus will process information about minors only for the purpose of providing the services to the institution, under the agreement, according to the customer's instructions and in accordance with the law.
6.7.We are aware of the extreme sensitivity of health, therapeutic and psychological data and allergies that may be entered into the system by educational staff. Smart Campus undertakes to process this information under strict security controls, in accordance with the requirements of the law (including the Patient's Rights Law, where applicable) and in alignment with international information security standards for health environments (ISO 27799). Full responsibility for entering the information, managing access permissions to it (Least Privilege) and obtaining consent from the student's parents lies entirely with the institution.
7.Ministry of Education directives and educational institutions
7.1.Where the system is used by an educational institution or a body subject to Ministry of Education directives, the institution and users must act in accordance with the law, Ministry of Education procedures, information security guidelines, privacy guidelines, data transfer procedures and regulatory provisions that apply to them.
7.2.Smart Campus will act in accordance with the Ministry of Education directives that apply to it as a supplier, insofar as they apply, insofar as they have been provided to it, and insofar as required under the engagement with the customer.
7.3.Personal information, sensitive information or student information must not be transferred to Smart Campus by insecure means, such as private email, private WhatsApp, USB devices, external drives or unapproved channels, unless this is permitted by law and approved in advance by the competent authority.
7.4.Transfer of personal or sensitive information to Smart Campus shall be made through the system, secure interfaces, secure upload tools or other channels approved by Smart Campus.
8.Use of cookies and similar technologies
8.1.The website and system may use cookies, local storage, pixels, tags, measurement tools and similar technologies.
8.2.Cookies may be used for:
- aProper operation of the website and system;
- bInformation security and user identification;
- cSaving user preferences;
- dManaging login;
- eUsage analysis and improving the user experience;
- fPerformance measurement;
- gMarketing and advertising, insofar as permitted by law and subject to the required consents.
8.3.Cookies can be blocked or deleted through browser settings. Blocking or deleting essential cookies may impair the ability to use the website or the system.
8.4.Some measurement tools or cookies may be operated by third parties. Third-party use of information is subject to their privacy policies.
9.Use of artificial intelligence and automated tools
9.1.Smart Campus may use software tools, analytics tools, monitoring tools, security tools, automation tools or artificial intelligence tools for operational, business, security or support purposes, subject to the law, agreements with customers and information security procedures.
9.2.Smart Campus will not enter personal information of students, participants, parents, guardians, staff or customers into a public or unapproved AI tool for model training, advertising, independent research or any use unrelated to providing the service, unless this is permitted by law and approved in accordance with the agreement with the customer.
9.3.System users may not copy, export, enter or share information from the system with AI tools, translation tools, summarization tools, analysis tools, chatbots, code tools, transcription tools or any other external service, without prior approval from the institution and Smart Campus, and in accordance with the law.
9.4.Automated outputs, if any, do not replace human, professional, educational, therapeutic, legal or managerial judgment.
10.Disclosure to third parties and subprocessors
10.1.Smart Campus will not sell personal information to third parties.
10.2.Smart Campus may disclose information or allow limited access to information to subprocessors and service providers acting on its behalf, only insofar as necessary for providing the services, securing them, maintaining them, supporting them or complying with the law.
10.3.Subprocessors may include, among others:
- aCloud, hosting and backup providers;
- bInformation security and monitoring providers;
- cCommunication, SMS, WhatsApp, email and system message providers;
- dPayment processing, bookkeeping and collection providers;
- eTechnical support, maintenance and development providers;
- fLegal advisers, accountants, auditors and security consultants;
- gCompetent authorities, as required by law.
10.4.Smart Campus will make reasonable efforts to ensure that subprocessors who receive access to personal information are bound by appropriate obligations of confidentiality, privacy and information security.
10.5.Smart Campus may transfer information if required by law, court order, instruction of a competent authority, legal proceedings, protection of its rights, fraud prevention, prevention of harm to the system or protection of users and data subjects.
11.Transfer of information outside Israel
11.1.Some of the services, infrastructure, cloud, backup, communication, security or support providers may be located outside Israel or operated by international providers.
11.2.When information is transferred or accessible outside Israel, Smart Campus will act in accordance with applicable law, the relevant agreements and the protections required to safeguard the information.
11.3.Use of the system by the customer constitutes confirmation that subprocessors and technological infrastructure may be located outside Israel, insofar as necessary to provide the services and in accordance with the law.
11.4.Notwithstanding the above, it is clarified that with respect to customers and institutions subject to Ministry of Education directives, personal and sensitive information will be stored only on servers located within the borders of the State of Israel, unless other explicit prior approval has been obtained from the competent authority at the Ministry of Education.
12.Information security
12.1.Smart Campus takes reasonable and accepted information security measures for a SaaS system that processes information of educational institutions and minors, in accordance with the nature of the information, the level of risk, applicable law and its contractual obligations.
12.2.Security measures may include, among others:
- aPermission control by role and need;
- bSeparation of permissions;
- cUser authentication;
- dStrong passwords and multi-factor authentication, where required or possible;
- eEncryption of communications;
- fBackups;
- gMonitoring and logging of actions;
- hSecurity incident management;
- iSecurity updates;
- jLimiting access of employees and service providers to need only;
- kTraining employees and service providers on confidentiality, privacy and information security;
- lProcedures regarding the use of end-user equipment, Windows and Mac computers, mobile phones, remote access and external tools.
12.3.Despite security efforts, no technological system is completely immune to intrusion, malfunction, human error, cyberattack or unforeseen events. Smart Campus cannot guarantee absolute immunity, but will act reasonably and professionally to reduce risks and handle incidents.
12.4.The customer and users are responsible for keeping their login details confidential, managing permissions correctly, removing unauthorized users, using strong passwords, avoiding account sharing, protecting end-user equipment and reporting immediately any suspicion of unauthorized use.
13.Security incidents
13.1.If Smart Campus discovers a serious information security incident, or a real concern of such an incident, involving the personal information of a customer or its users, Smart Campus will notify the relevant customer immediately, and no later than 24 hours from the time of discovery and initial verification of the incident, in accordance with the law and the agreement.
13.2.The notice will include, as far as possible at that time, a general description of the incident, the types of information involved, initial actions taken and recommended steps to mitigate the damage.
13.3.Smart Campus and the customer will cooperate to investigate the incident, reduce its impact, report to the Privacy Protection Authority or to data subjects as required by law, and document the handling and lessons learned.
13.4.Users and customers are required to report to Smart Campus immediately any suspected security incident, password exposure, unauthorized access, information sent to the wrong recipient, loss of a device, theft of a computer, suspected phishing, malware, ransomware or any event that may harm the information or the system.
14.Retention and deletion of information
14.1.Smart Campus will retain personal information as long as necessary to provide the services, fulfill agreements, comply with legal obligations, maintain information security, resolve disputes, exercise legal rights or for other legitimate purposes under the law.
14.2.Information entered into the system by a customer will be retained in accordance with the agreement with the customer, the service settings, the order form, the customer's instructions and applicable law.
14.3.Upon termination of the engagement, Smart Campus will allow the customer, for a reasonable period as set in the agreement or by law, to export the information available in the system in a standard format, insofar as supported by the system.
14.4.After termination of the engagement, Smart Campus may delete or block access to the information, subject to the law and the agreement. Deletion from backup systems will be carried out automatically according to the backup and overwrite cycles customary at Smart Campus, so that information deleted from the active system will also be completely deleted from the backup systems at the end of the last relevant backup cycle.
14.5.Information required for bookkeeping, tax, security documentation, fraud prevention, legal defense or compliance with legal obligations may be retained for the period required by law or by legitimate need.
15.Rights of data subjects
15.1.In accordance with the law, a data subject may be entitled to review personal information about them, request correction of information that is not accurate, complete, clear or up to date, and exercise additional rights insofar as they exist under the law.
15.2.When the information is held by Smart Campus on behalf of an institution or customer, the request will generally be addressed to the institution or customer that controls the information. Smart Campus may refer the person to the institution or act according to its instructions, unless the law requires otherwise.
15.3.Requests concerning information that Smart Campus manages itself, such as contact information, marketing information, operational information or support information, may be sent to: info@smart-campus.co.il.
15.4.To handle a request, Smart Campus may ask for details that will allow it to identify the requester, verify their entitlement to the information, locate the relevant information and prevent disclosure of information to an unauthorized person.
15.5.Requests will be handled in accordance with the law, agreements with customers and the reasonable technological capabilities of the system.
16.Direct mail, marketing messages and service messages
16.1.Smart Campus may send customers, prospects, institution representatives and users service messages, system messages, security messages, support messages, operational messages and updates related to the service.
16.2.Marketing messages or advertising will be sent only in accordance with the law and subject to consent where required.
16.3.You may request removal from a marketing mailing list via an unsubscribe link, by replying to the message or by contacting info@smart-campus.co.il.
16.4.Removal from marketing mail does not prevent the sending of service messages, system messages, security messages or messages required to provide the service.
17.Links to external websites and services
17.1.The website or the system may include links to websites, services, systems, documents or tools of third parties.
17.2.Smart Campus is not responsible for the privacy policies, information security, content, terms or conduct of these third parties.
17.3.Use of external services is subject to the terms of use and privacy policies of those third parties.
18.Anonymous and aggregate information
18.1.Smart Campus may use technical, statistical, aggregate or anonymous information that does not identify a person and does not allow reasonable identification of a person, institution or customer, for security, measurement, service improvement, performance analysis, product development, internal control and presentation of general data.
18.2.Smart Campus will not use anonymous or aggregate information in a way that allows reasonable identification of a student, participant, parent, guardian, employee, user or institution, unless this is permitted by law and explicitly agreed.
19.Changes to this privacy policy
19.1.Smart Campus may update this privacy policy from time to time, among other reasons due to changes in law, regulation, Ministry of Education requirements, technology, services or business and operational needs.
19.2.An updated version will be published on the website. The date of the last update will appear at the top of the policy.
19.3.A material change to the policy, where required by law or by agreement, will be brought to the attention of customers or users in a reasonable manner.
20.Privacy contact
For questions, requests or inquiries regarding privacy, you can contact us:
Smart Campus | Sveosoft
- Licensed dealer no.
- 336065909
- Address
- 24 Shai Agnon Blvd., Jerusalem, Israel
- Phone
- 050-350-3250
- Email
- info@smart-campus.co.il
Inquiries about information entered by an educational institution or customer may be forwarded to the relevant institution or customer for handling, as applicable.
