Data Usage Policy

How the Dream application collects, uses, protects, and disposes of data — with full transparency for the schools and districts we serve.

1. Purpose

The Dream Data Usage Policy establishes Vivacity Tech PBC’s commitment to responsible data stewardship. It outlines how data—particularly student data—is collected, used, protected, and ultimately disposed of when no longer required. The policy ensures compliance with applicable data privacy and protection laws and provides transparency into the governance of data within the Dream application. The LEA retains ownership and control of all Customer Data, including student data.

2. Scope

This policy applies to:

  • All student data collected via the Dream application
  • Data submitted by users or imported from integrated Google services
  • All employees, contractors, school district personnel, and external partners who access or process data via Dream

Dream is an application designed for K–12 schools and districts to manage personal devices (e.g., Chromebooks, laptops). It tracks device assignments, repairs, and student–device associations.

3. Data Governance Principles

Dream adheres to the following data governance principles:

  • Accountability: Team roles and responsibilities ensure compliance with data standards.
  • Transparency: All data practices are clearly documented and accessible.
  • Privacy and Security: Data must be handled using industry best practices and legal safeguards.

4. Data Collection and Classification

Based on the aforementioned data input sources, Dream may collect data from these various categories:

  • Student Identifiers: name, ID, and email.
  • Device Management Data: device assignments and repair history.
  • Communication Data: phone numbers and email addresses.
  • Google Account Metadata: Google ID, sign-in information (non-sensitive), and account linkage data.
  • Organizational Information: district, building, and organizational structure.
  • Thumbnail and Titles: for identifying roles and personalization within the app.

Data not collected includes race, ethnicity, health data, attendance records, behavioral information, and standardized test results.

Cookies: Dream uses only essential cookies required for authentication, session management, and security (e.g., load balancing, CSRF protection). Dream does not use advertising cookies or third-party tracking cookies. A current cookie list and purposes are available in our Cookie Notice.

5. Data Access and Roles

Vivacity Tech Roles

  • Software Developers: improve application features and functionality.
  • Database Specialists: organize and manage data systems.
  • Tech Leads: oversee data practices and system integrity.
  • Customer Support: individuals within Vivacity who assist customers.
  • RMA Support: individuals within Vivacity who support device repairs and warranty claims.

Dream User Roles

Role NameRole Description
Super AdminFor schools and districts to oversee and manage use of the Dream application to ensure proper use.
Vivacity AdminFor Vivacity employees (Customer Service, Tech Leads, etc.) to assist schools and districts when they encounter issues. Also used to demo the application.
FacilitatorGuide and assist students with their devices, repairs, and Dream.
Building AdminKeep track of students, devices, and repairs that happen within a building.
School District AdminKeep track of students, devices, and repairs that happen within a school district.
Repair TechAssist in managing repairs of student devices and getting devices back to students.
Student Repair TechTrained students who assist in the device repair process for other students.
Super StudentTrained students who assist in the device repair process for other students (similar to Student Repair Tech but a different skill level).
StudentsKeep track of their devices and their repairs.
Practice StudentStudents training to assist in the device repair process for other students.
Loaner ManagerManage who has access to devices and what type of access they have.
Custom RolesSchools can create their own custom roles, which may have access to student data depending on the school's choice and reasoning.

All application access is authenticated, and all users have access to multi-factor authentication (MFA).

6. Data Elements

Student Information

DataNot CollectedOptionalCurrently UsedSourcePurpose
Full Name——✓Dream & GoogleKeep track of students and their laptops & repairs
Nickname—✓—GoogleNo current use
Email Address——✓Dream & GoogleTo provide a way for Dream users to contact students
Phone Number—✓✓DreamTo provide a way for Dream users to contact students
Address✓——
Thumbnail Photo—✓✓GoogleTo help Dream users personalize and identify students
Title—✓✓Dream & GoogleHelp understand the student's role
Student ID——✓DreamUnique identifier so student data is not confused
Gender—✓—GoogleNo current use
Preferred Gender—✓—GoogleNo current use
Date of Birth✓——
Place of Birth✓——
Ethnicity or Race✓——
Language Information✓——
Conduct or Behavioral Data✓——
IP Address / Cookies✓——
Other Application Metadata✓——
Metadata on User Interaction With Application✓——

Student Identifiers

DataNot CollectedOptionalCurrently UsedSourcePurpose
Local (School District) ID Number——✓DreamIdentify the location students need their laptops & repairs
State ID Number✓——
Provider/App Assigned Student ID Number——✓DreamUnique identifier so student data is not confused
Student App Username——✓DreamFor students to log in
Student App Passwords——✓DreamFor students to log in (password is encoded)

Assessment / Attendance Data

DataNot CollectedOptionalCurrently UsedSourcePurpose
Standardized Test Scores✓——
Observation Data✓——
Voice Recordings✓——
Student Scheduled Courses✓——
Teacher Names✓——
Student Daily School Attendance✓——
Student Class Attendance✓——
Online Communication Captured✓——
Student In-App Performance✓——
Student Generated Content✓——

Transcript

DataNot CollectedOptionalCurrently UsedSourcePurpose
Student Course Grades✓——
Student Course Data✓——
Student Course Performance Scores✓——

Transportation

DataNot CollectedOptionalCurrently UsedSourcePurpose
Student Bus Assignment✓——
Student Pick-Up / Drop-Off Location✓——
Student Bus Card ID Number✓——

Special Indicator

DataNot CollectedOptionalCurrently UsedSourcePurpose
English Language Learner Information✓——
Low-Income Status✓——
Medical Alerts / Health Data✓——
Student Disability Information✓——
Specialized Education Services✓——
Living Situations✓——

Enrollment

DataNot CollectedOptionalCurrently UsedSourcePurpose
Student School Enrollment——✓DreamTo identify if the student is still a student
Student Grade Level✓——
Homeroom✓——
Guidance Counselor✓——
Specific Curriculum Programs✓——
Year of Graduation✓——
Academic or Extracurricular Activities✓——
Student Responses to Surveys or Questionnaires✓——

Parent / Guardian Information

DataNot CollectedOptionalCurrently UsedSourcePurpose
Address✓——
Name✓——
Email✓——
Phone✓——
Parent/Guardian ID Number✓——

School Information

DataNot CollectedOptionalCurrently UsedSourcePurpose
School District / Account——✓DreamOrganizational location data to help students with their laptops & repairs
School Building——✓DreamOrganizational location data to help with laptops, repairs, and shipping
Whitelisted IP Address——✓DreamNo current use
Organizational Path—✓✓Dream & GoogleOrganizational data to help schools organize students

Google Account Info

DataNot CollectedOptionalCurrently UsedSourcePurpose
Google ID——✓GoogleSync Google account to Dream
2FA Enrollment—✓—GoogleNo current use
Google Mailbox Setup—✓—GoogleNo current use
Included in Global Address List—✓—GoogleNo current use
Last Google Sign-In—✓—GoogleNo current use
Google Account Creation Date—✓—GoogleNo current use
Google Account Last Updated Date—✓—GoogleNo current use
Google Account Deletion Date—✓—GoogleNo current use

7. Data Usage

Device Data

Vivacity Tech practices data minimization and uses device data for operational and educational purposes, including:

  • Manage assets and repairs
  • Allow communication between authorized students and staff
  • Improve the Dream application and its services
  • Share with approved partners in order to enhance the platform
  • Send to other internal Vivacity platforms that adhere to the same data standards, for the purposes of enhancing Dream

Student Data

Student data is not shared with third parties except as required to provide services explicitly requested by the LEA and under a written agreement with data protection terms aligned to this policy.

8. Retention Periods

We keep information collected on behalf of our customers for the minimum period 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.

9. Deletion and Anonymization

We are committed to adhering to the protocols outlined in the Dream Data Deletion Policy. All deletion and anonymization actions are logged and independently verified to ensure policy compliance.

10. Data Security

Dream implements strong security protocols, including:

  • Encryption: all confidential data is encrypted in transit and at rest.
  • Network Controls: firewalls.
  • Vulnerability Testing: regular security audits and penetration testing.

11. Compliance and Monitoring

  • Audits: internal and third-party audits are conducted periodically.
  • Monitoring: systems monitor for unauthorized data access or misuse.
  • Incident Response: a formal Incident Response Plan is in place for any breach.

Vivacity Tech complies with all applicable federal and state privacy laws including FERPA, COPPA, and any relevant state-specific education privacy legislation. Vivacity will notify affected LEAs of any data breach involving student information within 72 hours of discovery.

12. Student and Parent Rights

Upon request by the LEA, Vivacity will assist in accommodating parent or student requests to access, review, or delete their data in compliance with applicable laws.

13. Data Subprocessors

Vivacity Tech may engage third-party service providers (“subprocessors”) to support the operation, maintenance, and improvement of the Dream application. These subprocessors may have access to student data only to the extent required to perform services on behalf of Vivacity and under strict contractual obligations.

All subprocessors are contractually bound to:

  • Use data solely for the purpose of delivering services to Vivacity Tech;
  • Maintain data security and confidentiality consistent with this policy and all applicable laws;
  • Refrain from further disclosure or use of data for any non-authorized purpose.

Current Subprocessors:

  • Google Cloud Platform (hosting/storage)
  • Google Analytics (product analytics)
  • Auth0
  • EmailJS
  • Oracle NetSuite

Data used by subprocessor:

  • Google Cloud Platform (hosting/storage): stores and processes student identifiers (name, ID, email), device records, repair history, role/permission assignments, and service logs to operate Dream.
  • Google Analytics (product analytics): receives de-identified, aggregated usage events (e.g., feature clicks, page-load timing) and does not receive student PII.
  • Auth0 (authentication and identity management): stores and processes user authentication data, including name, email address, user ID, hashed passwords (if applicable), login timestamps, IP address, and role/permission claims. Auth0 is used to authenticate users, manage sessions, enforce role-based access control, and secure access to Dream. Data is not de-identified.
  • EmailJS (transactional email delivery): processes user contact information, including name and email address, and message content necessary to deliver system-generated communications such as password resets, account notifications, and repair status updates. EmailJS is used to transmit transactional emails required for operation of Dream. Data is not de-identified.
  • Oracle NetSuite (billing and financial management): processes customer order and billing information, which may include staff and, in limited cases, student names and contact information associated with repair tickets, as well as email addresses, physical mailing addresses, phone numbers, organization details, invoice records, and payment status information. NetSuite is used to manage order processing, invoicing, subscription billing, and financial reporting related to Dream services. Data is not de-identified.

The list of subprocessors is maintained within this policy. We update the published list before onboarding new subprocessors. For each subprocessor we disclose the data elements, purpose, and whether the data is de-identified.

14. Training and Awareness

All employees receive mandatory training upon onboarding and annually thereafter.

15. Amendments

This policy may be revised as needed to reflect:

  • Legal or regulatory changes
  • Advances in technology
  • Operational modifications

Amendments will be communicated via the Dream platform and/or email to authorized users.

16. Non-Compliance

Violations of this policy may result in disciplinary action up to termination of employment or contracts. External partners may face agreement termination.

17. Contact Information

For questions or concerns about this policy, please contact the Vivacity Tech Success Team at success@vivacitytech.com.