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 Name | Role Description |
|---|---|
| Super Admin | For schools and districts to oversee and manage use of the Dream application to ensure proper use. |
| Vivacity Admin | For Vivacity employees (Customer Service, Tech Leads, etc.) to assist schools and districts when they encounter issues. Also used to demo the application. |
| Facilitator | Guide and assist students with their devices, repairs, and Dream. |
| Building Admin | Keep track of students, devices, and repairs that happen within a building. |
| School District Admin | Keep track of students, devices, and repairs that happen within a school district. |
| Repair Tech | Assist in managing repairs of student devices and getting devices back to students. |
| Student Repair Tech | Trained students who assist in the device repair process for other students. |
| Super Student | Trained students who assist in the device repair process for other students (similar to Student Repair Tech but a different skill level). |
| Students | Keep track of their devices and their repairs. |
| Practice Student | Students training to assist in the device repair process for other students. |
| Loaner Manager | Manage who has access to devices and what type of access they have. |
| Custom Roles | Schools 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
| Data | Not Collected | Optional | Currently Used | Source | Purpose |
|---|---|---|---|---|---|
| Full Name | — | — | ✓ | Dream & Google | Keep track of students and their laptops & repairs |
| Nickname | — | ✓ | — | No current use | |
| Email Address | — | — | ✓ | Dream & Google | To provide a way for Dream users to contact students |
| Phone Number | — | ✓ | ✓ | Dream | To provide a way for Dream users to contact students |
| Address | ✓ | — | — | ||
| Thumbnail Photo | — | ✓ | ✓ | To help Dream users personalize and identify students | |
| Title | — | ✓ | ✓ | Dream & Google | Help understand the student's role |
| Student ID | — | — | ✓ | Dream | Unique identifier so student data is not confused |
| Gender | — | ✓ | — | No current use | |
| Preferred Gender | — | ✓ | — | No 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
| Data | Not Collected | Optional | Currently Used | Source | Purpose |
|---|---|---|---|---|---|
| Local (School District) ID Number | — | — | ✓ | Dream | Identify the location students need their laptops & repairs |
| State ID Number | ✓ | — | — | ||
| Provider/App Assigned Student ID Number | — | — | ✓ | Dream | Unique identifier so student data is not confused |
| Student App Username | — | — | ✓ | Dream | For students to log in |
| Student App Passwords | — | — | ✓ | Dream | For students to log in (password is encoded) |
Assessment / Attendance Data
| Data | Not Collected | Optional | Currently Used | Source | Purpose |
|---|---|---|---|---|---|
| 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
| Data | Not Collected | Optional | Currently Used | Source | Purpose |
|---|---|---|---|---|---|
| Student Course Grades | ✓ | — | — | ||
| Student Course Data | ✓ | — | — | ||
| Student Course Performance Scores | ✓ | — | — |
Transportation
| Data | Not Collected | Optional | Currently Used | Source | Purpose |
|---|---|---|---|---|---|
| Student Bus Assignment | ✓ | — | — | ||
| Student Pick-Up / Drop-Off Location | ✓ | — | — | ||
| Student Bus Card ID Number | ✓ | — | — |
Special Indicator
| Data | Not Collected | Optional | Currently Used | Source | Purpose |
|---|---|---|---|---|---|
| English Language Learner Information | ✓ | — | — | ||
| Low-Income Status | ✓ | — | — | ||
| Medical Alerts / Health Data | ✓ | — | — | ||
| Student Disability Information | ✓ | — | — | ||
| Specialized Education Services | ✓ | — | — | ||
| Living Situations | ✓ | — | — |
Enrollment
| Data | Not Collected | Optional | Currently Used | Source | Purpose |
|---|---|---|---|---|---|
| Student School Enrollment | — | — | ✓ | Dream | To 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
| Data | Not Collected | Optional | Currently Used | Source | Purpose |
|---|---|---|---|---|---|
| Address | ✓ | — | — | ||
| Name | ✓ | — | — | ||
| ✓ | — | — | |||
| Phone | ✓ | — | — | ||
| Parent/Guardian ID Number | ✓ | — | — |
School Information
| Data | Not Collected | Optional | Currently Used | Source | Purpose |
|---|---|---|---|---|---|
| School District / Account | — | — | ✓ | Dream | Organizational location data to help students with their laptops & repairs |
| School Building | — | — | ✓ | Dream | Organizational location data to help with laptops, repairs, and shipping |
| Whitelisted IP Address | — | — | ✓ | Dream | No current use |
| Organizational Path | — | ✓ | ✓ | Dream & Google | Organizational data to help schools organize students |
Google Account Info
| Data | Not Collected | Optional | Currently Used | Source | Purpose |
|---|---|---|---|---|---|
| Google ID | — | — | ✓ | Sync Google account to Dream | |
| 2FA Enrollment | — | ✓ | — | No current use | |
| Google Mailbox Setup | — | ✓ | — | No current use | |
| Included in Global Address List | — | ✓ | — | No current use | |
| Last Google Sign-In | — | ✓ | — | No current use | |
| Google Account Creation Date | — | ✓ | — | No current use | |
| Google Account Last Updated Date | — | ✓ | — | No current use | |
| Google Account Deletion Date | — | ✓ | — | No 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.