COPPA Privacy Notice

LAST UPDATED: 04th Nov 2022 Spektra Systems is committed to protecting the privacy of children who use our Platforms-CloudLabs & CloudEvents for learning purpose. This Children’s Online Privacy Policy (COPPA) explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“child” or “children”), and uses terms that are defined in our general Privacy Policy. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our practices in the United States regarding children’s personal information. As per COPPA, Spektra Systems (“Company”) are required to inform parents and legal guardians about our practices for Collecting, using, and disclosing personal data from children under the age of 13. This COPPA Notice only applies to the data collection practices of Spektra Systems “CloudLabs” & “CloudEvents” (collectively referred herein as “Services”) attributes directed to children under the age of 13 and supplements the Privacy Policy. Data privacy Terms not defined in this COPPA Notice are otherwise defined in our Privacy Policy. We do encourage you to review our FERPA Policy in conjunction with this. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection. CloudLabs is an Online learning platform and does not encourage use by Children under 13 years without Parental notice, Consent and supervision.

Who we are and What we do

CloudLabs platform helps to run hands-on-labs, test drives & POCs for various scenarios at large scale. CloudLabs is designed for Organizations and educational institutes of all sizes to offer an impactful learning experience with zero to minimal management overhead. Following are the handful of services that CloudLabs offer to its partners and users. CloudEvents (Hackathons): Organize impactful technology events with live progress tracking HOL Platform: Build, deliver and consume custom technology labs at scale. Users can build their lab desired configuration once and deploy thousands of times with a few clicks. Trainings & Workshops: Leverage our pre-built hands-on labs or bring your custom labs for trainings and workshops. Demonstrations: Showcase tech product with impactful scenarios. Events Support: Managed Support for in-person and virtual events for hands-on labs. Cloud Orchestrator: Automate your cloud environments provisioning and lifecycle. 24*7 Live Support: Instant support for any technical and non-tech problems.

Pre-Built Labs

Virtual Delivery Experience: CloudLabs is optimized to support virtual labs deliveries in today’s remote world, with features such as the ability to shadow cloud and VM environments, providing watch over the shoulder experience for instructors. Skill Validation: Our latest feature addition helps you validate if learners have completed the labs correctly to ensure skill validation and quality assessments.

How We Protect Children’s Privacy?

We take special precautions to protect the privacy of children using our platforms. If you have a question about whether a particular Service is directed to children, please contact us by sending an email @privacy@spektrasystems.com or write to us Attention: Privacy. Spektra Systems LLC 8201 164TH AVE NE, Suite 200 Redmond WA 98052-7615, USA.

REGISTRATION

A.  School Accounts For children accessing our services via Schools (Educator/Educational Agencies) account with whom Spektra systems has a Contract, it is the responsibility of the Educator to obtain Parental consent to use our services. The Educator shall guide the child on creating account and using our services. CloudLabs does not encourage children to share their data publicly. Teachers and the school control the visibility of the data. B.  Individual Accounts In other Cases, during the registration process, we may ask the child to provide certain information for age Validation purpose, including a parent or guardian’s email address, Date of Birth, the child’s first name and last name (optional), Country and School Name. If the child is under 13 years, signup is restricted unless consent is received from the parent/guardian. By providing consent, the parents agree to our Terms of Use and Privacy Policy. This shall be communicated to the parents in the email notification that they receive from us for Parental Consent. Please note that it is up to the user to choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary to participate in an online activity. Collection of parent email address: Consistent with the requirements of COPPA, or in any instance where we ask for age and determine the user is age 13 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at privacy@spektrasystems.com . We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.

ABOUT VERIFIABLE PARENTAL CONSENT:

Email Consent. In the event we wish to collect personal information from a child under 13, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity. Teacher consent in lieu of a parent. With regard to school-based activities, COPPA allows teachers and school administrators to act instead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA Privacy Notice Section.

WHAT DATA WE COLLECT FROM CHILDREN?

We only collect the minimal amount of personal data necessary for children to use our Services. Specifically, first name, last name (optional), email address, Country, and date of birth during initial registration. Date of Birth is collected only to determine the age of signing user and if he/she is determined to be under 13, parent’s email address is collected to obtain Parental Consent. We only use username (created by the child in the guidance of parents) and email address to track a child’s progress in our courses or to reset passwords; we will not contact a child using his or her email address or username. We may ask for certain information that is not personally identifiable like, school name, school address, school city/district, or school grade, in connection with your child’s use of our services and to help us improve the quality of the same; we do not associate this with the child’s name or other personal information and we use it only to compile aggregate and de-identified information about participants in our courses .We may also collect the IP address from which the child accesses the Services in connection with the child’s use of the Services. Parents   may    ask    us    to    stop   collecting   personal   information    from   their    child   by    emailing    us at Privacy@spektrasystems.com, however, in such cases the child will not be able to take or complete our courses. If a parent directs us to stop collecting and using a child’s personal information, we must disable his or her use of our courses to ensure that no information is collected. We use cookies, and other similar technology, to collect information when children use our Service such as the amount of time children spend on learning activities available through the Services, the actions performed by children such as logging in and out, and the pages children visit. Please visit our detailed version of Cookie Policy. Data Collected will not be:

1. at any time, utilized to target advertising
2. used to create advertising profiles on any users
3. sold, traded, or rented;

Children PII will not be shared or otherwise transferred to any third parties for advertising or marketing purposes. If you are a user of CloudLabs, please refer to “Data Collection section” by CloudLabs under our FERPA Notice. If you are a user of CloudEvents, wishing to participate in Hackathons organized by our partners, please refer to “Data Collection section” by CloudEvents under our FERPA Notice.

Chat

Chat feature is designed into our lab environments based on the agreements that we may enter with schools. Only the instructors/trainers approved by the Educator can create groups to interact with the students. Students are not allowed directly to create a group and discuss with fellow members. The trainers/instructors are selected by schools itself. Our Services does not engage in the selection of Instructors/Trainers for any lab environments. We strongly encourage children never to provide personal information about themselves or any third party and raise concern of any inappropriate content or abuse directly to privacy@spektrasystems.com. We also recommend that parents carefully supervise their children when the children participate in such activities.

THIRD PARTIES

Spektra Systems may engage third party service providers on behalf of us to improve the quality of our services and for internal operations. However, our services do not share any personal information of children data or its users with third party service providers. In the event we do so, it will be notified to the concerned for obtaining consent prior to disclosure. Please refer to “third party service providers” under FERPA Rights.

YOUR RIGHTS TO REVIEW, DELETE, AND CONTROL OUR USE OF CHILDREN’S PERSONAL INFORMATION

Parents have a right to review the information we have collected about their children and students, respectively, and   to   delete   it,   and   to   tell us   to   stop   using   it.   To   exercise these rights,   you   may   contact   us at privacy@spektrasystems.com. You will be required to authenticate yourself as the child’s parent to receive information about that child. All requests will be responded within a time frame of 72 hours. We encourage you to review our Data Retention policy under FERPA and Retention of Personal Information under our Privacy Policy.

DISCLOSURE OF CHILDREN INFORMATION

Please refer to “When We May Disclose Your Personal Information” under our FERPA Notice.

CHANGES TO THIS COPPA NOTICE

We may revise our Privacy Policy from time to time. You can see when the last update was by looking at the “Last updated” date at the top of this page. We won’t reduce your rights under this Privacy Policy without your explicit consent. If we make any significant changes, we’ll provide prominent notice by posting a notice on the Service and notifying you by email (30 days in advance using the email address you provided), so you can review and make sure you know about them. We encourage you to review this Notice from time to time, to stay informed about our collection, use, and disclosure of personal information through the Services Websites. If you don’t agree with any changes to the Privacy Policy, you may terminate your account. By continuing to use the Services after the revised Privacy Policy has become effective, you acknowledge that you accept and agree to the current version of the Privacy Policy.

CONTACTING SPEKTRA SYSTEMS

In some scenarios, you may become aware of a breach and may wish to notify Spektra Systems. The current protocol is to notify Spektra Systems Support, which will then interface with engineering teams for more information. In this scenario, Spektra Systems engineering teams are similarly committed to providing the information customers need, through their support contact, in a timely fashion. Customers need to reach out to Spektra Systems on privacy@spektrasystems.com for any scenario that constitutes a breach as per this policy. If you believe that Our services have not adhered to this Policy, please contact us electronically at the email address below and we will use commercially reasonable efforts to promptly determine and remedy the problem. Spektra Systems LLC 8201 164TH AVE NE, Suite 200 Redmond WA 98052-7615, USA Phone: 1-844-773-5872 Email: legal@spektrasystems.com