Privacy Policy

1. Introduction & Our Commitment

Welcome to the Grado Pilot Program, an official partnership between Intelimina Systems, Inc. ("we," "us," "our") and the DepEd Schools Division of City of Baliwag ("SDO Baliwag"). We are deeply committed to protecting the privacy and security of the personal data of all participants, including students, parents, guardians, teachers, and school administrators.

This Privacy Policy explains how we collect, use, share, and protect personal and sensitive information in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations. This policy governs the data processed through the Grado School Management System platform ("Grado," "the platform") for the duration of this pilot program.

2. The Information We Collect

As a school management system, we process information that is necessary for the educational and administrative functions of the pilot schools, as directed by SDO Baliwag and its authorized school personnel. This includes:

• Student Information: Full name, Learner Reference Number (LRN), date of birth, grade level, section, attendance records, grades, and other academic data.

• Parent/Guardian Information: Full name, contact information (email address, mobile number), and relationship to the student.

• Teacher & Administrator Information: Full name, employee ID, contact information, and subjects taught or administrative role.

• Usage Information: We collect limited technical information when you access the Grado platform, such as login timestamps and actions taken within the system (e.g., posting an announcement, submitting a grade). This is strictly for security, system improvement, and audit purposes.

We strictly limit our data collection to what is essential for the platform's operation. We do not collect sensitive information beyond what is required for educational purposes (e.g., we do not collect biometric data, religious affiliation, or health information through the Grado platform itself).

3. How We Use Your Information

The data collected is used exclusively for the following purposes, as authorized by SDO Baliwag:

• To Operate and Maintain the Grado Platform: To facilitate student enrollment, manage class schedules, track attendance, record grades, and enable communication between the school, teachers, and parents.

• To Provide Support: To assist users with technical issues, answer questions, and provide training.

• To Ensure Security: To monitor for and prevent unauthorized access, maintain the security of our systems, and conduct security audits.

• To Improve the Service (Aggregated Data Only): To analyze system performance and usage trends to improve the platform's functionality. This analysis is only ever performed on anonymized and aggregated data. We will never analyze the personal information of an individual student or teacher for this purpose.

• To Fulfill Legal Obligations: To comply with our legal and regulatory requirements as mandated by Philippine law.

4. Data Sharing and Disclosure

Your personal information is not for sale. We will not sell, rent, or share any personal data with third parties for marketing or advertising purposes.

We only share information under the following limited and controlled circumstances:

• With Authorized School & Division Personnel: Your information is accessible to authorized users based on their roles (e.g., a teacher can only see data for their own students; a principal can see data for their school; authorized SDO officials can view consolidated reports).

• With Our Service Providers: We may engage trusted third-party service providers for essential services like cloud hosting (e.g., Amazon Web Services, Google Cloud). These providers are contractually bound to maintain the confidentiality and security of the data and are prohibited from using it for any other purpose.

• For Legal Reasons: We may disclose information if required by law, subpoena, or other legal processes, or if we have a good-faith belief that it is necessary to protect the rights, property, or safety of our users or the public.

5. Data Security

We take the security of your data very seriously. We implement a range of technical, administrative, and physical security measures to protect your information from unauthorized access, use, or disclosure, including:

• Data Encryption: All data is encrypted both in transit (when it travels over the internet) and at rest (when it is stored on our servers).

• Access Controls: We use strict, role-based access controls to ensure that users can only access the information relevant to their official duties.

• Regular Security Audits: We conduct regular security assessments and vulnerability scans to identify and address potential threats.

• Data Breach Protocol: In the unlikely event of a data breach, we will comply with all DPA notification requirements and inform affected parties and the National Privacy Commission in a timely manner.

6. Your Rights as a Data Subject

As a participant in this program, you have rights over your personal data as provided by the Data Privacy Act of 2012. These include:

• The Right to be Informed: You have the right to know how your data is being processed.

• The Right to Access: You have the right to request access to your personal information.

• The Right to Object: You have the right to object to the processing of your data.

• The Right to Rectification: You have the right to correct any inaccurate data.

• The Right to Erasure or Blocking: You have the right to have your data erased or blocked from our systems under specific circumstances.

To exercise these rights, please first contact your respective School Principal or the SDO Baliwag Data Protection Officer. We will work closely with them to address your request in accordance with the law.

7. Data Retention

We will retain the data collected during the pilot program only for as long as necessary to fulfill the purposes outlined in this policy, or as required by our agreement with SDO Baliwag and by Philippine law. Upon the conclusion of the pilot program or our agreement, all personally identifiable information will be securely deleted or returned to SDO Baliwag as per their instruction.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on this site and, where appropriate, through other communication channels.

9. Contact Us

For any questions about this policy, or any concerns about our use of your personal information, email us at info@intelimina.com.