Student Data Processing Agreement (DPA)

Effective Date: June 27th, 2025

1. Purpose

This agreement governs how VideoLink, operated by Vitzo LLC, collects, uses, and protects student data when educational institutions use the platform. It is intended to ensure compliance with the Children's Online Privacy Protection Act (COPPA) and the Family Educational Rights and Privacy Act (FERPA).

2. Definitions

• "Student Data" means any personal information that can identify a student, such as name and email address.
• "School" refers to the educational institution agreeing to this DPA.
• "VideoLink" or "Platform" refers to the educational service provided by Vitzo LLC.

3. Data Collected

With school authorization, VideoLink may collect and store the following limited data solely for educational use:

• Student name
• Student email address

We do not collect message content, passwords, browsing history, or other unnecessary personal data.

If schools use Google login for authentication, we collect only basic account information (Google ID, name, and email address) necessary for platform access. No other personal data or private content from student accounts is accessed.

4. Purpose of Use

Student data is used only for legitimate educational purposes, including:

• Delivering shared video links and access notices
• Sending platform notifications
• Providing usage insights to educators
• Supporting educators or administrators with relevant communications

Data is never used for advertising profiling or commercial marketing.

5. Security and Privacy

VideoLink is committed to safeguarding student privacy. We:

• Encrypt student data in transit and at rest
• Limit access to authorized personnel only
• Do not sell, rent, or share data with third parties for commercial purposes
• Automatically delete or anonymize inactive accounts after a reasonable period

6. Data Retention and Deletion

• Student data is retained only for as long as needed to support educational use.
• Schools, parents, or legal guardians may request deletion at any time by contacting [email protected].
• Inactive accounts may be automatically anonymized or deleted after prolonged non-use.

7. Subprocessors

We may engage subprocessors for services such as hosting, content delivery, authentication, and analytics. These include (but are not limited to) AWS, Cloudflare, and Google Analytics. All subprocessors are contractually required to protect student data in a manner consistent with this agreement and applicable privacy laws. A current list is available upon request.

8. FERPA and COPPA Compliance

By using VideoLink, the school confirms it is authorized to act on behalf of parents and provide educational consent for the collection and use of student data in compliance with COPPA.

The school also designates Vitzo LLC as a "school official" under FERPA, with legitimate educational interest in processing student data.

Parents may review, access, or request deletion of their child's data by contacting the school or VideoLink at [email protected].

We recommend that schools:

• Keep a copy of this DPA for their records
• Inform parents that the school is providing consent on their behalf
• Optionally submit a digital acknowledgment during onboarding

Where required under local law (e.g., GDPR in the EU), schools may enter into a separate data processing addendum or designate a legal basis for processing (e.g., public interest or legitimate interest). Contact us for assistance.

9. Breach Notification

In the event of a data breach involving student data, VideoLink will notify the affected school within 72 hours and provide details on:

• The nature of the breach
• Types of data affected
• Mitigation measures taken

10. Term and Termination

This agreement remains effective for the duration of the school’s use of VideoLink. It may be terminated by written notice. Upon termination, VideoLink will delete or anonymize all associated student data.

11. Governing Law

This agreement is governed by the laws of the State of Wyoming and applicable United States federal education privacy laws.

Questions or Concerns

For inquiries about this agreement or our student data practices, contact:

VideoLink (Operated by Vitzo LLC)
Email: [email protected]
Website: https://video.link