Roles and Responsibilities
WayWink operates as a technology platform used by participating schools for school transportation management.
1.1 Participating Schools
The respective school determines and provides much of the information entered into WayWink, including information concerning:
- students;
- parents and guardians;
- drivers;
- school administrators;
- buses and other transit vehicles;
- transportation routes; and
- designated pickup and drop-off stops.
School administrators create and manage records for their respective school through the WayWink administrative dashboard.
The school is responsible for ensuring that personal data submitted to WayWink has been collected lawfully and that all notices, permissions, authorisations and parental or guardian consents required under applicable law have been obtained before such data is entered into or processed through WayWink.
1.2 Lansumtech
Lansumtech develops, operates, hosts, maintains and secures the WayWink platform and processes information as necessary to provide its functionality.
Depending upon the particular processing activity, Lansumtech may have responsibilities as a Data Fiduciary or may process personal data on behalf of a participating school. Each party is responsible for fulfilling the obligations applicable to it under Indian law.
Lansumtech does not independently collect Aadhaar information or driver background-verification records through WayWink.
Categories of Users
WayWink is designed primarily for the following categories of users:
School Administrators: Accounts are initially provisioned through Lansumtech's authorised Super Administrator arrangements. School administrators subsequently manage their school's transportation information and create or manage authorised parent and driver accounts.
Drivers: Drivers receive authorised credentials and use the WayWink mobile application to access transportation duties and provide location information during active trips.
Parents/Guardians: Parents or guardians receive authorised credentials to access transportation information associated with their linked child or children.
Students: Students are transportation beneficiaries recorded within the system. Students do not receive or operate WayWink user accounts.
Lansumtech Super Administrators: Limited authorised Lansumtech personnel may access administrative functionality where necessary to provision schools, operate the service, provide technical support, maintain security or fulfil lawful requests.
Access to information is restricted according to the role assigned to each authorised user.
Personal Data We Collect
The information processed through WayWink depends upon the user's role and the services used.
3.1 School Information
The Platform may process:
- school name;
- official email address;
- contact number;
- principal's name;
- school registration number; and
- official school address.
3.2 School Administrator Information
We may process:
- full name;
- mobile number;
- email address;
- emergency contact details;
- physical address;
- account credentials; and
- system-generated or subsequently customised passwords.
Passwords are intended to be stored using appropriate security protections rather than in readable plaintext form.
3.3 Bus and Transit Vehicle Information
WayWink may process:
- route or bus number;
- official vehicle registration/license plate number;
- passenger seating capacity;
- vehicle type; and
- operational characteristics such as AC, non-AC or mini-bus classification.
3.4 Driver Information
Driver profiles may contain:
- full name;
- profile photograph;
- mobile number;
- email address;
- driving licence number;
- driving licence expiry date;
- physical address; and
- account credentials.
WayWink does not collect or store Aadhaar information or driver background-verification documentation as part of the Platform. Responsibility for such records, where applicable, remains with the respective school authority.
3.5 Student Information
Because WayWink provides school transportation services, participating schools may enter:
- student's full name;
- roll number;
- grade;
- section;
- date of birth;
- gender;
- home address;
- assigned route;
- assigned transit stop; and
- transportation assignment information.
Students do not have login accounts.
3.6 Parent or Guardian Information
We may process:
- full name;
- email address;
- mobile number;
- emergency contact details;
- relationship with the student;
- physical address; and
- account credentials.
3.7 Location and Trip Information
During an active school transportation trip, WayWink may process information including:
- precise GPS coordinates;
- vehicle location;
- vehicle transit speed;
- location timestamps;
- route progress;
- pickup/drop information; and
- geofence-related events.
Location collection is used for the transportation functionality described in Section 5.
3.8 Device and Technical Information
When the Platform is used, certain technical information may be processed, including:
- device UUID or other applicable device identifiers;
- IMEI where technically available and lawfully accessible;
- device operating system and version;
- application version;
- technical logs;
- timestamps; and
- application crash reports.
We use such information primarily for application functionality, security, troubleshooting and technical maintenance.
Mobile Device Permissions
Depending upon the user's device, operating system and role, WayWink may request the following permissions.
Location
WayWink requests location permission where necessary for transportation tracking functionality. In particular, a driver's location may be processed while an authorised trip is active.
Camera
WayWink may request access to the device camera where an application feature requires the user to capture or upload an image, such as an authorised profile photograph.
Camera access is not intended to provide WayWink with unrestricted access to the user's camera.
Notifications
WayWink may request permission to send push notifications concerning transportation activities and other relevant service information.
Users may control certain device permissions through their Android or iOS operating-system settings. Disabling a permission may cause functionality dependent upon that permission to become unavailable.
Precise Location and School Bus Tracking
Location information is fundamental to certain WayWink transportation features.
During an active trip, location information generated through the driver's device may be used to:
- display the live location of the school bus;
- enable authorised parents and school administrators to track trip progress;
- calculate or display estimated arrival information;
- support student transportation attendance functionality;
- identify entry into or exit from configured geofence areas; and
- operate transportation and safety-related functionality.
WayWink is designed so that trip-related GPS tracking is associated with an active transportation trip rather than being used to continuously monitor a driver for unrelated purposes.
Parents may view the relevant transportation information made available to their account, subject to the permissions and relationships configured by their school.
Location information is not used for behavioural advertising, targeted advertising or the creation of advertising profiles.
How We Use Personal Data
Personal data processed through WayWink may be used to:
- create and administer authorised accounts;
- authenticate users;
- maintain role-based access;
- manage school transportation operations;
- maintain student-to-parent relationships;
- assign students to routes and stops;
- assign buses and drivers to routes;
- generate and operate transportation trips;
- provide live bus tracking;
- provide estimated arrival information;
- support transportation attendance;
- provide geofencing functionality;
- send operational and safety-related notifications;
- provide technical and customer support;
- diagnose crashes and technical errors;
- protect accounts and the Platform from unauthorised access;
- maintain records necessary for security and operational integrity;
- comply with applicable laws, lawful government requests or legal proceedings; and
- establish, exercise or defend legal claims where permitted by law.
WayWink does not currently use personal data for third-party advertising or behavioural advertising.
WayWink does not currently use artificial intelligence to process personal data or provide the functionality described in this Privacy Policy.
WayWink does not currently use user information for general advertising analytics.
Children's Personal Data
WayWink is used in connection with school transportation and therefore necessarily processes information relating to children.
However, students do not create or operate WayWink accounts.
Student information is entered and managed by authorised school personnel for school transportation purposes.
The respective school is responsible for obtaining verifiable consent from the parent or lawful guardian where required under applicable Indian law before children's personal data is submitted to or processed through WayWink.
Lansumtech expects participating schools to provide appropriate information to parents or guardians concerning the school's use of WayWink.
Children's information processed through WayWink is intended solely for legitimate school transportation and related operational purposes.
WayWink does not:
- sell children's personal data;
- use children's information for targeted advertising;
- undertake behavioural monitoring of children for advertising purposes; or
- create advertising profiles based on children's personal data.
A parent or guardian wishing to correct or delete information relating to their child should contact the respective school.
The school may then make the permitted changes through its administrative functionality or contact Lansumtech where assistance is required.
Data Storage and Transfers
WayWink's primary cloud infrastructure is hosted using Amazon Web Services in the Mumbai, India region.
Certain technology providers, including Google or Apple, may operate infrastructure in multiple jurisdictions. Consequently, limited information processed through their services may be handled according to their infrastructure arrangements and applicable privacy terms.
Where personal data is processed outside India, Lansumtech will take reasonable measures to ensure that such processing is consistent with applicable Indian legal requirements and any restrictions issued by competent authorities.
Data Retention
Lansumtech does not intend to retain identifiable personal data indefinitely.
Depending upon operational and legal requirements, records including:
- school records;
- student records;
- parent/guardian records;
- driver records;
- GPS and trip history;
- account information; and
- technical and security logs
may generally be retained for up to two (2) years where necessary for the purposes for which they were collected.
Information may be deleted earlier where it is no longer required or where an authorised deletion request is validly made.
Certain records may need to be retained for a longer period where required by applicable law, legal proceedings, fraud prevention, security investigations or other lawful requirements.
Information that has been irreversibly anonymised so that it can no longer identify an individual may be retained separately where permitted by law.
Access, Correction and Deletion
WayWink provides different procedures depending upon the relationship between the individual and the participating school.
Parents and Guardians
Parents and guardians cannot directly delete the school's underlying student or parent records from the Platform.
A parent or guardian who wishes to:
- correct personal information;
- update student information;
- request deletion of their information;
- request deletion of their child's information; or
- raise a concern regarding the school's processing of their information
should first contact the respective school.
The school can review the request and make appropriate changes or communicate with Lansumtech where platform-level assistance is necessary.
Drivers
Drivers should contact their respective school regarding correction or deletion of information maintained by the school.
Schools
Where a school wishes to terminate its use of WayWink or request deletion of school-level information that cannot be removed through its administrative dashboard, an authorised school representative should contact Lansumtech.
Requests may be sent to:
admin@lansumtech.comLansumtech may take reasonable steps to verify the identity and authority of the requesting person before carrying out a request.
Deletion requests remain subject to information that Lansumtech or the school is legally required or permitted to retain.
Rights Under Applicable Indian Data Protection Law
Subject to the DPDP Act and other applicable law, individuals may have rights concerning their personal data, including rights relating to:
- obtaining information about the processing of their personal data;
- correction of inaccurate or misleading personal data;
- completion or updating of personal data;
- erasure of personal data where applicable;
- withdrawal of consent where processing is based upon consent; and
- grievance redressal.
Requests relating to school-managed information should ordinarily be raised with the relevant school first because the school creates and manages the relevant student, parent and driver records.
Where the request concerns processing performed directly by Lansumtech, users may contact Lansumtech using the details provided below.
Withdrawal of consent does not affect processing lawfully undertaken before the withdrawal and may affect the availability of functionality that necessarily depends upon the relevant personal data.
Information Security
Lansumtech takes reasonable technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, loss or misuse.
Depending upon the relevant system and functionality, these measures may include:
- encrypted HTTPS/TLS communications;
- secure password storage mechanisms;
- authentication controls;
- role-based access control;
- separation of permissions between different user roles;
- restricted administrative access;
- secure AWS cloud infrastructure;
- logging and monitoring of relevant system activity;
- application and infrastructure security measures; and
- backup and recovery practices where appropriate.
Access to personal data by Lansumtech personnel is intended to be limited to authorised personnel who require such access for legitimate operational, security or support purposes.
No internet-connected information system can be guaranteed to be completely secure. Accordingly, while Lansumtech maintains reasonable safeguards, absolute security cannot be guaranteed.
Users are also responsible for protecting their account credentials and should not share their password with unauthorised persons.
Personal Data Breaches
If Lansumtech becomes aware of a personal data breach affecting information under its responsibility, it will investigate the incident and take reasonable measures to contain and remediate it.
Where notification is required under applicable Indian law, Lansumtech will provide the required information to affected individuals and/or the Data Protection Board of India or other competent authority, in the manner and within the period prescribed by applicable law.
Participating schools will be informed where their cooperation is reasonably required in relation to an incident affecting school-managed information.
Advertising, Analytics and Automated Decision-Making
WayWink currently:
- does not display third-party advertisements;
- does not sell personal data to advertisers;
- does not use personal data for behavioural advertising;
- does not use advertising analytics services; and
- does not use artificial intelligence for automated decisions concerning students, parents or drivers.
If WayWink introduces materially different processing practices in the future, this Privacy Policy will be updated and additional notice or consent will be obtained where required by applicable law.
Account and Platform Security Responsibilities
Users must keep their login credentials confidential.
Parents, drivers and school administrators should immediately notify the relevant school or Lansumtech if they believe that their WayWink account has been compromised.
Schools are responsible for managing the accounts and access permissions of their authorised personnel and for promptly disabling access where a user is no longer authorised to use the school's WayWink environment.
Lansumtech reserves the right to temporarily restrict access to an account where reasonably necessary to protect users, personal data or the security of the Platform.
Changes to This Privacy Policy
Lansumtech may update this Privacy Policy from time to time to reflect:
- changes to WayWink functionality;
- changes to our data practices;
- changes to third-party services;
- security requirements; or
- changes to applicable laws or regulatory requirements.
The latest version will identify its effective or last-updated date.
Where a change materially affects how personal data is processed, Lansumtech and/or the participating school will provide additional notice or obtain consent where required by applicable law.
Users are encouraged to review this Privacy Policy periodically.
Grievance Redressal
Individuals may raise privacy-related questions, complaints or grievances regarding WayWink using the contact information provided below.
Lansumtech intends to designate appropriate grievance contact information in accordance with applicable requirements.
- Grievance Officer
- To be appointed/updated
- Grievance Officer Email
- To be updated
Until those details are published, privacy-related communications may be sent to:
admin@lansumtech.comWhere a grievance concerns information collected and managed by a participating school, Lansumtech may coordinate with or direct the matter to the relevant school as appropriate.
Nothing in this section limits any right available to an individual under applicable Indian law.
Contact Us
Questions regarding this Privacy Policy, WayWink's privacy practices or personal data processed directly by Lansumtech may be directed to:
Lansumtech
Centurion Park Terrace Homes
Greater Noida (West)
Uttar Pradesh – 201306
India
- Privacy / Administrative Email
- admin@lansumtech.com
- Support Email
- lansumtech@gmail.com
- Website
- lansumtech.com
For information maintained by a participating school, parents, guardians and drivers are encouraged to contact the respective school in the first instance.