Privacy Policy
Effective Date: 7 September 2026
Last Updated: 7 September 2026
SkuulNet respects the privacy of students, parents and guardians, teachers, school administrators, staff and other Users of the Platform.
This Privacy Policy explains how SkuulNet collects, uses, stores, protects and processes personal information when providing its school management services.
Because SkuulNet is primarily designed for schools in Vanuatu, this Policy is intended to reflect applicable Vanuatu privacy and data-protection requirements, including the Data Protection and Privacy Act No. 13 of 2024.
Privacy at a Glance
- We do not sell student personal information.
- We do not use student information for targeted advertising.
- We do not knowingly build advertising profiles of students.
- Schools generally determine why and how school information is collected and used.
- SkuulNet generally processes school information on behalf of the school.
- We use reasonable measures designed to protect personal information.
- Individuals may have privacy rights under applicable law.
1. Who is Responsible for Your Information?
For information entered into SkuulNet by a school, the school will generally determine why and how that information is collected and used.
The School is generally the Data Controller, while SkuulNet acts as a Data Processor/service provider processing information on the school's behalf.
For information SkuulNet collects directly for its own business purposes, such as information from a school administrator contacting SkuulNet, SkuulNet may act as the data controller.
2. Information We May Collect
Depending on how SkuulNet is configured and used, we may process:
Student Information
- Full name and student identification number
- Date of birth and gender
- Class, year level and enrolment information
- Attendance and academic results
- Examination information
- Disciplinary or school records
- Parent or guardian information
- School-related communications
- Other information entered by the school
Parent and Guardian Information
- Name
- Telephone number
- Email and contact information
- Relationship to the student
- Information provided through SkuulNet
Teacher and Staff Information
- Name and employee or staff identification number
- Contact information
- Role or position
- Subjects or classes
- Attendance
- Professional or employment-related information entered by the school
Technical Information
- IP address
- Browser, device and operating system
- Login information and access times
- Pages or functions accessed
- Security logs
- Error and diagnostic information
3. How We Use Personal Information
We may use personal information to:
- Provide SkuulNet's school management services
- Create and manage accounts and school records
- Provide academic and administrative functionality
- Facilitate authorised communications
- Provide technical support
- Maintain security and prevent unauthorised access
- Troubleshoot problems and maintain backups
- Improve the Platform
- Comply with legal obligations
- Protect Users and SkuulNet
We will not use student information for unrelated purposes without an appropriate lawful basis or authorisation.
4. Student Information
SkuulNet recognises that education platforms process information relating to children and that such information requires particular care.
Schools are responsible for ensuring that student information is collected and provided to SkuulNet lawfully.
SkuulNet will process student information for legitimate purposes associated with the school's use of the Platform, subject to applicable law and the school's instructions.
SkuulNet does not sell student personal information.
SkuulNet does not use student information for targeted advertising.
SkuulNet does not knowingly build advertising profiles of students.
5. Sensitive Personal Information
Certain information may receive additional protection under applicable law, including information relating to health, religious beliefs, political opinions, ethnicity, sexual life or other recognised sensitive or special personal data.
Schools should only enter sensitive information into SkuulNet where there is an appropriate educational, administrative or legal reason and the necessary authority.
Vanuatu's 2024 Data Protection and Privacy Act identifies special categories of personal data and provides specific rules concerning their processing.
6. Legal Basis for Processing
Depending on the circumstances, information may be processed because:
- It is necessary to provide the contracted service
- The school has a lawful basis for processing
- Consent has been provided where required
- Processing is necessary to comply with a legal obligation
- Processing protects an individual's vital interests
- Another lawful basis under applicable Vanuatu law applies
7. Information Sharing
SkuulNet may provide access to personal information to:
- Authorised school administrators
- Teachers and staff who require access for their duties
- Authorised students, parents or guardians
- Hosting and infrastructure providers
- Technical, communication and cybersecurity providers
- Payment providers where applicable
- Professional advisers
- Government authorities where required by law
We do not sell personal information to advertisers or data brokers.
Third-party providers should only receive information reasonably necessary for the service they provide and may be subject to confidentiality and data-protection obligations.
8. International and Cross-Border Data Transfers
Some SkuulNet infrastructure or third-party providers may be located outside Vanuatu.
Where personal information is transferred outside Vanuatu, SkuulNet will take reasonable steps to ensure that the transfer complies with applicable Vanuatu data-protection requirements.
Where required, SkuulNet will seek to use appropriate contractual, technical or organisational safeguards.
9. Data Security
SkuulNet uses reasonable security measures designed to protect personal information.
- Encrypted connections
- Authentication and access controls
- Password protection
- Security monitoring and logging
- Backups
- Restricted administrative access
- Security updates
No online platform can guarantee that information will always remain completely secure.
10. Data Retention
We retain personal information for as long as reasonably necessary to:
- Provide the Service
- Maintain school records
- Comply with legal requirements
- Maintain financial and business records
- Resolve disputes
- Maintain security
- Protect legitimate interests
Retention periods may vary depending on the information, purpose, school requirements and applicable law.
When information is no longer required, SkuulNet will take reasonable steps to delete, anonymise or securely dispose of it, subject to legal and operational requirements.
11. Access to Personal Information
Individuals may have rights under applicable law to request information about personal data held about them.
Depending on the circumstances, Users may request:
- Access to personal information
- Correction of inaccurate information
- Deletion or erasure of information
- Restriction of processing
- Objection to certain processing
- Other rights provided by applicable law
Vanuatu's 2024 Act provides data-subject rights relating to access, restriction, rectification, erasure and objection.
How to Make a Privacy Request
Privacy questions and data requests may be made using the contact information in Section 19.
Where the information belongs to a student's school record, the request may need to be made through the relevant school because the school generally controls the underlying record.
We may verify the identity and authority of a person making a request before providing access or changing information.
12. Children's Privacy
SkuulNet is an education platform and may process information relating to children. We recognise that such information requires particular care and appropriate safeguards.
We do not require children to provide personal information for advertising purposes and do not use student information for targeted advertising.
Schools and authorised adults are responsible for appropriately creating and managing student accounts and information.
Where parental or guardian consent is required by law, the school is responsible for obtaining and maintaining that consent unless otherwise agreed with SkuulNet.
13. Cookies and Similar Technologies
SkuulNet may use cookies and similar technologies necessary to:
- Maintain login sessions
- Remember preferences
- Improve security
- Monitor system performance
- Understand Platform usage
Non-essential cookies, where used, will be handled in accordance with applicable requirements.
14. Communications
SkuulNet may send service-related communications such as:
- Account notifications
- Security alerts
- System updates
- Password-reset messages
- Maintenance notices
- Important administrative information
These communications are necessary for operation of the Service and are not marketing communications.
15. Data Breaches and Security Incidents
If SkuulNet becomes aware of a security incident involving personal information, we will investigate and take reasonable steps to contain, mitigate and remediate the incident.
Where applicable law requires notification to affected schools, individuals or authorities, SkuulNet will make such notifications within the applicable timeframe.
Vanuatu's Digital Transformation Act No. 42 of 2025 establishes cybersecurity-related responsibilities and provides for reporting of cyber incidents in certain circumstances.
16. School Responsibilities
Schools using SkuulNet are responsible for:
- Ensuring information is collected lawfully
- Informing students, parents, guardians and staff about applicable privacy practices
- Obtaining consent where required
- Maintaining appropriate user permissions
- Ensuring staff only access information necessary for their roles
- Protecting administrator credentials
- Complying with applicable education and privacy requirements
Schools should also ensure information provided to SkuulNet is accurate, appropriate and relevant to the purpose for which it is collected.
SkuulNet provides technology infrastructure but does not replace the school's legal or administrative responsibilities.
17. Third-Party Services
SkuulNet may use third-party providers for hosting, communications, security, backups, analytics and other infrastructure.
We seek to ensure providers receive only information reasonably necessary for their services and are subject to appropriate confidentiality and data-protection obligations.
SkuulNet does not authorise third-party providers to sell student personal information or use it for targeted advertising on SkuulNet's behalf.
18. Changes to this Privacy Policy
We may update this Privacy Policy from time to time.
When significant changes are made, we will update the effective date and last updated date and, where appropriate, provide notice through the Platform.
The current version will always be the version published through SkuulNet. Users should periodically review this Policy for updates.
19. Contact Us
For privacy questions, data requests or concerns regarding the handling of personal information, contact:
SkuulNet
Republic of Vanuatu
Email:
360vanuatu@gmail.com
Website:
skuulnet.com
If your request relates to a student's school record, we may direct you to the relevant school where appropriate.