# Privacy Policy **Date of Last Revision: April 4, 2024** --- ## About Code.org Code.org® is a US-based charitable nonprofit dedicated to expanding access to computer science in schools and increasing participation by young women and students from other underrepresented groups. Our vision is that every student in every school has the opportunity to learn computer science. Your privacy is important to us. We want to be transparent about the personal data we collect, why we collect it, and what we do with it. Moreover, we want you to know your rights regarding your personal data. We recommend that you read this Privacy Policy carefully before accessing or using the Services. If you have any questions about this Privacy Policy, you can email us at [privacy@code.org](mailto:privacy@code.org). --- ## Code.org Privacy Principles Our Privacy Policy is fueled by our commitment to the following Privacy Principles: We are committed to creating a safe and secure environment for learners of all ages and other visitors on our websites located at https://code.org, https://studio.code.org, https://hourofcode.com, https://curriculum.code.org, https://advocacy.code.org, https://k12cs.org, https://codeprojects.org, and any other websites or online services (collectively, our "Services") that link to this Privacy Policy. Visitors and users of the Services and participants in our education programs are referred to in this Privacy Policy individually as "User" (or "you" depending on the context) and collectively as "Users." 1. We're deeply committed to creating a safe and secure learning environment for our students and teachers. We take the protection of this information seriously. 2. We do not require you to provide any Personal Information in order to try our courses, most of which are accessible without a User account (only your IP address is collected). However, learning progress won't be saved without creating an account. 3. The only reason we collect any data from Students or Teachers is to better succeed at our mission of providing high-quality computer science education for every student in every school. 4. We do not sell your Personal Information or exploit it for financial gain. We do not sell ads. We are a charitable nonprofit and almost all our revenue comes from philanthropic gifts and donations. We established ourselves as a nonprofit so our mission and your trust will not be in conflict with a for-profit motive. 5. Any Student academic data we provide to third-party evaluators for the purpose of evaluating our courses in meeting our mission will be de-identified (per standard industry practice). 6. We strive to provide you with access to and control over the information you give us (as detailed below), and we use physical, administrative, and technical safeguards designed to reasonably protect your information. 7. When Student Records are provided to Code.org by a school or school district, Code.org agrees to retain such information as directed by the school or school district. 8. We hold our partners and service providers to privacy and security practices no less stringent than our own. Any User that creates a student account is referred to as "Student" even if they are using the Code.org Services outside of a school setting. Similarly, any User that creates a teacher account is referred to as "Teacher." As a not-for-profit organization, we use the data we collect only insofar as it helps our mission of providing a high-quality computer science education for every student in every school. We established ourselves as a not-for-profit organization so that a for-profit motive will not interfere with our mission of providing a trusted educational resource. Our Privacy Policy describes what information we collect, how we use it, when we may share it, how we protect it, and your choices and rights. Your use of the Services and any information you provide on the Services are subject to the terms of this Privacy Policy, which is incorporated into and subject to our Terms of Service. By visiting or using our Services, you expressly consent to the information handling practices described in this Privacy Policy. In the event this Privacy Policy is translated into another language resulting in any potential conflict or ambiguity, the official version of the Privacy Policy shall remain the English version. Where we have entered into separate agreements with local education authorities or similar entities that supplement our Terms of Service for the processing of Student Records (as defined in the School Users and Student Records section below), such as our Student Data Privacy Addendum, the processing terms of those agreements may also apply. Code.org is a signatory to the Student Privacy Pledge, which contains a set of principles intended to safeguard student privacy, including responsible stewardship, protection, and transparent handling of student data. --- ## Quick Reference YOU CAN USE THE LINKS BELOW TO QUICKLY FIND INFORMATION IN OUR PRIVACY POLICY - [How We Collect and Use Information](#how-we-collect-and-use-information) - [How We Share or Transfer Information](#how-we-share-or-transfer-information) - [How We Protect Information](#how-we-protect-information) - [Your Choices - How to Access, Correct, Update, or Delete Your Information](#your-choices---how-to-access-correct-update-or-delete-your-information) - [School Users and Student Records](#school-users-and-student-records) - [Children's Privacy Notice](#childrens-privacy-notice) - [Links to Other Sites and Services](#links-to-other-sites-and-services) - [We Do Not Allow Advertising on Our Services](#we-do-not-allow-advertising-on-our-services) - [International Users](#international-users) - [Rights Under the General Data Protection Regulation (GDPR)](#rights-under-the-general-data-protection-regulation-gdpr) - [Changes and Updates to Our Privacy Policy](#changes-and-updates-to-our-privacy-policy) - [Contacting Code.org](#contacting-codeorg) --- ## How We Collect and Use Information The sections below describe the ways Code.org collects and uses personal data, which refers to any information that Code.org can use to reasonably identify a User as an individual (directly or indirectly), as well as information that is or can be reasonably linked (directly or indirectly) to a User or a User's device. This includes things like name, display name, email address, school name and address, telephone number, etc., provided by Users ("Personal Information"), persistent cookies or IP addresses automatically collected ("Persistent Identifiers"), as well as some of the non-Personal Information and technical information (described below) we collect that is associated with a User. We generally collect personal data in three ways: (1) information a User voluntarily provides to us by using the Services, (2) information we automatically collect as a User uses the Services, and (3) information from third parties. The types and amounts of personal data collected vary depending on whether the User is a Student, Teacher, parent or other visitor, and on how they use the Services, but can be generally categorized as: - **(a)** Account registration data (such as username, password, email address) - **(b)** Demographic data (such as age, gender, race) - **(c)** Technical data (such as browser or device, IP address, login times) - **(d)** User uploaded data (such as images and sounds) - **(e)** User response or feedback data (such as survey responses and notes to and from Teachers) - **(f)** Platform usage data (such as progress data, projects created) - **(g)** Contact data for non-curriculum processes (such as email addresses for educators, parents, and others who wish to receive newsletters and other updates) We generally use personal data to (1) provide our Services, (2) personalize User experiences, (3) communicate with Users or others (such as donors or educators), (4) provide or facilitate professional development for CS teachers, (5) understand, improve, develop, and protect our Services, and (6) for legal, compliance, and safety reasons. Our goal is to minimize the personal data we collect. We do not require Users to create a Code.org account or otherwise provide Personal Information in order to participate in the Hour of Code tutorials or to try our courses. However, we cannot save a Student's learning progress or a Teacher's class records unless a User creates a Code.org account. ### Code.org Student and Teacher Accounts The following table describes the data that Code.org collects and stores if a User creates a Code.org Student or Teacher account for use with Code.org courses. #### Student Account Data | DATA STORED BY CODE.ORG IF A USER CREATES A CODE.ORG STUDENT ACCOUNT | HOW AND WHEN IS THE DATA COLLECTED? | HOW THIS DATA IS USED | | --- | --- | --- | | Display Name (e.g., "Cool Coder" or "John") and username (e.g., "coolcoder7") | Required by User (or their Teacher) on account creation | Display name is used to provide Students a welcoming login and to identify the Student in the Teacher's roster view of student progress. Although not required, this may include - at the teacher's or student's option - student first and last name or initials. Usernames are generated based on the initial display name and can be used along with a password to sign into an account. | | Account passwords | Required by User (or their Teacher) on account creation. | Passwords are established by the User and can be updated through the User's account settings or by a Teacher that manages a section in which the Student is enrolled. They are used for User authentication at sign-in. | | Secret words/pictures | System generated by Teacher when adding Student to section (if choosing not to use Student accounts with passwords). | Secret words or pictures are system generated, but can be reset by the Teacher. They are used for User authentication at sign-in. | | Age (Not birthdate) | Required by User (or their Teacher) on account creation or first sign in before using the site. | This data is used to understand the developmental stage of Students in order to offer an age-appropriate experience for each Student. We also use this field to ensure we don't allow Students under age 13 to access age-restricted features. We store ages (e.g., 16), as opposed to birth dates (e.g., Feb 13, 2001). | | State (in US Only) | Required by User on account creation or first sign in. | This data is used to identify the state in which a Student resides in order to apply state-specific laws (where applicable) and to allow aggregate analyses. | | One-way hash of student email address | Email address is required (but not stored) on account creation if a Student creates an account or if a Teacher creates the student account via a third-party authentication service or LMS provider, or the Student later adds a personal login to a Teacher-created account. Email address is not required if an account is created by a Teacher using a picture or secret word login for the section, though it can be optionally added by the Student later. | Where a Student creates a personal login, the Student's email address is only used for the purposes of login. It is NOT stored by Code.org in a retrievable format. To protect Student privacy, we only store a one-way hash of the email address. We do not have any way of sending email to Students or retrieving their actual email addresses from their account. | | Parent or guardian email address | Can be optionally provided by a parent to receive updates or create a login for their child at home. In some jurisdictions, we may require a Student under 13 to provide a parent or guardian email address for the purpose of obtaining consent. | Parents or guardians can choose to link their email address to their Student's account to receive updates from Code.org. In some jurisdictions, we may require a parent or guardian email address for the purpose of consenting to the creation of a Student Code.org account for a Student under the age of 13. The Parent email address can also be used for password recovery and to request support. | | Account Identifiers | System generated (separate identifiers may be provided by authentication services). This is NOT a student number assigned by a school. | These identifiers are used to maintain and operationalize accounts. | | Login time, IP address, and other technical data | Automatically collected as the Services are used. | This data helps Code.org troubleshoot any problems Users experience. It also helps Code.org understand usage patterns, ensure the service can support all Users, and enable Services updates with minimal service disruption. | | Gender | Optionally provided by the Student or their Teacher. | This information is only used in aggregate to measure gender distribution and how Students respond to different computer science challenges, or track our aggregate progress towards reducing the gender gap in computer science. | | Race | Optionally provided by the Student (only requested from Students 13 and over and only if their IP address is in the US). | Students aged 13 and over have an option to indicate their race. For Students under age 13 we do not ask individual race, but we ask the Teacher to optionally estimate the racial distribution of the entire classroom. This information is only used in aggregate. | | Progress in the course | Collected as a Student works through a tutorial or course progression. | This information is displayed to Students and their Teachers to see their progress in a course, to see the code they've created, and to identify topics they need help with. It also lets Students pick up where they left off. In de-identified or aggregate form, it also helps Code.org improve course effectiveness. | | Student projects - apps, animations, stories, or code-art | Collected as a Student creates such projects. | The code and any associated data for these apps are stored by Code.org so Students can retrieve their projects each time they log in. When Students work in the context of a classroom, their Teacher also has access to view the projects. Student projects each have a custom URL that Students can use to share with others. | | Student-uploaded images, sounds, or videos | Collected if a Student chooses to upload custom files. | Only available to Students age 13 and older, or Students under 13 who are in a Teacher's class section (for grades 6+ tools: App Lab, Game Lab, and Web Lab). These files are not used by Code.org for any purpose other than within these projects. | | Student Free Text Entries, which could include personal data | Collected if users enter data in free text fields, such as a response to a survey question or an AI tutor query. | In some cases, students may be able to enter free text data in various fields, which could include personal data despite warnings/instructions not to include such data. The free text fields may be processed and stored as part of the Code.org functionality. | | Data collected by Student-created apps | Collected if users of a code project created by the Student choose to enter data into the app. | Students may use Code.org to create their own apps. If a Student creates an app that collects and stores data, all data entered by Users of the app may be accessed and possibly shared publicly by the app author. Before using a Student-created app that collects data, Users are shown a clear warning that any data they enter may be shared publicly. | | Written comments in response to curricular/educational prompts | Collected if a Student chooses to enter text in response to the prompts. | Answers are shared with any Teacher with whom the Student is affiliated on Code.org and are used by Code.org in de-identified form to improve the curriculum. | | Student-provided responses to surveys | Collected if a Student chooses to fill out a survey offered inside the courses. | We may ask for responses to attitudinal questions to assist the Teacher in understanding their classroom's reaction to learning computer science and, in de-identified or aggregate form, to help Code.org improve our curriculum. Students are informed that answers to attitudinal questions are shared with the Teacher anonymously. | #### Teacher Account Data *A Teacher account on Code.org has all the functionality of a Student account, and as a result the data collected and stored for a Teacher account is a superset of the data stored for a Student account.* | ADDITIONAL DATA STORED BY CODE.ORG IF A USER CREATES A CODE.ORG TEACHER ACCOUNT | HOW AND WHEN IS THE DATA COLLECTED? | HOW THIS DATA IS USED | | --- | --- | --- | | Email address | Email address is required at account creation (or when switching from a Student account to a Teacher account). | Email addresses are used to send emails to the Teacher with updates about their classroom or Student progress, send notices when new coursework is available, and provide updates on curriculum, tools, professional learning opportunities, etc. Teachers can choose at account creation whether to receive non-transactional emails. | | First and Last Name | Collected at account creation. | Teacher names are used to customize communications and streamline processes such as enrolling in professional learning. | | District and school name and/or school type and/or school address | Optionally provided by the Teacher at account creation or after creating an account. | At the Teacher's discretion, we will list their school in the Code.org map and database of schools that teach computer science courses. Code.org or our professional development partners may also use this information to reach out to the Teacher's school or district. | | Teacher's primary role, grades taught, and subjects of interest | Collected at account creation. | This data is used to better understand how teachers in different roles use Code.org and provide potential recommendations and tips. | | Verified Teacher Identification Information | Optionally provided by the Teacher when seeking "verified teacher" status. | At the Teacher's discretion, they may provide a copy of an identification to our support desk as part of demonstrating their teacher status. We recommend redacting data beyond name, photo, and issuing authority. All such images are deleted after the verification is complete. | | Student section data | Collected if a Teacher decides to create a section on Code.org to manage their Students. | The Teacher may create accounts for their students and organize them into sections. The Teacher may assign each section a display name, a course assignment, and grade level. | | Survey and demographic data | Collected if a Teacher chooses to optionally fill out a survey. | For the purposes of evaluating our own work and improving our education results, Code.org regularly sends surveys to Teachers. These surveys are completely optional. Any survey data shared with external parties is de-identified and aggregated. | | Attendance at professional learning workshops | Collected when a Teacher attends a workshop. | Attendance data may be shared with parties involved in the Teacher's professional learning, such as the facilitator or school district. In some cases, the school district may use workshop attendance data to compensate Teachers. | | Progress, answers, documents, projects, and peer reviews for online professional learning | Collected as a teacher interacts with our online professional learning tools. | Progress and answers in online professional learning courses are stored in their Teacher account to allow Teachers to pick up where they left off. Includes lesson plans, documents, projects, and peer feedback. | | Comment feedback provided to students | Collected if a Teacher decides to give written comments to their Students on their work. | Though a Student will only see the most recently provided comment on a given level, we store all the previously shared comments as part of the Teacher's account in case the Teacher or school needs to access them later. | Teachers can create accounts on behalf of Students. When registering an account for a Student who is under the age of 13, the Teacher represents and warrants that they or the educational organization they work for has proper permission to register the Student for a Code.org account, and that they or the educational organization has obtained the necessary parental consent for collection of the Student's Personal Information for the use and benefit of the school and for no other commercial purpose. ### Third-Party Authentication Services and Learning Management Services (LMS) If you register for a Code.org account through an authentication service or identity provider (such as Google Accounts, Microsoft Accounts, or Facebook Connect) or through an LMS (such as Google Classroom, Clever, Canvas, or Schoology), we will store and use the information already associated with that service consistent with this Privacy Policy. In these instances, Code.org only **receives** information from these services — Code.org does not share information with such services. You (or your school) may revoke Code.org's access to your account on any authentication service or LMS at any time by disconnecting the respective authentication service from your account settings. Please review each service's terms of use and privacy policies carefully before connecting them to our Services. ### Non-Curriculum Features and Other Services When you use certain non-curriculum features of our Services, Code.org may ask you to provide Personal Information including your full name, email address, age, school or company name, and postal code or school street address, as well as your billing and/or shipping information when necessary to complete a purchase or make a donation. Examples include: - Signing forms or petitions to help advocate for computer science - Providing information to put your school on the map of schools teaching computer science - Contacting us for help or information via customer support pages - Subscribing to receive email communications from Code.org - Participating in a workshop - Signing up as a local volunteer - Bringing Code.org programs to your school or district - Donating to Code.org - Purchasing t-shirts or other items - Nominating a teacher - Participating in online surveys All non-transactional emails we send include an "unsubscribe" link. When a User identified as under the age of 16 signs our online petition supporting Code.org's mission, any name or email address they provide is deleted from our servers. ### Location Information Code.org does not request or collect GPS or other precise location data. We may collect and store non-precise location information (e.g., the approximate geographic region of a computer or mobile device, as determined from the IP address, or state as entered by the User) to help provide educational experiences or email updates that are tailored for that region. ### Information from Other Sources In certain situations, we may obtain information, including Personal Information, from third parties or other sources. If we combine or associate information from other sources with personal data that we collect through the Services, we will treat the combined information as personal data in accordance with this Privacy Policy. ### Technical Information To provide a personalized learning and high-quality experience for our Users, we may use various technologies that automatically record certain technical information from the User's browser or device, including browser language settings, standard log files, web beacons, or pixel tags. This technical information may include Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system, and the dates and times the User visited the Services. We may also use pixel tags (also known as "clear GIFs" or "web beacons"), which are tiny images that can be placed on a Web page or in an email to tell us when the recipient has displayed that page or opened that email. We may allow third-party service providers to place and read their own cookies, pixel tags, and similar technologies to collect information through the Services. For more information, see the [Code.org Cookie Notice](https://code.org) or the [Hourofcode.com Cookie Notice](https://hourofcode.com). ### Custom Content Student and Teacher profiles cannot be customized with a photo. As part of certain in-browser programming tools available on Code.org (such as "App Lab," "Game Lab," "Web Lab," and "Sprite Lab"), Students can upload custom images, text, sound, and videos to the Code.org platform to use within applications that they create. These files are stored by Code.org, but are not used by Code.org for any purpose other than within the applications created by Users. ### Internet Simulator and Other Messages Code.org offers a tool called the "Internet Simulator" for use in High School classrooms to model how the Internet functions. With this tool, Students participating in a Teacher-supervised classroom activity can send text-based messages to their Teacher and to other Students in their specific classroom section. Message contents are visible to the classroom Teacher and are not accessed or used by Code.org for any purpose other than in this educational tool. All messages are deleted after two hours of class inactivity, or upon a manual reset by the Teacher. In select courses, Teachers may optionally enable peer review groups within their classroom sections to allow students to provide feedback on other students' projects. The student feedback is visible only to the Teacher and to students within the group designated by the Teacher. Other than the above, the Services do not directly provide any other form of messaging among Users. ### Student Email Addresses Code.org does not store the email address provided by Users, authentication services, or LMS providers in a retrievable format. Instead, we create and store only a one-way hashed version of the email address (which cannot be converted back into the original address), and use it only for login, account management, and password recovery. For a small minority of our Students, and only if they are over the age of 18, we may offer the opportunity to participate in a "longitudinal" study to understand the multi-year impact of learning computer science. Participation in such a study is entirely optional. This contact information will not be shared with third parties, nor used in any way outside the purpose of such a study. ### No Commercial Use of Student Personal Information Some laws, such as California's Student Online Personal Information Protection Act (SOPIPA) and similar state laws, prohibit the gathering of the Personal Information of K-12 students for targeted advertising purposes. Code.org abides by such laws and shall not use, disclose, or compile Personal Information of Students on the Services for the purpose of marketing or advertising commercial products or services. We do not disclose Personal Information or other personal data of Students to third parties for marketing purposes. ### Service Improvement and Internal Operations We may use data (including personal data) we obtain or generate from the operation of our Services to (1) conduct internal research to improve, repair, or develop products, services, or technology; (2) identify and repair technical errors; (3) prevent, detect, protect against and respond to security threats or incidents; and (4) perform internal operations. --- ## How We Share or Transfer Information We do not rent or sell personal data or any other information that we collect from Users, or exploit it for financial gain in any other way. Code.org will never share or grant rights to personal data with other third-party organizations to use without your consent, except as part of a specific program or feature for which you will have the explicit ability and choice to opt-in. In particular, we do not share any personal data you provide with our donors or sponsors (only de-identified reports) without your explicit consent. ### We may share personal data with third-party service providers Code.org may use a variety of third-party service providers to support our operations. For example, we may use third parties such as email service platforms to send email, analytics companies to understand our Services usage and performance, Large Language Model providers to support AI-supported curricula, and social networking platforms to host our videos. When we give service providers access to data, including personal data, they are only allowed to use the data to provide services for which we have contracted. They are not allowed to use personal data for any other reason without the user's consent. You can find a list of third-party service providers we use on the Code.org website. ### We may share Student personal data with the Teacher and Teacher personal data with the Student If a Student belongs to a Teacher's section, we will share Student account information, course progress, and standalone projects with that Teacher so the Teacher can help manage the Student's progress. The Student will also see limited information about their Teacher including their Teacher's display name and section information. ### We may share personal data on classroom usage and Student achievement with the school or school district In order to support school and district needs to oversee Code.org usage in their classrooms, we may allow a Student's school or school district to access reporting data on student progress and achievement at the student-level, classroom-level, teacher-level, grade-level or school-level basis. We may also share personal data in Student Records with third parties as directed by a school or school district. ### We may share Teacher personal data with training facilitators, our Local Partner, the school district, and other partners Code.org partners with U.S.-based nonprofit professional learning organizations (our "Regional Partners") as well as similar organizations outside the U.S. (our "International Partners") (collectively our "Local Partners"). We share limited personal data (never including Student personal data) with these partners to allow them to run local professional development workshops and support teachers and schools in their region. Each Local Partner signs an agreement with Code.org that requires them to comply with this Privacy Policy and to treat any information received through the partnership as confidential. We may also share the list of schools (solely the school identities, without any personal data about Teachers or Students) that use Code.org or have participated in our professional learning program with select partners such as local, state, regional, or national education agencies, so long as such partners agree to treat the information as confidential. ### We may share personal data Users choose to post publicly In certain cases, Users may choose to post information that is publicly accessible on our Services. This includes making public posts as a Teacher on our forum, offering to be a volunteer if a User is over the age of 18, or choosing to put information about a User's school or organization on a public map. When you are filling out a form to post information on our Services, we will always make it clear exactly what will be shared publicly. Some of our Users choose to post their code-creations or other information to social networks. This functionality is entirely optional. When you post content to social networks, the content posted is entirely under your control, and never posted automatically on your behalf by Code.org. ### We may share personal data when Users contact us for support When a User contacts us with a support request, they may provide personal data, which is shared with a Code.org support representative in order to process the User's request. Code.org support representatives are either employees or independent contractors of Code.org, and will always have signed an agreement requiring them to protect and not disclose confidential information including personal data of Users. ### We may share personal data if Users are chosen (and give permission) to be profiled on our Services Code.org promotes Student and Teacher work on our Services and social media channels. These profiles and similar testimonials are published with the permission of the participating Student or Teacher and, if applicable, their parent, legal guardian, or teacher, and may include personal data such as the name, likeness, and photo or video of the person being profiled. ### We may share personal data when required by law Code.org may disclose personal data if required to do so by law, or if we have a good-faith belief that such action is necessary to comply with local, state, federal, international, or other applicable laws or respond to a court order, judicial or other government order, subpoena, warrant, or administrative request. In some cases, we may make such disclosures without first providing notice. ### We may share personal data when necessary or appropriate to protect Code.org or others Code.org may disclose personal data that we believe, in good faith, is appropriate or necessary to: take precautions against liability; protect Code.org from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; assist government enforcement agencies; protect the security or integrity of the Services; or protect the rights, property, or personal safety of Code.org, our Users, or others. ### We may share or transfer personal data in the context of a change of business, including a merger or acquisition In the event that Code.org is acquired by, or combined or merged with, another entity, we may transfer or assign the personal data that we have collected as part of such merger, acquisition, sale, or other change of control. Any personal data we have collected will be used, shared, and safeguarded by the acquiring organization under the same conditions described in this Privacy Policy. ### We may share de-identified or aggregate data We may share or publish de-identified or aggregate data about Students, Teachers, and our Services for various purposes. De-identified and aggregate data does not contain any personal data. For example: - We may provide our Local Partners with de-identified demographic information and information about usage of courses and professional learning programs for schools and districts in their area. - We may publish de-identified information about Student performance on our Services. These reports will never include personal data. Instead, aggregated, de-identified data over large populations of Students may be reported by demographic criteria such as age, general location, gender, race or ethnicity, and socioeconomic status. - We may work with third parties (such as universities and education research organizations) to improve our services and disclose automatically collected and other aggregated and de-identified data to these authorized partners to conduct research on online education. We require any research partner that receives de-identified data from us to agree in advance that they will not attempt to use this data to identify Users. --- ## How We Protect Information ### We use reasonable safeguards to help ensure that our Services are secure Code.org uses physical, administrative, and technical safeguards designed to reasonably protect the confidentiality, availability, integrity, and security of personal data and other information we collect and maintain in connection with the Services. These safeguards include, for example, restrictions on physical access to the data center, hardened system configuration, two-factor authentication, patch management, disaster recovery processes, employee security and privacy training, employee background checks, and third-party security resources, among others. We encrypt Personal Information in transit and at rest, and we have generally aligned our security practices to the NIST Cybersecurity Framework. However, no security measures can fully ensure the security of any or all of the personal data or other information we collect and store. If you transmit personal data to Code.org you do so at your own risk. We cannot guarantee that such personal data and other information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, administrative, or technical safeguards. If we learn of a data security incident that compromises or appears to compromise your Personal Information or that of your Students, we will attempt to notify you electronically so that you can take appropriate protective steps. ### We try to minimize the personal data we collect and store Code.org's goal is to minimize the personal data we collect. For instance, Code.org does not directly collect or store payment instrument data. Donations to Code.org or purchases from the Code.org store are processed via third parties, and Code.org never receives the payment instrument data. Similarly, Code.org does not collect or store biometric or health-related data and other sensitive categories of data except as disclosed in this Privacy Policy. Even when Code.org collects personal data in order to provide the Services, we attempt to minimize the data we store. For instance we intentionally choose not to store email addresses for Code.org Student accounts or phone numbers used in our send-to-phone feature. ### We limit employee and authorized party access to personal data Code.org's officers, directors, employees, agents and contractors must have a legitimate business reason (related directly to furthering our charitable, nonprofit, education-focused mission) to access personal data we maintain about Users or others. Code.org provides staff privacy and security training and will require our officers, directors, employees, agents, and contractors to comply with this Privacy Policy, and to treat any personal data of Code.org Users as confidential information. --- ## Your Choices - How to Access, Correct, Update, or Delete Your Information If, at any point, you wish to access, correct, update, or delete your personal data on the Code.org learning platform, you may do so from your Code.org account settings page as described below. Alternatively, you can email us at [support@code.org](mailto:support@code.org) or enter a request at [https://code.org/contact](https://code.org/contact). We will promptly review all such requests in accordance with applicable laws after verifying your identity. In the event you believe your request has been improperly denied or insufficiently processed, you may appeal that decision by submitting your request and the reasons you believe your request was improperly denied or insufficiently processed in an email to [privacy@code.org](mailto:privacy@code.org). Within forty-five (45) days after receipt of an appeal, we will inform you of any additional action taken or not taken in response to the appeal, along with a written explanation of the reasons in support of the response. Unless we receive a deletion request, we may retain your personal data as long as a User account is active, as long as the personal data is necessary or useful for operational purposes, or as required under any contract or by applicable law. We may indefinitely retain information which has been de-identified or aggregated such that it is no longer personal data. We do not engage in targeting advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning a User. Therefore, we do not process requests to "opt-out" of such processing. ### Managing and Deleting Code.org Accounts Code.org does not require an account to try our courses. However, Students and Teachers with an account may update, correct, or delete Personal Information and other personal data in their Code.org accounts at any time via the account settings page after logging into their account. Teachers can go to their section's "Manage Students" tab to update the most common settings or to access and delete a Student's login information. A parent or legal guardian of a Student under the age of 18 may also review Personal Information and correct erroneous information, if any, by asking the Student or Teacher to access the Student account. In order to allow Users to recover deleted accounts, we will save progress, code creations and other data for a short period of time after a User executes an online deletion request. A User can email [support@code.org](mailto:support@code.org) or enter a request at [https://code.org/contact](https://code.org/contact) to request an immediate permanent deletion of their account and all the associated data. A Teacher may also request the immediate deletion of Student accounts or particular Student projects or Student personal data the same way. We automatically delete personal data associated with Student or Teacher accounts that have remained unused and inactive for a period of time in accordance with our data retention policies. ### Managing and Deleting Other Data Deleting your Code.org account will not delete data that you may have submitted outside of Code.org's learning platform (such as signing our petition to support advocacy in your area) or on related services hosted by third parties such as our support forum or the teacher forum. Please send us an email at [support@code.org](mailto:support@code.org) or enter a request at [https://code.org/contact](https://code.org/contact) if you would like to have this information deleted and we will take reasonable steps to do so. --- ## School Users and Student Records Code.org may be used in a classroom setting by schools, school districts, or teachers (collectively referred to as "Schools"). When the Services are used as part of a School's educational curriculum, the personal data related to the School's Student Users that is provided to Code.org by the School or collected by Code.org during the provision of the Services to a School, may include information defined as "educational records" by the Family Educational Rights and Privacy Act ("FERPA") or be covered by other similar student data privacy laws, to which the School may be subject. In these cases, the Student's personal data we collect, along with any other student records the school provides to us and any student-generated content is referred to as "Student Records" and we have implemented controls and procedures to help the Schools address their obligations under such laws. In some cases where we process Student Records, we may enter into separate agreements with Schools that supplement our Terms of Service, such as our Student Data Privacy Addendum. Because many of our Student accounts are used for both School and non-School purposes, only personal data relating to Code.org accounts that are (1) created by a School (for example, when a Teacher creates the user name, login and password to establish the Student account, or when the teacher rosters a class using Google Classroom, Clever, or similar service), or (2) created by a Student at the direction of a School or Teacher, using a School email address and associated with a Teacher's section, are "Student Records." --- ## Children's Privacy Notice This privacy notice supplements our full Privacy Policy and provides additional information about how we collect, use and share Personal Information from children under the age of 13 (a "Child" or "Children"). The Code.org Services are designed for Users of all ages, including Children with the involvement of and pre-authorization by their school, teacher, parent or legal guardian. As a nonprofit entity, Code.org is not subject to the Children's Online Privacy Act ("COPPA"). However, Code.org takes numerous steps to promote parental involvement in their Child's use of Code.org and to minimize the collection and use of Personal Information from Children, including: - We do not require Users to create a Code.org account or otherwise provide Personal Information in order to participate in the Hour of Code tutorials or to try our courses. - We do not store actual Student email addresses for Student accounts (even those for Students 13 or older). We only store a one-way hashed version of the email address which we cannot reverse. - We do not collect full dates of birth, only age. - We do not collect Student physical addresses or phone numbers. - We do not generally support the display of public user profiles, except when we highlight or profile a user, with appropriate permission. - We do not support online messaging between Students (except for the Internet Simulator function for classrooms). - We only display a Student's first initial when we display projects on our Services. - We only provide a mechanism for Students age 13 or over to post projects to their social media accounts. - We automatically monitor some text entered in projects for elementary school courses, such as Play Lab and Sprite Lab, to help prevent sharing of personal data such as email address and phone number. - When we allow uploads of custom images, sounds, and videos by Students under age 13, we implement controls that block Student sharing of such projects. ### Code.org account sign-up When a Child creates a Code.org account using a personal login, we request a username, age (not birthdate), password, and email address (although we retain only a one-way hash of Student email addresses). In some jurisdictions, we may seek the consent of a parent or legal guardian before establishing the account for a Child. ### A School may create a Code.org account for a Child When Code.org is used by a School in an educational setting in classrooms with Children, we strongly recommend that Teachers not ask their students to create Code.org accounts with personal logins. Instead, we recommend that Teachers use one of the account creation methods noted below. Teachers who have classrooms with Children can create Code.org accounts without personal logins by using either a rostering service like Google Classroom or Clever, or by creating Code.org logins with picture passwords or secret word passwords that Teachers set for each student in a Teacher section. When Schools create Code.org accounts in these manners, we rely on the Teacher/School to obtain required consent, if any. ### How Parents can provide consent (where required) Although parental consent is not generally required, in those jurisdictions where we require such consent in connection with a Child account, the parent may provide consent by responding affirmatively to an email sent by Code.org to the Parent's email address provided by the Child during registration. We will send a reminder email after a few days if no response is received, but if we do not receive consent within the time prescribed, the Child's account will be closed and all account information (including the parent's email information) will be deleted from our systems. ### How we restrict functionality for Child accounts As explained in more detail in the full Privacy Policy, Code.org attempts to restrict Child account access to certain features that could potentially increase the inadvertent disclosure of the Child's personal information through the Service. ### No Third Party Tracking and No Targeted Advertising Code.org does not display targeted advertising on the Service. We do not disclose personal information of Children for direct marketing purposes or for targeted advertising purposes — on our site or on other sites. ### How to access, modify and delete Children Accounts As a Parent, you have the ability to access and control information about your Child — including requesting deletion of the Child account — by either logging into their account with their credentials and using the self-help delete function or by contacting us from your Parent email address associated with the child's account (if any) at [support@code.org](mailto:support@code.org). If Code.org learns that it has inadvertently collected Personal Information or Persistent Identifiers from children under the age of 13 without prior parental or teacher consent, Code.org will take appropriate steps to delete this information. To make such a request, please email us at [support@code.org](mailto:support@code.org) or enter a request at [https://code.org/contact](https://code.org/contact). Before processing your request, we may verify your identity and your relationship with the Student. --- ## Links to Other Sites and Services The Code.org Services may link to, and may be linked from, websites operated by other entities or individuals. Some third-party websites, such as the Code.org Facebook page and Twitter page, may be co-branded with our name or logo. Use of these third-party services are completely optional and typically meant only for adult users. These services are governed by the privacy policy of these third parties. We encourage you to review these third-party privacy policies for details about how they may collect, store, and use your personal data if you choose to engage with them. --- ## We Do Not Allow Advertising on Our Services Code.org does not allow advertising on our Services, and we do not have the ability to collect web search history across third-party Internet websites or search engines. However, if you navigate to the Code.org Services via a web search, your web browser may automatically provide to us the web search term you used in order to find Code.org. Because Code.org doesn't display advertising or track browsing on third-party sites, we do not do anything different in response to "do not track" signals transmitted by web browsers. We use the embedded YouTube player in Privacy Enhanced Mode to deliver computer science videos within our curriculum. This means that YouTube does not place cookies or track viewing behavior for advertising purposes. We have also tagged our "YouTube" videos on the site for "child-directed treatment." Schools can also choose to block access to YouTube, in which case we use a fallback option that plays videos directly from our Services. We offer clearly marked links to visit Facebook or Twitter to share various things such as User creations or certificates on Code.org. Using an account on these third-party social networking services is entirely at your option and under your control, and will not result in behavioral tracking of your browsing behavior on Code.org. On student-facing course and activity pages, we don't offer links to these services to Students under the age of 13, or in schools that have blocked Internet access to these services. To opt out of various forms of internet advertising by third parties, you may visit the following links: - [http://www.networkadvertising.org/choices](http://www.networkadvertising.org/choices) - [http://www.aboutads.info/choices/](http://www.aboutads.info/choices/) - EU-based: [http://www.youronlinechoices.eu/](http://www.youronlinechoices.eu/) --- ## International Users Our Services are operated and managed on servers located within the United States. If you choose to use our Services from regions of the world with laws governing data collection and use that differ from U.S. law, then you acknowledge and agree that you are transferring information, including personal data, outside of those regions to the United States and that, by providing your personal data on the Services, you are providing your consent to that transfer. --- ## Rights Under the General Data Protection Regulation (GDPR) If you are an individual in the European Economic Area (EEA) and you choose to use our US-based Services, we collect and process personal data about you only where we have a legal basis for doing so under the GDPR or other applicable EU laws. This means we process your personal data only where: - You give us consent to do so for a specific purpose; - The processing is necessary for the performance of a contract between us (e.g., our terms of service) or in order to take steps at your request prior to entering into a contract; - The processing is necessary to provide you the functionality of the Services, including to operate the Services, provide customer support and personalized features, and to protect the safety and security of the Services; - The processing is necessary for the purposes of our legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services, and to protect our legal rights and interests; or - The processing is necessary to comply with a legal obligation. If you have consented to our use of personal data for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. If you use our Services from the EEA, your personal data will be transferred to and processed in the United States. Code.org generally relies on derogations for specific situations as set forth in Article 49 of the GDPR for such transfers. In particular, Code.org collects and transfers to the U.S. personal data (1) with your explicit consent or (2) to perform a contract with you. In most cases, Code.org is the controller of personal data we collect and process through the Services. Where we are the controller of your personal data, you have the following rights: - **Right of access and portability.** The right to obtain access to your personal data, and to receive the personal data in a commonly used format and to have it transferred to another data controller. - **Right to rectification.** The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete. - **Right to erasure.** The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed. - **Right to restriction.** The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you. - **Right to object.** The right to object, on grounds relating to your particular situation, to the processing of your personal data. - **Right to Complain.** The right to file a complaint with a supervisory authority if you believe that we have violated any of the rights concerning personal data about you. We encourage you to first reach out to us at [privacy@code.org](mailto:privacy@code.org) so we have an opportunity to address your concerns directly before you do so. A list of Supervisory Authorities is available [here](https://edpb.europa.eu/about-edpb/board/members_en). To exercise the foregoing rights, please contact us by sending us an email at [support@code.org](mailto:support@code.org) or enter a request at [https://code.org/contact](https://code.org/contact). We will consider your request in accordance with applicable law. In some cases our ability to uphold these rights may depend upon our obligations to process personal data for security, safety, and fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request. --- ## Changes and Updates to Our Privacy Policy We may update our Privacy Policy from time to time. Code.org will notify Users of any change to our Privacy Policy by posting the revised Privacy Policy with an updated date of revision on our Services. If we make material changes to the Privacy Policy we will highlight that fact with a short notice of the revision conspicuously posted on the Services homepage. We will contact Users and notify them of the changes if required by law. We stand behind the promises we make, and will not change how we use personal data we have already collected from Users in any material way without also providing notice of the change via email, through the Services, or through other means, and obtaining consent via your continued use to any new data use policies after such notice. --- ## Contacting Code.org If you have questions or concerns about this Privacy Policy or Code.org's data collection and processing practices, or if you want to report any security violations, please contact us: - **Email:** [privacy@code.org](mailto:privacy@code.org) - **Mail:** Code.org 1501 4th Avenue, Suite 900 Seattle, WA 98101 Attn: Privacy Officer --- *Source: [https://code.org/en-US/privacy](https://code.org/en-US/privacy)*