Last Updated: May 13, 2022
COMPLIANCE WITH COPPA AND FERPA
We designed the School Services to comply with applicable privacy laws, including the Children’s Online Privacy Protection Act (“COPPA“) and the Family Educational Rights and Privacy Act (“FERPA”). When FERPA applies, we act as a “school official” to our school or school district customer, which means that we are under the direct control of the school or district and use student data only to provide our services to the school or district and not for our own purposes. To the extent COPPA applies, the school or district provides us with any necessary consent on behalf of students’ parents or guardians to permit processing of student data.
OUR COLLECTION OF STUDENT DATA
We request student data as necessary to provide the School Services and for authorized school purposes, at the direction of our school and school district customers. We collect the following categories of information.
Student nickname: We collect a nickname from a student when they play a game through the School Services. This nickname is deleted after the session and not associated with a persistent identifier.
Information collected automatically:
We automatically collect the following types of information through background technologies when a student plays a game through the School Services:
- Device operating system
- Curriculum completed within the game
- Internet Service Provider
- Internet Protocol (IP) address or other persistent identifiers
We use this information in support of international operations, such as to make the School Services more interesting and useful to students, and maintain, secure, and analyze the School Services.
Personal information collected at a teacher’s direction: Certain features of the School Services permit a teacher to collect additional information about their class, as well as about individual students, such as attendance, results, answers submitted when playing our games (including in response to open-ended questions) and performance on our games. We use such information to provide the services to the teacher, such as to permit the teacher to interact with students and track their progress over time. A school or teacher may permit students to share information with others, such as with other students in the same class, school, or school district.
USE OF STUDENT DATA
We may use the student data we collect: (1) to provide the School Services; (2) to comply with the law (such as when we use information for record-keeping to satisfy legal and compliance obligations); (3) in accordance with valid consent (as conveyed to us through the schools); and (4) as necessary for business interests (such as when we collect and use a student’s data in support of internal operations). In addition, the extent permitted law, we may use and disclose anonymized and/or aggregated student data for any purpose, including for analytics purposes, and to help us understand how our products are used and improve upon them.
SPECIAL CIRCUMSTANCES FOR DISCLOSURE
We reserve the right to disclose student data:
- To facilitate teacher or school review of a student’s progress.
- As permitted or required by applicable law, such as to operate the School Services; to maintain the safety and integrity of the School Services; to send technical notices, updates, security alerts, information regarding changes to policies, and administrative messages; to prevent fraud, breaches of our policies, and threats of harm; to conduct research; to improve the School Services; to take precautions against other liability; or when we believe release is required to comply with federal, state or local law (such as cooperating with a judicial process or law enforcement investigation).
- In connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets, wind-down of business or related due diligence.
We do not engage in the following practices with respect to student data:
- We do not sell student data to third parties.
- We do not serve targeted ads on the School Service and do not use student data we collect to serve targeted ads on other services.
- We do not build a profile of a student other than in support of authorized school purposes.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect student data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about users.
RETENTION AND DELETION
We keep the student data we collect for a reasonable amount of time to perform the task for which we collected it. We reserve the right to keep certain information to the extent permitted and/or required by law, including any statutory retention requirements. When deleted, student data is deleted securely. In some cases, to the extent permitted by law, we may deidentify or aggregate student data instead of deleting it.
We support our school customers in providing parents and eligible students with access to their student data and in fulfilling other requests that parents and eligible students may make, such as to request deletion of student data or to refuse its further collection or use. If you are a parent or legal guardian and wish to exercise your rights, please contact your child’s school or school district directly. In your request, please include your child’s name, and specify the action you would like the school or school district to take. For your child’s protection, we may need to verify your identity before implementing your request. Please keep in mind that a request to delete student data may lead to a termination of your child’s ability to use the School Services.
Changes to this Policy
This policy may be changed, so please be sure to check regularly. If we make a material change to this policy and we have your contact details, we will contact you before we make the change. We will also post a notice at the start of the policy.
Redwood Pro Media LLC
P.O. Box 912
Crescent City, CA 95531