Privacy Notice

(see also ourlegal page)

This privacy notice has been compiled to better serve those who are concerned with how their 'Personally identifiable information' (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

Note that this privacy policy covers all of CodeCombat's products, including Ozaria Classroom, CodeCombat Classroom, CodeCombat Home, CodeCombat AI League, CodeCombat Live Online Classes, CodeCombat Worlds, CodeCombat AI HackStack, and our professional development courses.

At CodeCombat, we understand the importance of safeguarding student data and we take this responsibility seriously. We have signed hundreds of data privacy agreements with school districts across the United States, including some of the largest, as well as with international government entities. These agreements outline specific terms of service that detail exactly how we protect student data. We strive to provide a secure and reliable service, do not seek to absolve ourselves from any legal responsibilities related to the operation of our service, and are committed to addressing any issues that may arise in a fair and lawful manner. We are always open to signing additional agreements with our customers to further reflect our commitments around the safety and privacy of student data.

What personal information do we collect from the people that visit our website?

When do we collect information?

We collect information from you when you register on our site, place an order, fill out a form, or enter information on our site.

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to an email, play the game, or use certain other site features in the following ways:

How do we protect visitor information?

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. All financial transactions are processed through a secure gateway provider (Stripe), with no sensitive financial information stored or processed on our servers.

CodeCombat takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of your personal information. These measures include but are not limited to SSL, strong encryption, de-identification, pseudonymization, limited access controls, regular testing, and minimal data collection and data retention.

Do we use 'cookies'?

Yes. Cookies are small files that a site transfers to your computer's hard drive through your Web browser (if you allow) that enable the site's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to authenticate your browsing session. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

• Understand and save your preferences for future visits.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.

If users disable cookies in their browser:

If you disable cookies, it will turn off some of the features that make your site experience more efficient and some of our services will not function properly.

Delete Your Account

To delete your account and all personal data relating to your account, go to https://codecombat.com/account/settings and scroll down to the section Delete Your Account . Enter your email address and password, and click Delete this account permanently. All user data will then be deleted.

Third Party Disclosure

We do not sell or trade to outside parties your personally identifiable information, and do not otherwise transfer it except as described in this privacy notice.

How does our site handle do not track signals?

We avoid tracking as many non-required analytics and cookies as possible, but cannot guarantee 100% coverage.

Does our site allow third party behavioral tracking?

Yes, for example, via Google Analytics.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. See morehere.

According to CalOPPA: users can visit our site anonymously; we link to this Privacy Policy on the home page; and our Privacy Policy link includes the word 'Privacy', and can be easily be found on the home page.

Users will be notified of any privacy policy changes on this Privacy Policy Page. Users are able to change their personal information by logging into their account or by emailing us. Should CodeCombat need to terminate a user account, we will attempt to forewarn the user via the email address on file.

FERPA

Our collection, use, and disclosure of student data is governed by this privacy policy, any other agreement with an educational agency, the provisions of the Family Educational Rights and Privacy Act (FERPA), COPPA, and applicable state laws which relate to the collection of student data. See the rest of this privacy policy for other details on the limited ways in which we handle student data.

SOPIPA

CodeCombat is compliant with SOPIPA, meeting, among others, these requirements. We:

1. do not use any data collected via the service to target ads to students;
2. do not create advertising profiles on students;
3. do not sell student information;
4. do not disclose personal information, unless required by law or as part of the maintenance and development of the service;
5. do use sound information security, including encryption of data and other industry-standard practices;
6. will delete data that we have collected from students in a school when the school or district requests it;
7. share information only with educational researchers or with educational agencies performing a function for the school;
8. innovate safely without compromising student privacy by only using de-identified and aggregated data to develop and improve the service.

AB 1584

CodeCombat is compliant with AB 1584. For our classroom version, pupil records continue to be the property of and under the control of the local educational agency. Pupils may retain possession and control of their own pupil-generated content by editing or deleting their content from our servers themselves via the website or by emailing [email protected]. Pupils may also request to transfer their pupil-generated content to a personal account. Third parties will not have access to any personally identifiable information in the pupil record for any purpose. Parents, legal guardians, and eligible pupils may review their information and request corrections to erroneous information through account settings on our website or by emailing [email protected]. We take actions to ensure the security and confidentiality of pupil records, including but not limited to designating and training responsible individuals on ensuring the security and confidentiality of pupil records, by using current, commercially reasonable methods. In the event of an unauthorized disclosure of a pupil's records, CodeCombat shall report to an affected parent, legal guardian, or eligible pupil pursuant via email (if provided). CodeCombat shall not use any information in a pupil record for any purpose other than those required or specifically permitted by this privacy policy. CodeCombat will not use pupil records to engage in targeted advertising. A pupil's records shall not be retained or available to CodeCombat past the terms of any contract with a local educational agency, except for a case where a pupil chooses to establish or maintain an account with CodeCombat for the purpose of storing pupil-generated content, either by retaining possession and control of their own pupil-generated content, or by transferring pupil-generated content to a personal account.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We adhere to the following COPPA tenets:

• We will not require a child to disclose more information than is reasonably necessary to particapate in our service.
• Teachers and parents can agree to the collection and use of their students' information, but still not allow disclosure to third parties.
• Teachers and parents can review, delete, and manage their students' information through account settings on our website or by emailing [email protected].
• We notify teachers and parents directly before collecting PII from their children. This includes what specific information will be collected and how it might be disclosed, a link to our online privacy policy, and how teachers and parents can give their consent.
• Parents can give consent by creating accounts for their children and providing the minimum necessary personal information needed during that account creation.
• Student accounts for use in school settings can only be created with consent of a teacher.

In other countries with similar children's privacy laws applying to children under 13 - 16 years old per country, we follow similar consent and information security policies to protect the personal data of children.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices, should a data breach occur, we will notify the affected users via email within 7 business days (or within 72 hours for certain categories of breach).

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Authenticate your user account.
• Send information, respond to inquiries, and/or other requests or questions.
• Process orders and to send information and updates pertaining to orders
• We may also send you additional information related to your product and/or service (optional).

To be in accordance with CAN-SPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Include the physical address of our business or site headquarters
• Monitor third party email marketing services for compliance, if used
• Honor opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email

If at any time you would like to unsubscribe from receiving future emails, you can change your email settings in your account preferences, email us, or follow the instructions at the bottom of each email, and we will promptly remove you from all correspondence.

Student Data Processors

Personal student data is collected and processed only when necessary to provide the service. These data subprocessors are bound to safeguard student data and assist CodeCombat in providing its services:

General Data Protection Regulation (GDPR) for EU users

GDPR is a Regulation by which the European Commission intends to strengthen and unify data protection for individuals within the European Union. For users within the EU, we comply with GDPR and the Privacy by Design principles that guide it, including minimal collection of personal data, deletion of personal data that are no longer necessary, securely restricted access to personal data, privacy as the default, and visibility and transparency.

Legal basis of processing

CodeCombat may process personal data relating to EU users if one of the following applies:

• EU users have given their consent for one or more specific purposes.
• provision of personal data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which CodeCombat is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in CodeCombat;
• processing is necessary for the purposes of the legitimate interests pursued by CodeCombat or by a third party.

In any case, CodeCombat will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place of processing

EU users' personal data are processed on US-based CodeCombat servers and at CodeCombat's San Francisco office. This necessitates a cross-border data transfer to the United States, a country whose privacy laws the EU does not consider as providing adequate data safeguards. As CodeCombat does not yet have the Privacy Shield certification necessary to ensure adequacy, EU users may either explicitly consent to such a transfer or refrain from granting CodeCombat consent while creating a CodeCombat account. At any time, this consent may be withdrawn by deleting your CodeCombat account or contacting us to request deletion. All of the data processors that might receive personal data do have adequate data protection safeguards in place, such as Privacy Shield certification or EU-approved standard contractual clauses.

Data retention time limits

Personal data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• Personal data collected for purposes related to the performance of a contract between CodeCombat and an EU user shall be retained until such contract has been fully performed and the user has determined that no further contract will be needed.
• Personal data collected for the purposes of CodeCombat’s legitimate interests shall be retained as long as needed to fulfill such purposes. EU users may find specific information regarding the legitimate interests pursued by CodeCombat within the relevant sections of this document or by contacting CodeCombat.
• CodeCombat may be allowed to retain personal data for a longer period whenever an EU user has given consent to such processing, as long as such consent is not withdrawn. Furthermore, CodeCombat may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

More specifically, CodeCombat will retain server log files for no more than 30 days, and will retain inactive, unpaid EU user accounts for no more than 2 years.

Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Detailed information on the processing of personal data

CodeCombat is assisted by the following GDPR-compliant data processors and data controllers, some of which will be disabled by setting the Do Not Track option in your browser or, in the EU, opting out of cookies:

Usage data is defined as information collected automatically through CodeCombat (or third-party services employed by CodeCombat), which can include: the IP addresses or domain names of the computers utilized by the users who use CodeCombat, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by a user, the various time details per visit (e.g., the time spent on each page within CodeCombat) and the details about the path followed within CodeCombat with special reference to the sequence of pages visited, and other parameters about the device operating system and/or a user's IT environment.

In addition to the data processed by our partners, CodeCombat also directly processes the following categories of personal data for EU users:

The rights of EU users

EU users may exercise certain rights regarding their personal data processed by CodeCombat. In particular, EU users have the right to do the following:

• Withdraw their consent at any time. EU users have the right to withdraw consent where they have previously given their consent to the processing of their personal data.
• Object to processing of their personal data. EU users have the right to object to the processing of their personal data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their personal data. EU users have the right to learn if personal data are being processed by CodeCombat, obtain disclosure regarding certain aspects of the processing and obtain a copy of the personal data undergoing processing.
• Verify and seek rectification. EU users have the right to verify the accuracy of their personal data and ask for data to be updated or corrected.
• Restrict the processing of their personal data. EU users have the right, under certain circumstances, to restrict the processing of their personal data. In this case, CodeCombat will not process their personal data for any purpose other than storage.
• Have their personal data deleted or otherwise removed. EU users have the right, under certain circumstances, to obtain the erasure of their personal data from CodeCombat.
• Receive their personal data and have data transferred to another controller. EU users have the right to receive their personal data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the personal data are processed by automated means and that the processing is based on an EU user's consent, on a contract which an EU user is part of or on pre-contractual obligations thereof.
• Lodge a complaint. EU users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where personal data are processed for a public interest, in the exercise of an official authority vested in CodeCombat or for the purposes of the legitimate interests pursued by CodeCombat, EU users may object to such processing by providing a ground related to their particular situation to justify the objection. EU users should know that, however, should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.

How to exercise these rights

Any requests to exercise user rights can be directed to CodeCombat through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by CodeCombat as early as possible and always within one month. For the right to deletion, users can also simply use the Delete Account functionality in their account settings. Various consents can also be withdrawn in the account settings.

Applicability of broader protection standards

While most provisions of this document concern all users, some GDPR-specific provisions expressly only apply to users located within the EU. We are happy to provide many of these rights to all users when appropriate.

Contacting Us

If you have any questions regarding this privacy policy or requests about your personal data, you may contact us using the information below.

CodeCombat Inc.
2261 Market Street #4388
San Francisco, CA 94114
USA
[email protected]

Last Edited on 2023-05-17