Code.org is an online application dedicated to expanding access to computer science learning, and increasing participation by women and underrepresented students of color. Code.org's terms state they allow representatives of school districts and schools, such as teachers, administrators, counselors, and other volunteer mentors to set up classrooms with their students through the Services in order to provide tutorial, educational and similar services. Code.org's terms state they collect personally identifiable information and automatically collected usage information from a user when they create a Code Studio Student or Teacher account. In addition, Code.org's terms state they take the protection of a user’s information very seriously and its officers, directors, employees, agents and contractors must have a legitimate business reason to access a user’s Personal Information and to treat any Personal Information of Code.org users as confidential information. Lastly, Code.org's terms specify they take steps to minimize the collection of personal data from users under the age of 13, and encourage children to get the approval of a parent or legal guardian before creating an account on Code.org.
The terms of Code.org state they are deeply committed to creating a safe and secure learning environment for its students and teachers. Code.org's terms specify they allow representatives of school districts and schools, such as teachers, administrators, counselors, and other volunteer mentors to set up classrooms with their students through the Services in order to provide tutorial, educational and similar services. However, Code.org’s platform does not connect students directly to volunteers or mentors, but instead provides Educators information about potential volunteers.
In addition, Code.org's terms state they have created 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. The terms state message contents are visible to the classroom teacher and are not accessed or used by Code.org for any purpose other than an educational tool. All messages are deleted after two hours of class inactivity, or upon a manual reset by the teacher.
Code.org's terms state they collect personally identifiable information and automatically collected usage information from a user when they create a Code Studio Student or Teacher account. However, Code.org's terms state they do not require a user to provide any personal information in order to try the tutorials, many of which are accessible without creating a user account. The terms of Code.org state they will never share a user’s personal information with other third parties without the user’s explicit opt-in consent. In addition, Code.org's terms state they do not rent or sell personal information, persistent identifiers, or any other information that they may collect from users, or exploit it for financial gain. Moreover, Code.org's terms specify they do not display any advertising and do not use student data for any targeted or behavioral advertising, profiling, onward disclosure, or collect a user’s web search history across third-party Internet websites or search engines.
Lastly, the terms of Code.org state that school district partners may provide anonymous or de-identified student academic data to an independent third party evaluator to measure how well their programs perform and how well students are learning from them in select partner school districts. Aggregated and anonymized data about student performance over large populations of students may be reported by demographic criteria such as age, general location, gender, ethnicity, and socioeconomic status, but Code.org’s contracts with school districts specify very strict limitations on who may access this data.
Code.org's terms state they take the protection of a user’s information very seriously and its officers, directors, employees, agents and contractors must have a legitimate business reason to access a user’s Personal Information and are required to treat any Personal Information of Code.org users as confidential information. In addition, Code.org's terms state they use certain physical, managerial, and technical safeguards designed to preserve the integrity and security of a user’s Personal Information. However, the terms do not discuss whether personal information is encrypted while in transit or while in storage. To protect a user’s privacy and security, Code.org's terms state they take reasonable steps to verify an individual’s identity before granting them account access or making corrections to their Personal Information. Teachers who create user accounts on behalf of students can reset the “secret word” or “secret picture” for young children who can’t read, as long as the student leaves the teacher in control of the account.
In addition, although a user may provide personal information to Code.org to use the Service, Code.org's terms state they believe that data they do not store cannot be stolen from them. Code.org's terms state they intentionally choose not to store email addresses for Code Studio student accounts, or phone numbers used in the send-to- phone feature. Lastly, if Code.org learns of a data security incident that compromises or appears to compromise a user’s Personal Information, they will attempt to notify affected users electronically so that they can take appropriate protective steps.
Code.org's terms state they take steps to minimize the collection of personal data from users under the age of 13, and encourage children to get the approval of a parent or legal guardian before creating an account on Code.org. If a user is under the age of 13, the terms state they will be able to use the App Lab, Game Lab, and Web Lab tools in the classroom with their teacher’s approval.
The terms state users under 13 can try most tutorials without creating an account, but their learning progress won’t be saved. 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. The terms also state when students create accounts on Code Studio, Code.org does not store the email address provided by those Users in a retrievable format. Code.org's terms state they immediately create and store a one-way hashed version of the email address, which cannot be converted back into the original address, and use it only for the purposes of login, account management, and password recovery.
In addition, the terms state Code Studio's learning platform is designed to be used by Users of all ages, including children under the age of 13 with the involvement of and authorization by their school, teacher, parent or legal guardian. A student’s educator or associated educational organization is required have proper permission to register a student for Code.org, and they must have obtained the necessary parental consent for Code.org’s collection of the student’s personal information for the use and benefit of the school and for no other commercial purpose.
Every privacy rating includes an overall score. A higher score (up to 100%) means the product provides more transparent privacy policies with better practices to protect user data. The score is best used is as an indicator of how much additional work a person will need to do to make an informed decision about a product.
|Basic Score||Full Score|
The privacy evaluation process summarizes the policies of an application or service into concern categories based on a subset of evaluation questions that can be used to quickly identify particular practices of a vendor’s policies. These concerns are composed of evaluation questions that can be used to calculate scores relative to that concern.
|Concern||Basic Score||Full Score|
|Data Collection: Protecting personal information||75||55|
|Data Sharing: Protecting data from third parties||100||90|
|Data Security: Protecting against unauthorized access||83||85|
|Data Rights: Controlling data use||88||95|
|Data Sold: Preventing sale of data||75||70|
|Data Safety: Promoting responsible use||100||80|
|Ads & Tracking: Prohibiting the exploitation of users' decision making process||100||90|
|Parental Consent: Protecting children’s personal information||100||90|
|School Purpose: Following student data privacy laws||100||70|
Each statute or regulation is associated with one or more evaluation questions. As such, we can calculate scores for each statute or regulation using only those questions associated with the statute or regulation. Each specific statute or regulation's score serves as an indirect proxy indicating the likelihood of the application or service satisfying all of its compliance obligations.
|Statute||Basic Score||Full Score|
|California Online Privacy Protection Act (CalOPPA)||92||79|
|Children's Online Privacy Protection Act (COPPA)||96||82|
|Family Educational Rights and Privacy Act (FERPA)||94||76|
|Student Online Personal Information Protection Act (SOPIPA)||96||80|
|General Data Protection Regulation (GDPR)||89||80|
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Privacy policies do not indicate a changelog or past policy version is available.
1.2: Policy Notice
- Users are notified if there are any material changes to the policies.
- Privacy policies indicate the method used to notify a user when policies are updated.
1.3: Policy Changes
- Unclear whether users are notified prior to any material changes to the policies.
- Changes to the policies are effective immediately and continued use of the product indicates consent.
1.4: Policy Coverage
- Privacy policies indicate the products that are covered by the policies.
1.5: Policy Contact
1.6: Policy Principles
- Privacy policies do indicate any privacy principles, layered notices, or a table of contents.
1.7: Policy Language
- Privacy policies are available in multiple languages.
1.8: Intended Use
- Intended for children under 13.
- Unclear whether intended for teens.
- Intended for adults over 18.
- Intended for parents or guardians.
- Intended for students.
- Intended for teachers.
2: Focused Collection
2.1: Data Collection
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Geolocation data are collected.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- Unclear whether this product collects sensitive data.
- Non-personally identifiable information is collected.
- Unclear whether free or reduced lunch status is collected.
2.2: Data Source
- Personal information or education records are collected from preK-12 students.
- Personal information from children under 13 years of age is collected online.
2.3: Data Exclusion
- Specific types of personal information are not collected.
2.4: Data Limitation
- Collection or use of data is limited to product requirements.
3: Data Sharing
3.1: Data Shared With Third Parties
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
3.2: Data Use by Third Parties
- The purpose for sharing a user's personal information with third parties is indicated.
- Data are shared for analytics.
- Data are shared for research and/or product improvement.
- Data are not shared for third-party advertising and/or marketing.
3.3: Data Not Shared With Third Parties
- Unclear whether there are specific categories of information that are not shared with third parties.
3.4: Data Sold to Third Parties
- Data are not sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Personal information from users is acquired from third parties.
3.6: Third-Party Links
- Links to third-party external websites are not age-appropriate.
3.7: Third-Party Data Access
- Third parties are authorized to access a user's information.
3.8: Third-Party Data Collection
- Personal information of users is collected by a third party.
3.9: Third-Party Data Misuse
- Unclear whether personal information can be deleted from a third party if found to be misused.
3.10: Third-Party Service Providers
- Data are shared with third-party service providers.
- The roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
- The categories of third parties that receive personal information are indicated.
3.12: Third-Party Policies
- Unclear whether links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
- Unclear whether data can be combined with data from third-party sources.
- Unclear whether data shared with third parties can be combined by third parties for their own purposes.
3.14: Third-Party Authentication
- Social or federated login is supported.
- Personal information from social or federated login providers is collected.
- Personal Information is shared with social or federated login providers.
3.15: De-identified or Anonymized Data
- User information is shared in an anonymous or deidentified format.
- The vendor describes their deidentification process of user information.
3.16: Third-Party Contractual Obligations
- Contractual limits are placed on third-party data use.
- Contractual limits prohibit third parties from reidentifying deidentified information.
4: Respect for Context
4.1: Data Use
- Use of information is limited to the purpose for which it was collected.
- The purpose for which data atr collected is indicated.
4.2: Data Combination
- Combined information is treated as personally identifiable information (PII).
4.3: Data Notice
- Notice is provided if the context in which data are collected changes.
4.4: Data Changes
- Consent is obtained if the practices in which data are collected change.
4.5: Policy Enforcement
- Accounts may be terminated if users engage in any prohibited activities.
5: Individual Control
5.1: User Content
- Users can create or upload content.
5.2: User Consent
- Opt-in consent is requested from users at the time personal information is collected.
5.3: Remedy Process
- Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
5.4: Data Settings
- Users can control their information through privacy settings.
5.5: Data Disclosure
- Users can opt out from the disclosure or sale of their data to a third party.
- Users can request to know what personal information has been shared with third parties for commercial purposes.
- Notice is provided in the event the vendor receives a government or legal request for a user’s information.
5.6: Intellectual Property
- Users retain ownership of their data.
- A copyright license is claimed to data or content collected from a user.
- Any copyright license to a user's data is limited in scope or duration.
- Notice is not provided to users when their content is removed or disabled because of an alleged copyright violation.
6: Access and Accuracy
6.1: Data Access
- Processes to access and review user data are available.
- Permissions, roles, or access controls are available to restrict who has access to data.
- Processes to review data are available for the school, parents, or students.
6.2: Data Integrity
- The vendor does not maintain the accuracy of data they collect.
6.3: Data Correction
- Processes to modify inaccurate data are available.
- Processes for the school, parents, or students to modify data are available.
- Unclear whether the time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- The retention time period of a user's data can be changed upon a valid inspection request.
6.5: Data Deletion
- Data are deleted when no longer necessary.
- A user's data are deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Processes for the school, parents, or students to delete data are available.
- The time period for the vendor to delete data is indicated.
6.6: Data Portability
- Processes to download user data are available.
- Unclear whether a user can assign an authorized account manager or legacy contact.
7: Data Transfer
7.1: Data Handling
- User information can be transferred to a third party.
- Notice is provided to users if the vendor assigns its rights or delegates its duties to another company.
- Unclear whether users are notified if their information is transferred to a third party.
7.2: Transfer Request
- Unclear whether user information can be deleted prior to its transfer to a third party.
7.3: Onward Contractual Obligations
- Third-party transfer is contractually required to use the same privacy practices.
8.1: User Identity
- A user's identity is verified with additional personal information.
8.2: User Account
- Account creation is not required.
- Parental controls or managed accounts are available.
- Two-factor account protection is available.
8.3: Third-Party Security
- Third-party contractual security protections are required.
8.4: Data Confidentiality
- Industry best practices are used to protect data.
- Employee or physical access to user information is limited.
8.5: Data Transmission
- Unclear whether this product encrypts all data in transit.
8.6: Data Storage
- All data at rest are encrypted.
- Personal information of users is stored with a third party.
8.7: Data Breach
- Notice is provided in the event of a data breach.
8.8: Data Oversight
- Unclear whether this product performs data-privacy and security-compliance audits.
9: Responsible Use
9.1: Social Interactions
- Users can interact with trusted users and/or students.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information is not shared for social interactions.
9.2: Data Visibility
- Personal information is not displayed publicly.
- Users can control how their data are displayed.
9.3: Monitor and Review
- User-created content is reviewed, screened, or monitored by the vendor.
- User-created content is filtered for personal information before being made publicly visible.
- Social interactions between users are moderated.
- Unclear whether social interactions of users are logged.
9.4: Report Content
- Users can filter or block inappropriate content.
- Unclear whether users can report abuse or cyberbullying.
9.5: Internet Safety
- The vendor provides links to tools or processes that support safe and appropriate social interactions.
10.1: Vendor Communications
- A user can receive service- or administrative-related communications from the vendor.
10.2: Traditional Advertising
- Traditional or contextual advertisements are not displayed.
10.3: Behavioral Advertising
- Behavioral or targeted advertising is not displayed.
10.4: Ad Tracking
- Data are not collected by third-party advertising or tracking services.
- Data are not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
- Unclear whether children may receive inappropriate advertisements.
10.6: Marketing Communications
- The vendor cannot send marketing messages.
- Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
- Users can opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Vendor does respond to Do Not Track or other opt-out mechanisms.
- The vendor does provide a method for users to opt-out from third-party tracking.
11.1: Children Under 13
- Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- Account creation is restricted for users under 13 years of age.
- Vendor does restrict in-app purchases for users under 13 years of age.
- Unclear whether the vendor participates in an FTC-approved COPPA safe harbor program.
11.2: Students in K–12
- Product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Product does create education records.
- Notification of a contract or additional rights is provided.
- Vendor is designated as a school official.
11.3: Parental Consent
- Parental consent is required.
- Parental consent is limited with respect to third parties.
- Parents can withdraw consent for the further collection of their child's information.
- Children's personal information is deleted if collected without parental consent.
- Parental consent notice and method for submission are provided.
- Unclear whether the vendor can use collected information to support the “internal operations” of the product.
- Unclear whether this product indicates COPPA parental consent exceptions.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.
- Parental consent obligations are transferred to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing any dispute is indicated.
- A user is required to waive the right to a jury trial, or settle any disputes by arbitration.
- Unclear whether a user is required to waive the right to join a class action lawsuit.
- A vendor will disclose personal information to law enforcement.
- The vendor has signed a privacy pledge or received a privacy certification.
11.6: International Laws
- A user's data are subject to International data transfer or jurisdiction laws, such as the GDPR.
- The vendor has indicated it is a Data Controller or Data Processor.