Render Direct Notice to Educational Institution
Last Updated: June 7, 2024
Under the U.S. Children’s Online Privacy Protection Act (COPPA), online service providers must provide parental notification and obtain verifiable parental consent before collecting personal information from children under the age of 13, except in limited situations. While COPPA does not apply to nonprofit organizations like CZI, we take privacy seriously and have chosen to inform our practices with COPPA.
In cases where educational institutions contract with online service providers to offer programs solely for the benefit of students and schools, COPPA allows for such institutions to act as a parent’s agent and to consent under COPPA to the collection of a child’s information on the parent’s behalf. Pursuant to our User Agreement, CZI will not collect personal information from a child under the age of 13 unless that child's teacher, school, or school district (hereinafter collectively referred to as “educational institution”), acting as the parent’s agent, has provided the required consent.
In order for CZI to rely on consent obtained from a child’s educational institution instead of the parent under COPPA, CZI must provide the educational institution with the same type of direct notice regarding its practices as to the collection, use, or disclosure of personal information from children as it would otherwise be required to provide to the parent, as follows:
CZI relies on educational institutions to consent under COPPA to the collection of a child’s information on the parent’s behalf; to collect the contact information needed to obtain parental consent; and to provide the means by which parental consent can be obtained regarding the collection, use, and disclosure of such information.
CZI intends to collect personal information from students, including children under the age of 13, but only to the extent that is reasonably necessary to enable students to participate in a Render co-building opportunity (including accessing and using a Render tool). CZI requires parental consent or school authorization for the collection, use, and/or disclosure of any child’s personal information. CZI will not collect, use, or disclose any personal information from a child if parental consent or school authorization is not provided.
If such consent is provided, CZI may collect the following personal information from the child:
Username or unique identifier;
Email address (optional, if the educational institution so chooses);
First and last name (optional, if the educational institution so chooses);
Parent or guardian name and email address (optional, if the educational institution so chooses);
Associated grade level, class names, and teacher names;
Student in-app performance data and usage data;
Student generated content including writing, pictures, assignments, quiz responses, etc (if applicable);
Content and files, and video & audio recordings (if applicable);
IP addresses for messages and comments.
Device information and identifiers;
Communications to teachers from within the application (if applicable);
Conduct or behavioral data input by teachers or school staff (if applicable);
We may use the Students’ personal information to determine the Student’s eligibility for a co-building opportunity; communicate with the Student about such co-building opportunities (such as instructions for participation); analytics about the Render tool usage (if applicable); provide support; and more. For more details, please see Section 2 of our Privacy Policy. Further, a Student’s information may be shared within their school environment (i.e., the Student’s teacher(s) and school leader); with their Caregiver (pursuant to school policy); and with service providers (but only to support Render).
Specifically, CZI stores the following information that educational institutions and students may choose to share within the school environment:
Student name;
Student email address;
Student activities within a Render tool;
School and class information;
Messages and comments within the Render tool (if applicable)
Upon request from the educational institution, CZI will provide a description of the types of personal information collected; an opportunity to review the child’s personal information and the right to have the information deleted; and the opportunity to prevent further use or online collection of a child’s personal information. For more information on our privacy practices, please see our Privacy Policy.
If such personal information is collected without Caregiver consent or collected beyond the scope needed for participation in Render, and if we become aware that such information, we will delete it within thirty (30) days of such awareness, or as directed by applicable law, or seek to obtain the appropriate consent to keep it if permitted by law, or if it is reasonably necessary for the Render co-building opportunities. If you believe that information from a student under the age of 13 has been provided in violation of these terms, please contact us at privacy@buildwithrender.org.
As a best practice, CZI recommends that educational institutions make this notice available to parents so that they may review the personal information collected.
Please feel free to contact CZI with any questions or concerns at privacy@buildwithrender.org.