Under the United States’ Children’s Online Privacy Protection Act (“COPPA”), online service providers such as Classtime Inc. (“Classtime”) must obtain verifiable parental consent before collecting, using, or disclosing personal information from children under the age of 13, except in limited situations.
COPPA allows for teachers, schools, and school districts (each, a “Local Education Provider”) to act as agents to parents and consent on the parents’ behalf to the collection, use, and disclosure of personal information of children under the age of 13. Classtime will not collect, use, or disclose personal information from a child under the age of 13 unless that child's Local Education Provider, acting as the parent’s agent, has agreed to Classtime’s collection of personal information from that child.
In order for Classtime to rely on consent from a Local Education Provider, Classtime must provide the Local Education Provider with the same type of direct notice regarding its collection, use, and disclosure of personal information from children as it would otherwise be required to provide to parents.
Classtime intends to collect and disclose the personal information of children under the age of 13 as follows:
Personal Information Classtime Intends to Collect from Children
Classtime may collect the following personal information from children as necessary to provide the Classtime platform and communicate with the children about the Classtime platform:
- IP addresses
- Basic browser information
- Profile information, either provided directly by the student or imported from third-party services that the student’s teacher chooses to integrate into the Classtime platform (like Google Classroom, Clever, or Microsoft Teams): username (which may be a pseudonym), and, if applicable, name, email, student picture, preferred language
- Personal information that the student may include in answers submitted through the Classtime platform
- Student login information and activities the student participates in on the Classtime platform
- All classes that the student is affiliated with (as designated by the student’s teacher(s))
- Cookies for storing authentication tokens and preferred language
Disclosure of Personal Information
Classtime may disclose personal information that it collects in the following circumstances:
- Information that students submit through the Classtime platform will be viewable by the teacher(s) administering the relevant activity on the platform.
- Our affiliate, Classtime AG, provides certain data processing and customer-management services on our behalf. As part of those services, Classtime AG engages third parties to perform certain business-related functions (each, a
“Vendor”), including but not limited to IT (such as maintaining databases, sending messages, providing and developing certain service functions, maintenance, and security), payment, billing, and collection. Classtime AG only provides each Vendor with the information it needs to perform its specific function.
- Classtime and its affiliate may disclose collected information if and to the extent necessary to (i) comply with a legal obligation, (ii) protect and defend Classtime’s or its affiliate’s rights or property or the rights or property of Classtime’s users (including, without limitation, against liability claims), or (iii) protect the security or integrity of Classtime’s services.
- Classtime and its affiliate may share personal information with third parties to whom the entity transfers its business or parts thereof or with whom the entity merges.
How to Provide Consent On Behalf of Parents
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