COPPA DIRECT NOTICE TO EDUCATIONAL INSTITUTIONS
Updated on:
Jul 1, 2024
At Edpuzzle, safeguarding student’s privacy, ensuring compliance with applicable regulations, and
upholding the utmost privacy standards in our practices of collecting, using, or disclosing personal
information from students are pivotal to our mission.
We hope this Direct Notice to Educational Institutions (“Notice”) is drafted in clear and understandable
language for you. Our hope is also that providing it in a Q&A format is helpful. If you have any questions or
concerns when reviewing this Notice, please feel free to contact us at [email protected] or at:
EDpuzzle, Inc.
833 Market St., Suite 427
San Francisco, CA 94103
In our commitment to protecting children's privacy, Edpuzzle participates in the FTC-approved COPPA
“Safe Harbor” Program from iKeepSafe, and has been granted the iKeepSafe FERPA, COPPA and CSPC
seals signifying that our website and apps have been reviewed and approved for having policies and
practices surrounding the collection, use, maintenance and disclosure of personal information from
children consistent with the iKeepSafe FERPA, COPPA and CSPC programs guidelines. Additionally,
Edpuzzle is also a signatory of the Student Privacy Pledge, agreeing to a set of principles intended to
safeguard student privacy, including responsible stewardship, protection, and transparent handling of
student personal information.
● Why are we providing you with this Notice?
● What are some highlights on how Edpuzzle collects, uses and/or discloses student data?
● What student data does Edpuzzle use to provide the service?
● For what purpose/s does Edpuzzle use student’s personal information?
● Does Edpuzzle disclose student personal information to third parties?
● Does Edpuzzle use or share student personal information for commercial purposes not
related to the provision of the Edpuzzle service requested by the Educational Institution?
● How can an Educational Institution review students’ personal information?
● How can Schools exercise their right to delete students’ personal information?
● What measures does Edpuzzle take to protect the security, confidentiality, and integrity
of student personal information collected?
● What are Edpuzzle’s data retention and deletion policies for student’s personal
information?
● Do you have to share this Notice with parents?
● Where can you find additional information on our privacy practices?
● How can you contact Edpuzzle with any questions or concerns?
Why are we providing you with this Notice?
In the United States, the Children’s Online Privacy Protection Act (COPPA) requires online service
providers like Edpuzzle, to obtain verifiable parental consent and provide parents with a direct notice
before collecting, using, or disclosing personal information from children under the age of 13, except in
limited scenarios. Such a limited scenario takes place when using Edpuzzle in an educational context (i.e.
using Edpuzzle for the use and benefit of the school and for no other commercial purpose). In this
educational context, the Federal Trade Commission (FTC) allows educators, schools, and school districts
(collectively “School/s” or “Educational Institution/s”) to act as the parent’s agent and consent to the
collection of students’ personal information on the parent’s behalf.
In order for Edpuzzle to rely on consent obtained from Educational Institutions instead of parents,
Edpuzzle must provide Educational Institutions 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
provide to the parent. This process ensures that educators are fully informed under COPPA requirements
when they use Edpuzzle for educational purposes.
This Direct Notice to Educational Institutions meets the COPPA requirements outlined above and provides
you with important information regarding Edpuzzle’s practices when collecting, using, and/or disclosing
personal information from students.
What are some highlights on how Edpuzzle collects, uses and/or discloses student data?
Here are some key aspects that underpin our commitment to privacy, especially regarding the collection,
use, and disclosure of student’s personal information:
● Edpuzzle collects the minimal amount of information from students necessary to create
accounts in our service.
● Edpuzzle does not sell or rent students' personal information (or of any of its users, for that
matter) to any third party for any purpose, including for advertising or marketing purposes.
● No student’s profile is made available or visible to the public, or to any other students, through
Edpuzzle. Furthermore, student accounts cannot interact with other student accounts, nor can
they interact with social media/networks. Interaction of student accounts is limited to interaction
with their teacher.
What student data does Edpuzzle use to provide the service?
Please see the table below, based on the “National Data Privacy Agreement v2” from Access 4 Learning
Community / Student Data Privacy Consortium (A4L/SDPC).
Category of Data
Data Elements
Used by Edpuzzle
Application Technology MetaData
IP addresses, use of cookies, etc.
✓
Other application technology metadata
Application Use Statistics
Metadata on user interaction with
application
✓
Assessment
Standardized test scores
Observation data
Voice recordings
✓
Other assessment data
Attendance
Student school (daily) attendance data
Student class attendance data
Communication
Online communication captured (emails,
blog entries)
Conduct
Conduct or behavioral data
✓
Demographics
Date of birth
Place of birth
Gender
Ethnicity or race
Language information (native, or primary
language spoken by student)
Other demographic information
Enrollment
Student school enrollment
✓
Student grade level
✓
Homeroom
Guidance counselor
Specific curriculum programs
Year of graduation
Other enrollment information
✓ (Subject: e.g.
mathematics)
Parent/Guardian Contact Information
Address
Email
Phone
Parent/Guardian ID
Parent ID (created to link parents to
students)
Parent/Guardian Name
First and/or last
Schedule
Student scheduled courses
Teacher names
✓
Special indicator
English language learner information
Low income status
Medical alerts/health data
Student disability information
Specialized education services (IEP or
504)
Living situations (homeless/foster care)
Other indicator information
Student contact information
Address
Email
✓(student email is
only collected when
using Edpuzzle
through an LMS
integration or Single
Sign-On solution)
Phone
Student identifiers
Local (School district) ID number
State ID number
Provider/App assigned student ID
number
✓
Student app username
✓
Student app passwords
✓
Student name
First and/or last
✓
Student In App Performance
Program/application performance
(typing program- student types 60 wpm,
reading program-student reads below
grade level)
✓
Student Program Membership
Academic or extracurricular activities a
student may belong to or participate in
Student Survey Responses
Student responses to surveys or
questionnaires
✓
Student Work
Student generated content; writing,
pictures, etc.
✓
Other student work data
Transcript
Student course grades
✓
Student course data
✓
Student course grades/ performance
scores
✓
Other transcript data
Transportation
Student bus assignment
Student pick up and/or drop off location
Student bus card ID number
Other transportation data
Other data collected
For data obtained from LMS integrations
please consult Edpuzzle's Privacy Policy
at https://www.edpuzzle.com/privacy
under the "Information Collected
Automatically" section
✓
Interface language preference
(customizable by the user through their
account settings page)
✓
None
No Student Data collected at this time.
Provider will immediately notify LEA if
this designation is no longer applicable.
Please note that Edpuzzle also offers teachers the possibility to use the “Open Class feature” that allows
students to use Edpuzzle without providing personal information.
For what purpose(s) does Edpuzzle use student’s personal information?
Personal information is collected to provide the service. More specifically, student data is collected for
the following purposes:
● To create the necessary accounts to use the service.
● To provide teachers with analytics on student progress.
● To send in-app and push notifications to users, if applicable (e.g., by letting students know if an
assignment is due soon).
● To assess the quality of the service and improve it.
● To secure and safeguard personal information and our community.
● To comply with applicable laws and regulations.
Does Edpuzzle disclose student personal information to third parties?
Disclosure of children's personal information is limited to third-party service providers necessary for
delivering our services, as allowed by law, or to ensure the security of the service and its users. For an
up-to-date list of our third-party service providers, please consult our Privacy Policy at
https://edpuzzle.com/privacy.
Does Edpuzzle use or share student personal information for commercial purposes not related to the
provision of the Edpuzzle service requested by the Educational Institution?
No.
How can an Educational Institution review students’ personal information?
Educational Institutions are in control of student data and as such, Schools may request Edpuzzle to
review or edit student data.
How can Schools exercise their right to delete students’ personal information?
Edpuzzle will delete student personal information upon written request from the Educational Institution. In
the absence of such a request, Edpuzzle will automatically delete student personal information when no
longer needed for the purposes for which it was received, which will be deemed to occur upon eighteen
(18) months of student-user account inactivity. Please note that deletion will not comprise (i) student data
that has been de-Identified or (ii) backups of student data that are part of our disaster recovery storage
system (we may retain backups for an additional term of six months).
What measures does Edpuzzle take to protect the security, confidentiality, and integrity of student
personal information collected?
● Pseudonymization and encryption: TLS v1.2 and v1.3 for all data in transit between clients and
server and AES256-CBC (256-bit Advanced Encryption Standard in Cipher Block Chaining mode)
for encrypting data at rest.
● Password protection.
● Ensure the ongoing confidentiality, integrity, availability and resilience of our processing systems
and services.
● Restore the availability and access to personal data in a timely manner in the event of a technical
incident.
● Regularly test, assess and evaluate the effectiveness of technical and organizational measures
ensuring the security of the processing.
What are Edpuzzle’s data retention and deletion policies for student’s personal information?
We only keep student personal information for as long as the student account is active, unless (i) we are
required by law to retain it, (ii) we need it to ensure the security of our community or our service, or (iii) we
need it to enforce our Terms of Service.
As mentioned above:
● student data will be deleted upon written request from the School or, in the absence of such a
request, when no longer needed for the purposes for which it was received, which will be deemed
to occur upon eighteen (18) months of end-user account inactivity.
● deletion will not comprise student data that has been de-identified or backups of student data
that is part of our disaster recovery storage system (which we may retain for an additional term of
six (6) months).
Do you have to share this Notice with parents?
As a best practice, Edpuzzle recommends Educational Institutions to provide parents with this Notice so
they can review the personal information collected.
Where can you find additional information on our privacy practices?
Please see our Privacy Policy at https://edpuzzle.com/privacy.
How can you contact Edpuzzle with any questions or concerns?
Please feel free to contact us at EDpuzzle, Inc., 833 Market Street, Suite 427, San Francisco, California
94103, or by email at [email protected].
Please note that this Notice does not constitute legal advice, and Edpuzzle recommends you seek
guidance from the School’s designated legal counsel if you have any concerns or inquiries regarding
compliance with COPPA.
