Children’s Privacy Policy Highlights

We believe you should always know what data we collect from your child, how we use it, and that you should have meaningful control over both. We wanted to empower users to make the best decisions about the information that they share with us about their children. In fact, we made a short video for children that highlights the most important details in our Services Privacy Policy and Children’s Privacy Policy that they should know about.

This Children’s Privacy Policy applies solely to the Dojo Tutor Services (defined in the Services Privacy Policy). Our full Services Privacy Policy for all users is located here. Additionally, if your child is using our ClassDojo Main Services product, please find the ClassDojo Main Services Privacy Policy located here.

You should read this policy in full, but here are the highlights:

• Personal Information We Collect: Please see this page where we detail the personal information we collect from each child, including the sources from which the information was collected, the business purpose for which the information was collected, and the third parties with whom we share or disclose personal information for a business purpose. You can also find more details below.

• How We Use the Information We Collect: We use the personal information we collect from learners (or about learners from tutors or their parents) to provide and improve (as allowed by law) the Service, for educational purposes, security, and safety purposes, including enforcing our Terms and addressing offensive content (including with the information collected through a learner’s customer service reporting), to comply with legal process or other laws or as allowed by law. We will not require learners or children to provide more personal information than is reasonably necessary to participate in the Service. See below for more information on our use of information collected from learners and children.

• Data Retention: We will not retain learner or children's personal information for any longer than is reasonably necessary to fulfill the purpose for which the information was collected, including, to provide and maintain the Service for which we receive or collect the learner personal information, keep our platform safe and secure, or to comply with legal obligations. We also protect learners with our industry-leading policy of deleting learner’s accounts that are inactive for more than twelve months. Additionally, some information is deleted or de-identified automatically after a set period of time. Please see below for more information.

• No Learner’s or Children's Information is Shown Publicly: No children’s or learner’s account or profile is made available or visible to the general public through the Service. For a list of what logged-in learner users’ information can be viewed by other logged-in Dojo Tutor Service users, please see our FAQ.

• We Never Sell Personal Information: We will never sell or rent your learner’s or children’s personal information or non-personal information. We will only disclose personal information as set forth in the Services Privacy Policy (including the below Children’s Privacy Policy), such as with a limited set of third-party service providers necessary to provide or develop our Services (such as database hosting) or as required by law, and we will be transparent about who these service providers are.
  We will contractually require that these service providers process personal information in accordance with our instructions and consistent with this Children’s Privacy Policy. We ensure that these service providers employ reasonable and comprehensive data protection and security protocols. See here for more details.
  Consistent with applicable state and federal laws, in connection with such a change to our organization where personal information that we have collected from users would be one of the assets transferred or acquired, our Privacy Policy and the below Children’s Privacy Policy, will continue to apply to your child or learner’s information, and any acquirer would only be able to handle your personal information as per these policies (unless you give consent to a new policy).

• We Never Use Learner or Children's Information for Behaviorally Targeted or Third-Party Advertising: Information collected from children or learners (including personal information and information collected automatically from areas designed for children to access) is never used or disclosed for third-party advertising. We also do not place any third-party advertisements in child or learner logged-in areas of the Service. Additionally, personal information collected from children and learners is never used for behaviorally-targeted advertising to children or learners by us or any third-party. We may present contextually relevant recommendations (which means not using children or learner personal information) for educational content for either our own products (e.g., Premium Features) or third-party products and services ourselves that we believe may be of interest to a learner or child (e.g., showing a child additional tutoring sessions for other school subjects they may be interested in).

• You own your data: We don’t own any content or information you provide or we receive — you (parents or your child) will own your learner content and information.

• Security and Privacy by Design and Default: We use security industry best practices to protect children’s personal information, including using encryption and other security safeguards to protect children' s personal information. We design products with security and privacy in mind from day one. See here for more information as well as our Security Overview and Privacy Center.

• Transparency and Choice: We tell you what data we collect, why we collect it, and how it’s used, retained, and shared with others. We are transparent about our practices so that you can make meaningful choices about how your personal information is used. If we make a material change, we will provide prominent notice by posting a notice on our Service or this website page and/or we will notify you by email (if you have provided an email address to us). See here for more information.

• Right to Access, Correction, and Deletion of Data: You can access, correct, and delete your personal information by contacting us at tutoring-privacy@classdojo.com, or you can use features in our account settings to do so. See here for more information on your or your child’s rights, including about any additional rights you or your child may have depending on the jurisdiction you reside in.

How Does Dojo Tutor Protect Children?

Protecting children’s privacy is especially important to us—we’re educators and parents ourselves, after all. This is why ClassDojo participates in the iKeepSafe Safe Harbor program. iKeepSafe’s has granted Dojo Tutor the COPPA Safe Harbor seal, signifying that this Website, Platform, and Apps have been reviewed and approved for policies and practices surrounding the collection, use, maintenance and disclosure of personal information from children are consistent with the iKeepSafe COPPA Safe Harbor program guidelines.

For more information about COPPA (as defined below) and generally protecting children’s online privacy, please visit OnGuard Online.

We’ve also made a short video for children and learners that highlights the most important details in our Privacy Policy that they should know about.

This Children’s Privacy Policy explains our information, collection, disclosure, and parental consent practices with respect to information provided by children, and uses terms that are defined in our general Services Privacy Policy. For our full Services Privacy Policy, please see here. Any terms not defined in this Children’s Privacy Policy are defined in the Services Privacy Policy. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act and its implementing regulations under the Children's Online Privacy Protection Rule (collectively, "COPPA"). COPPA protects the online privacy of children under the age of 13 (“child” or “children”). ClassDojo extends the U.S.-based COPPA consent protections in all jurisdictions, even if not legally required to do so to provide these privacy protective measures to children worldwide. If we rely on other legally applicable grounds for processing children's personal information (e.g. if we rely on legitimate interest in the European Union and the United Kingdom when acting as a Controller), we will still use the Federal Trade Commission’s (FTC) COPPA consent methods described to provide further transparency and privacy protections for both for parents and schools.

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Dojo Tutor is certified COPPA-compliant by iKeepSafe. ClassDojo extends the U.S.-based COPPA consent protections to all jurisdictions, even if not legally required to do so to provide these privacy protective measures to children worldwide.

What Information Does Dojo Tutor Collect from Children?

We collect two types of information from children: (1) information that children voluntarily provide us by using the Services (described below under “Information Children Provide to Us”) and (2) information collected automatically as result of children’s use of the Services (described below under “Information We Collect Automatically”). We also collect certain information about children from their tutor or parent as described below under the “Information Collected About the Child from Parents and Tutors Combined with Children’s Data”.

The statements we make regarding the information we collect from or about learners and children using Dojo Tutor and how we use this information applies equally to all children and learners regardless of their age. Accordingly, where this Privacy Policy references learners or any information collected from or about learners, our Privacy Policy applies to learners under 13 years old as well as learners 13 years old and above.

Information Children Provide to Us

Dojo Tutor collects the minimal amount of information from children and learners necessary to register for an account on or otherwise use the Service. Additionally, Dojo Tutor will not condition a child or learner’s participation in an online activity on the Service on a child providing more personal information than is reasonably necessary in order to participate in the Service. If we discover that we have collected information from a child in a manner inconsistent with COPPA, we will take appropriate steps to either delete the information or immediately seek the parent's consent for that collection. This information is necessary to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the Service and for security and safety purposes.

For more detail on the categories of personal information collected from learners, as well as the sources from which the information was collected, the purposes for which the information was collected, and the categories of third parties with whom we disclose such personal information for a business purpose please see our Information Transparency chart. In addition, please see our Mobile App Permissions chart for more detail on our mobile app permission.

We collect information from your child in the following ways:

Learner Account Creation

Currently, learners access the Services through a parent setting up the learner’s account and/or giving their child access to the Services through the parent’s device (“Learner Account”). When a parent sets up a Learner Account for their child, they will first need to create a parent account and then they must provide certain information about their child which is necessary to allow their child to participate in the Services (e.g., child’s name, grade level, tutoring subject, languages spoken). Parents with an existing ClassDojo Main Services account may alternatively log in or create a new Dojo Tutor parent account using their ClassDojo Main Services account login credentials and certain information, which may include Student Data, that you elect to share with Dojo Tutor, as noted below, will be shared from your ClassDojo Main Service account. The Dojo Tutor parent account will then be accessible through their existing ClassDojo Main Services account portal as well. In accordance with COPPA, we may ask the parent to provide the date of birth or age of their child, and if the child is under 13, we will also then seek to obtain verifiable parental consent in order to proceed with creating their child’s account or otherwise allowing their child to use the Service. The parent may choose to provide additional information - as set forth in the “Parents about their child” section below. Although not required under COPPA, we may at our discretion choose to impose parental consent requirements on learners ages 13 and above.

Tutoring Session Information

• Session Details: Information collected from both learners and tutors such as tutoring subject areas, tutoring attendance and how long participants stayed in Zoom (as reported from Zoom). The attendance data is shown to both the tutor and learner (to confirm they are following the attendance policy) and may also be shown to parents and other designated third parties with the learner’s or parent’s permission.

• Zoom Recordings: Certain information is captured by Zoom through your child’s participation in a tutoring session such as your child’s image, voice, movements, and other audio information as well as chat logs or other information provided during the tutoring session. We obtain this information through accessing recordings or reports from Zoom. Dojo Tutor currently uses the Zoom ISV Program to host its tutoring sessions, but has a Data Protection Addendum and other contracts in place with Zoom that allow for users under 13 and also under which Zoom has agreed to apply its Education Account Settings to Dojo Tutor’s use of Zoom. This includes treating Dojo Tutor’s use of Zoom as an Education Account to apply the additional privacy, security and safety features and settings offered to schools to Dojo Tutor’s use of Zoom. See Zoom’s Children’s Educational Privacy Statement here. The tutoring sessions (including transcripts and Zoom chat logs) are recorded from both learners (your child) and tutors to ensure the safety and quality of tutoring on the Services as well as to provide and maintain the service (such as to create transcripts of the tutoring sessions or shorter video “clips” as set forth below). These recordings are automatically deleted by Zoom after 14 days (unless we are required by law to retain it, need it to ensure the security of our community or our Service, or to enforce our Terms). To learn more, read the Zoom Retention Policy. Separately, within the 14-day period in which Zoom retains these recordings, Dojo Tutor may either download, store and retain the recordings (or elect to have Zoom retain these) for so long as the Learner’s Account is active to display a library of past sessions to the parent, provide and maintain the service, conduct internal analysis, and keep our platform safe and secure. In addition, the Tutoring Highlight Clips as noted here, will be kept for only so long the Learner’s Account is active.

• Tutoring Session Transcripts: Dojo Tutor uses a service provider to create transcripts from the recorded tutoring sessions (“Tutoring Session Transcripts”). Dojo Tutor shares only the audio portion of the Zoom recordings of tutoring sessions between the learner and tutor with the service provider and ensures that the audio recordings are deleted by the service provideris. Additionally, we ensure that the audio recordings can not be used by the service provider for any other purpose. Dojo Tutor also ensures that the service provider can’t retain the Tutoring Session Transcripts for more than thirty (30) days, unless deleted earlier by Dojo Tutor. Dojo Tutor uses these Tutoring Session Transcripts (if a parent consents) to perform certain artificial intelligence (“AI”) related tasks, which includes using for internal trust and safety purposes, as is further described below and in our AI Transparency Note. In addition, Dojo Tutor uses the AI related tasks performed on the Tutoring Session Transcripts to create video “highlight” clips from the full Zoom session recordings (“Tutoring Highlight Clips”).

Messaging and Other Communications

Contents of communications between learners and their tutors - such as messaging within the Services or information the child may communicate with their tutor during a recorded tutoring session. If your child participates in a group tutoring session, the content of their communications may be exposed to and shared with the other children in their tutoring class.

Location Information

When a child or learner uses our Services or Website, we may collect and process information about their geographic location. We never request or collect precise location data (“precise” meaning sufficient to identify the street name and name of city or town) from learners and no learner location data is available publicly. From learners, the primary form of location data is based on IP Addresses as well as the non-precise location collected by Zoom as set forth here.

Conduct and Safety Information

If a user reports another user on the Service (e.g., such as through a “report abuse” button) for conduct or other safety issues, Dojo Tutor collects this information to investigate the report. Dojo Tutor collects the information provided in the report (e.g. the username, the content being reported (including a screenshot of the reported content or incident), the reason for reporting, and may also collect the timestamp, relevant tutor information (such as tutor session, tutor name, and tutor email). This information is used to investigate the report (e.g. assess and address offensive content) and to keep the platform safe and secure. Dojo Tutor may notify and share this information with parents if follow-up is necessary based on the information collected.

User Testing

We may conduct Zoom-recorded testing and interviews to gather insights on new Dojo Tutor features. To that end, we may collect minimal information from children needed for the tests, including device-specific information (as noted below), test session details (e.g., interaction data and feedback from participants), communication contents, general location, Zoom recordings, and related product and event logs. Zoom may also collect the following from the device: information about the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, WiFi information, and other device information (like Bluetooth signals). Please see Zoom’s Children’s Education Privacy Statement for more information. We also collect from the parent their name and email, as well as the name of their child.

Parents must be present for these playtests and interviews, provide COPPA consent, and sign a separate participant release before testing. We use this user testing data for internal analytics to improve Dojo Tutor’s features. We retain the data only as needed, and delete the recordings from Zoom after 14 days, but may retain the recordings on our servers (or elect to have Zoom retain these) for as long as necessary, but not indefinitely, to conduct the internal analysis or as allowed by law. The data is encrypted in transit and at rest, and shared only with necessary back-end service providers like Zoom.

Information Collected About the Child from Parents and Tutors Combined with Children’s Data

While not collected directly from your child, we also collect and receive from the child’s parent and tutor certain personal information about the child that they choose to provide as set forth below and link or combine this information to the child’s Learner Account.

Parent About Their Child:

• Name, which may be displayed to the tutor either on its own, or in a list with other learners assigned to the same tutor.

• Age or date of birth

• A unique username and password

• Education information you provide about your child, such as what grade level your child is in.

• You may optionally provide your child’s school name and location; whether your child was home schooled or went to a private or public school; and graduation year

• Qualitative description of how your child is doing and where they need the most help. This information is used by the tutor to plan their tutoring session.

• Interests of your child (e.g., art, basketball, dance, swimming). Dojo Tutor uses interests you provide about your child to personalize their tutoring experience and provide a more customized service (including, but not limited to tailoring lesson plans to their interests).

• Languages spoken

• Gender pronouns

• Extra support received or student IEP needs. This information is used by the tutor to tailor the lesson plan according to your child’s needs.

• Tutoring subject areas

• Shared Student Data. As mentioned above, parents with an existing ClassDojo Main Services account may alternatively log in or create a new Dojo Tutor parent account using their ClassDojo Main Services account login credentials and certain information, which may include Student Data, that you elect to share with Dojo Tutor, as noted below, will be shared from your ClassDojo Main Service account.

Tutors About Learners (i.e., your child):

• Tutor’s’ assessments of the learner’s performance: During the first tutoring session and over the course of additional sessions tutors will provide learners with both positive and constructive feedback that can further their learning (e.g., areas of strength or improvement) as well as recommended activities, resources and a work plan). In making these assessments, tutors may leverage the help of artificial intelligence generated from the Tutoring Session Transcripts, see “Artificial Intelligence (AI)-Generated Insights on Tutoring Session” section for additional information. Tutors may also edit and provide further human review of various AI Output generated in connection with assessments and the Tutoring Session Transcripts. Please see our AI Transparency Note for more detail. The feedback is shared with the learner and their parents through the Service, and may be shared by the parent to other individuals of the parent’s choosing, including their child’s teachers, but is not made available to the general public. A tutor’s assessment may also be shared automatically by Dojo Tutor (unless a parent opts-out) with new tutors assigned to a learner.

• Contents of communications between your child and their tutors: This communication may include messaging within the Services or information your child may communicate with their tutor during a recorded tutoring session.

• Tutoring attendance and how long participants stayed in Zoom (reported from Zoom).

• AI Tools. In addition to the AI processes described below that Dojo Tutor utilizes in connection with the Tutoring Transcripts and Non-Identifying Text-Based Information (as defined below), A tutor may choose to provide “inputs” (which may include personal information about a learner, to the Dojo Tutor AI tools used in connection with assisting tutors in providing the tutoring (“Dojo Tutor AI Tools”) to generate various tutoring Al-related content or “outputs”. For instance, the learner’s tutor might use the learner’s name and session summaries to generate lessons plans and activities for tutoring sessions. T. The content created through this process, including the AI-generated “outputs” from the Dojo Tutor AI Tools will only be shared with the learner’s parents (those individuals the parent chooses to share with), the learner, and the tutor. Dojo Tutor may also provide certain AI features to assist tutors with certain tasks not connected to the tutoring session itself (e.g to provide tutors with coaching or feedback) (“Dojo Tutor AI Productivity Tools”). Users of Dojo Tutor AI Productivity Tools may choose to provide inputs that may contain learner personal information. Dojo Tutor may also use certain AI Tools for its own internal use (“Dojo Internal AI Tools”) to provide features such as enhanced account security or to assist with customer service inquiries. The Dojo Tutor AI Internal Tools may use the Tutoring Session Transcripts, tutoring session videos and Non-Identifying Text Based Information, but will not otherwise use learner or children’s personal information provided or collected from a learner, but may include a learner’s personal information provided by a parent (e.g. in connection with customer service inquiries). For more information on the “input” and “prompts” used to generate the AI “outputs”, as well as the information shared with our Large Language Model (“LLM”) service providers, please see our AI Transparency Note.

Information We Collect Automatically

In addition to the information listed above, we automatically collect some information from any use of our Service as set forth below.

The device and application-related data we collect originates from the device and application being utilized to give the child access to Dojo Tutor accounts (e.g., the parent’s device if the child is utilizing the parent’s device, or the child’s device if they are logging in separately on their own device).

This includes:

• Cookies and other similar technologies: We may use first party cookies or similar technologies to identify your browser or device. We will never use third party technologies in children or learner logged in areas of our Service in connection with advertising of our Service or other third-party services. We don’t allow these third-parties to advertise directly on our Service (i.e., such as when an advertiser would bid to place an advertisement directly on a platform such as Facebook), but we may serve contextually relevant advertising (which means not using any personal information to make decisions) for third-party products and services ourselves that we believe may be of interest to the learner or child (e.g., tutoring for other subjects that your child might benefit from). Please read our Online Tracking Technologies Policy for more details on our first party cookies used in connection with children and learners, including how to modify your cookie settings and a list of the tracking technologies we use. We do not use advertising cookies or similar technologies in areas where learners or children are logged in to the Services, or on the Dojo Tutor Website where a learner or child user is directed to login to the dedicated child or learner login page.

• Local storage: We may also use, collect, and store information and preferences locally on your child’s device using mechanisms such as browser-based web storage (including HTTP cookies and HTML5) and application data caches.
  Like many services, Dojo Tutor (or our service providers) uses both local storage and cookies or similar technologies to analyze trends, gather demographic information about our users, understand your engagement with the Service and Website, administer the Service and Website, tailor the Service and Website for you, and to help the Service and Website work better for you - for example, by remembering your child’s language preferences or other information so that your child will not have to re-enter it during the next time they visit the Website or Services. Please read our Online Tracking Technologies Policy for more details.

• Device information: We collect device-specific information such as your child’s device type, device brand, operating system, hardware version and settings, device settings, file and software names and types, battery and signal strength, device tokens (to send push notifications), and device identifiers (including unique device IDs). We may also collect device event information such as crashes, system activity, browser type, browser language, the date and time of your child’s request and referral URL. This helps us measure how the Website and Service is performing, improve Dojo Tutor for your child on their particular device, and send you push notifications if you’ve opted in to receive them. Zoom may also collect the following from the device: information about the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, WiFi information, IP address (which may be used to infer general location at a city or country level) and other device information (like Bluetooth signals). Please see Zoom’s Children’s Education Privacy Statement for more information.

• Mobile application information: Certain mobile applications or “apps” include a unique application number. This number and information about your child’s installation (for example, the operating system type and application version number) may be sent to Dojo Tutor when you install or uninstall that application, such as when your child installs the Dojo Tutor App, when your child opens the application, or when that application periodically contacts our servers, such as for automatic updates. Additionally, we may receive application state and crash log information which will help us debug and improve the Dojo Tutor App.

• Server log information: Like most online services, when you use our Service or Website we automatically collect and store certain information in our server logs. Examples of what’s associated with these logs include things like:

  • Telephone log information like your phone number and SMS routing information
  • IP address
  • Feature used

  We may use your IP address and share it with third parties to help diagnose problems with our servers, for security purposes, and to manage the Service or Website, to manage the Services. Third party sharing of IP address information for analytics and advertising is not allowed for children or learners. We automatically deleted IP addresses tracked in server logs after six months.

• Location information: Please see above.

• Cross-device collection: To provide users with a seamless online experience, we may link your identifiers on different browsers and environments you are using. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.

• Product Events: As children interact with the Service or Website, we collect product events, including from the child’s device, about how the product is being used, which features are used, which buttons are clicked, load time, etc. This includes events such as the last activity a child started, whether a child viewed a certain report from their device, etc). These are collected to provide the Services and Website, including for internal analysis on product usage and quality. We may also use it to track progress in the Service and Website, and for sending push or email notifications to the child or learner’s device to encourage them to take certain actions in the Service (e.g. to start the next activity). Our product event logs may also include unique device IDs and IP addresses. We automatically delete IP addresses tracked in product logs after six months.

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Dojo Tutor has been certified by iKeepSafe, an FTC-approved COPPA Safe Harbor, for compliance with their COPPA Safe Harbor program. We don’t ask for or require children to provide personal information beyond that which is reasonably necessary to use Dojo Tutor. Please see this chart for the detailed categories of information we collect from each user type and how we use the information, as well as the sources from which the information was collected, the business purpose for which the information was collected and the third parties with whom we disclose personal information for a business purpose.

How Does Dojo Tutor Use the Information it collects from Children?

First and foremost, you should know that Dojo Tutor does not sell or rent any of your child’s personal information to any third party for any purpose – including for advertising or marketing purposes. Information collected from children and learners (including personal information and information collected automatically) is never used or disclosed for third-party advertising. Additionally, personal information collected from children is never used for behaviorally-targeted advertising to learners by us or any third-party. We may present contextually relevant recommendations (which means not using learner personal information) for educational content for either our own products (e.g. showing a reading course while taking a math course) or third-party products and services ourselves that we believe may be of interest to a learner (e.g. an online platform that may help your kid practice math). When acting as a Controller of personal information about children and learners, we process this information given our legitimate interest in providing the Service.

Dojo Tutor commits that its collection, use, retention, and sharing of personal information shall be reasonably necessary and proportionate to achieve the purposes for which the personal information was collected or processed and for the purposes disclosed in this Children’s Privacy Policy and Information Transparency Chart and that the personal information will not be further processed in a manner incompatible with these purposes.

We use the information we collect from children and learners as follows:

Non-AI Uses

In addition to the uses mentioned above, we use the information we collect from children and learners (or about children and learners from parents and tutors):

• To provide and improve (as allowed by law) the Service to the child, including administering our tutoring sessions, to send push notifications or other in-app notifications to your child (e.g., to encourage them to take certain actions in the Service)
• For internal analytics on product usage
• For educational purposes and as authorized by law
• To identify, fix and troubleshoot bugs and Service errors
• For security and safety purposes, including enforcing our Terms, and assessing and addressing offensive content (including with the information collected through a learners customer service reporting)
• To comply with legal process or other laws

Additionally, we use the information we collect from children and learners as set forth in our Information Transparency Chart.

Artificial Intelligence (AI) Uses

AI -Generated Insights on Tutoring Session Transcripts and Non-Identifying Text-Based Information About Learners

Dojo Tutor uses Tutoring Session Transcripts (text only) as well as on the additional limited text-based non-identifying information indicated in our Tutor AI Transparency chart (e.g. first name only, grade and tutoring subjects) (“Non-Identifying Text-Based Information”) as “inputs” to generate AI insights through the use of Large Language Model (“LLM”) AI service providers to provide this AI service (“LLM Service Providers”). At the specific direction and instruction of Dojo Tutor, these LLM Service Providers will process these Tutoring Session Transcripts and Non-Identifying Text-Based Information in order to obtain AI-generated insights on tutoring sessions between our learners and tutors (“AI Outputs”). This processing performed on the Tutoring Session Transcripts and Non-Identifying Text-Based Information is done through the use of DojoTutoring directed instructions known as “prompts” to the LLM Service Providers (e.g. “summarize the tutoring session”). To protect the privacy of users, Dojo Tutor does not share any direct identifiers of tutors or learners to the LLM Service Providers (except to the extent that any direct identifiers are included within the Tutoring Session Transcripts).

AI -Generated Insights on Additional Information Provided through Dojo Tutor AI Tools, Dojo Tutor AI Productivity Tools, and Dojo Internal AI Tools

Dojo Tutor will use the additional information provided by tutors through the use of Dojo Tutor AI Tools and Dojo Tutor AI Productivity Tools as well as information provided in connection with the Dojo Internal AI Tools as “inputs” to generate AI insights through the use of LLM Service Providers (“Additional AI Provided Information). At the specific direction and instruction of Dojo Tutor, these LLM Service Providers will process the Additional AI Provided Information in order to obtain AI-generated insights on tutoring sessions between our learners and tutors as well as in connection with trust and safety matters (“AI Outputs”). This processing performed on the Additional AI Provided Information is done through the use of DojoTutoring directed instructions known as “prompts” to the LLM Service Providers (e.g. “provide instances of possible safety issues”).

From both categories listed above, data obtained from the AI Outputs and inputs (e.g. the Tutoring Session Transcripts) may be accessed, processed and used by Dojo Tutor to provide, improve (as allowed by law) and maintain the Service, personalize user experiences, perform internal analysis (including to provide metrics and data logs or activity records needed for measuring up/down time and debugging the tools), and keep our platform safe and secure. For example, the Tutoring Session Transcripts will be sent to the LLM Service Providers to create automated tutoring assessments, point out areas of the session to then create Tutoring Highlight Clips, lesson summaries, and learning plans. To understand more about the specific “prompts” used to generate these AI insights, the “inputs” or information shared with the LLM Service Providers, and Dojo Tutor’s use of AI, please see our AI Transparency Note.

Dojo Tutor does not use any children’s personal information contained in any Tutoring Session Transcripts to train any Dojo Tutor’s AI Systems. Dojo Tutor will only train our AI Systems with data that has been de-identified in such a way that it is not traceable to any Dojo Tutor user. Additionally, Dojo Tutor does not allow any LLM Service Provider or other AI third-party service providers to use any information (personal information or de-identified) to train, improve or develop their AI Systems. This commitment includes the information contained in the charts detailed in this AI Transparency Note, such as the Tutoring Session Transcripts, used to provide the AI Outputs.

If you, as the parent or guardian that has previously provided consent for the use of your child’s personal information in connection with Dojo Tutor’s AI use, would like to prevent further use and delete this information, please see the section “Parental Choices and Controls” below.

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We use the personal information we collect from learners (or about learners from tutors or their parents) to provide and improve the Service, for internal analytics on product usage, for educational purposes, security and safety purposes, or as allowed by and to comply with the law. In addition, we work with service providers to derive AI-generated insights from Tutoring Session Transcripts and Non-Identifying Text-Based Information. We will not require learners to provide more personal information than is reasonably necessary to participate in the Service.

Personal information collected from children is never used or disclosed for third party advertising. We do not place any third-party advertisements in learner logged-in areas of the Service. Personal information collected from learners is never used for behaviorally-targeted advertising to learners by us or any third-party. We may present contextually relevant educational content (not using learner personal information) for either our own products or third-party products and services ourselves that we believe may be of interest to a learner (e.g., our showing a child additional tutoring sessions for other school subjects they may be interested in). Children’s personal information is never sold or rented to anyone, including marketers and advertisers.

Push Notifications

Dojo Tutor may send push notifications to learners. We require children to provide a parent’s email address before they can receive push notifications from Dojo Tutor (or have a Learner Account previously set up on Dojo Tutor by their parent with any necessary parental consent obtained). We will then provide the parent with notice (if the account was set up by them or their child) that the push notifications are being sent to their child. The device identifier for a child’s account will only be associated with other personal information once parental consent is provided. These push notifications may contain information about taking an action in the Service, such as the child completing a task or other product feature or informing the child their learning assessment has improved. If you are a learner or a parent of a child and no longer want these communications to be sent, please either turn off the push notifications on your device or contact us at tutoring-privacy@classdojo.com.

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We may send push notifications to learners, but require children to provide a parent’s email address before receiving those notifications so that we may provide the parent with notice, or we will have previously obtained the parent’s consent if the child has a Learner Account previously set up on Dojo Tutor by their parent.

Does Dojo Tutor Disclose Any Information it Collects From Children?

We do not disclose any personal information about children to third-parties, except to service providers necessary to provide the Service, other users as part of the Service (such as tutors), as directed or approved the child’s parents (including in connection with the sharing as set forth below), as required by law, or to protect the security of the Service or other users. You can visit our service providers page to see the list of third-party operators collecting or maintaining personal information from children through the Service, the purpose of such disclosure, as well as an indication on whether those service providers are integral to the Service. You may choose to agree to the collection and use of your child’s personal information, but choose not to allow disclosure to certain third parties (unless such disclosure is integral to the Service). For any non-integral third party disclosures, we will provide a separate consent box. Please contact us as set forth in the section “How Can I Contact Dojo Tutor with Questions” with questions about the operators’ privacy policies and collection and use practices. Additionally, at any time, you may also agree to the collection and use of your child’s personal information, but choose not to allow disclosure to certain third parties (unless disclosure is integral to the Service).

As allowed by applicable laws, we may share aggregate or de-identified information, which cannot reasonably be used to identify your child, with third parties for various purposes, including compliance with various reporting obligations; to demonstrate how the Service is used;; or to assist third parties in understanding our users’ interest in, habits on, and usage patterns for certain programs. For additional information on the limited other circumstances in which we disclose children's personal information, please see the "How We Share Your Personal Information" Section.

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We do not disclose any personal information about children to third-parties, except to service providers necessary to provide the Service, other users as part of the Service (such as tutors), as directed or approved by the child’s parents, as required by law, or to protect the security of the Service. As allowed by applicable laws, we may share aggregated or de-identified information, which cannot reasonably be used to identify your child, with third parties for various purposes, including compliance with various reporting obligations; to demonstrate how the Service is used; for business purposes; or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs. Additionally, at any time, you may also agree to the collection and use of your child’s personal information, but choose not to allow disclosure to certain third parties (unless disclosure is integral to the Service).

What Children’s Information is Visible to Others?

No Learner Account, profile or personal information of a child is made available or visible to the general public through Dojo Tutor and no child can use Dojo Tutor without parental consent. Dojo Tutor does now knowingly post any child’s personal information publicly online unless the child’s parent has explicitly chosen to do so. Any content uploaded by you, your child, or your child’s tutor (including tutor and learner comments, assessments, or Zoom video recordings of tutoring sessions) through the Service, can only be viewed by you, those you choose to share assessments (e.g. to your child’s teacher), feedback, reviews or any other tutoring information with, and your child’s tutor. While you may choose to share your tutoring information with others, please keep in mind that information (including your or your child’s personal information) or content that you voluntarily disclose to others - including to other Dojo Tutor or ClassDojo users you interact with through and outside of the Service (such as messages you might send other users or individuals you collaborate with (such as tutors, teachers, friends or family members) - can be viewed, copied, stored, and used by the individuals you share it with. Dojo Tutor cannot control the actions of people with whom you choose to share information and we are not responsible for the collection, use, or disclosure of such information or content by others.

If you choose to enroll your child in a group tutoring session, any other child or learner in that tutoring session will also be able to see your child’s first name as well as any information another learner in that group tutoring session may share during the session (including through the chat feature). For group tutoring sessions, please note that other children will not be able to view your child’s assessment or other tutoring information. Output generated by AI Systems will only be shared with you (those you choose to share with), your child, and your child’s tutor. For a complete list of what logged-in learner user’s information can be viewed by other logged in Dojo Tutor users, please see our FAQ.

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No Learner Account, profile or personal information of a child is made available or visible to the general public through Dojo Tutor. If you choose to enroll in a group tutoring session, your child’s first name might be visible to the other children enrolled in the group session. For group sessions, other children will not be able to view your child’s assessment or other tutoring information. Output generated by AI Systems will only be shared with you (those you choose to share with), your child, and your child’s tutor. For a list of what logged in learner user’s information can be viewed by other logged in Dojo Tutor users, please see our FAQ.

Dojo Tutor will not retain a child’s personal information for any longer than is reasonably necessary to fulfill the purpose for which the information was collected, including, to provide and maintain the Service, for which we collect the child’s personal information, perform internal analysis, keep our platform safe and secure, or comply with legal obligations. Additionally, we only keep a child’s personal information for as long as their Learner Account is active, unless we are required by law to retain it, need it to ensure the security of our community or our Service, or to enforce our Terms (which shall not include retaining indefinitely).

We determine the appropriate retention period for personal information on the basis of the amount, nature and sensitivity of the personal information being processed, the potential risk of harm from unauthorized use or disclosure of the personal information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitations). The time periods for which we retain children's personal information depend on the purposes for which we use it. Personal information associated with your child’s account will be kept until your child’s account is deleted or is inactive, unless we no longer need the data to provide products and services, in which case we will delete prior to you deleting your child’s account or your child’s account becoming inactive.

Specifically, we implement the following policies:

• Deleting inactive Learner Accounts: If a child’s Learner Account is inactive for twelve months or more (meaning no learner (or their parent on behalf of their child) has logged into the Learner Account within the last 365 days), Dojo Tutor will delete the Learner Account. Learn more about how we delete inactive Learner Accounts here. For more information on the deletion of content related to Learner Accounts, please see our FAQ.

• 14-day deletion policy for tutoring session Recordings: To protect learners, Dojo Tutor sets limits on how long the Zoom recordings of tutoring sessions are maintained. These recordings are automatically deleted after 14 days by Zoom, unless we are required by law to retain it, need it to ensure the security of our community or our Service, or to enforce our Terms. The Zoom video recordings are stored on Zoom’s hosting provider’s servers. To learn more, read the Zoom Retention Policy.

• Retention policy for tutoring session recordings in the Service: Separately, within the 14-day period in which Zoom retains these recordings, Dojo Tutor may either download, store and retain the recordings (or elect to have Zoom retain these) for so long as the Learner’s Account is active to display a library of past sessions to the parent, provide and maintain the service, conduct internal analysis, and keep our platform safe and secure. In addition, the Tutoring Highlight Clips as noted here, will be kept for only so long as the Learner Account is active.

• Tutoring Session Transcripts: The audio only portion of Zoom recordings of tutoring sessions are deleted by theretained only transiently by the service provider and deleted immediately upon creating the Tutoring Session Transcripts. Additionally, Dojo Tutor ensures that its service provider can’t retain the Tutoring Session Transcripts for more than thirty (30) days, unless deleted earlier by Dojo Tutor. Dojo Tutor then receives and retains the Tutoring Session Transcripts for only as long as the Learner’s Account is active, unless we are required by law to retain them, need them to enforce our policies or to ensure the security of our community.

• Artificial Intelligence Input and Output: Your child's data (or you if you are a tutor) used to provide the “inputs” (e.g., the Tutoring Session Transcripts) may be transiently retained by the LLM Service Providers to provide the Service to Dojo Tutor. Additionally, any AI Outputs may also be transiently retained by the LLM Service Providers after performing the processing on the “inputs” (e.g,. the Tutoring Session Transcripts) to provide the Service to Dojo Tutor. Dojo Tutor has entered into a specific contract with the LLM Service Providers for “zero data retention” beyond this transient retention for the Dojo Tutor-provided AI tools mentioned above. This means that the prompts, inputs, and outputs (1) will not be logged for human review by the LLM Service Providers and (2) will not be saved to disk or retained by the LLM Service Providers. Note, however, that the LLM Service Providers may perform automated screening of the inputs and prompts for safety purposes (the “Safety Classifiers”), which shall consist solely of metadata (including classifier types, dates, counts, and confidence scores) and shall not include any inputs, prompts, or outputs themselves (including summarizations of prompts, inputs, or outputs) or any portion thereof. LLM Service Providers may retain data from Safety Classifiers. Dojo Tutor then receives and retains this AI Output for only as long as the Learner’s Account is active unless we are required by law to retain it, need it to enforce our policies or to ensure the security of our community.

Please see our Information Transparency chart and AI Transparency chart for more details on specific retention periods. Additionally, for more information on the deletion of content related to Learner Accounts, please see our FAQ. Please keep in mind that the deletion by our service providers may not be immediate and the deleted information may persist in backup copies for a reasonable period of time.

We may retain de-identified information for as long as we deem appropriate or as otherwise allowed by law.

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We will not retain a child’s personal information for any longer than is reasonably necessary to fulfill the purpose for which the information was collected, including to provide and maintain the Service for which we receive or collect the child’s personal information,perform internal analysis, keep our platform safe and secure, or comply with legal obligations.

We only keep a child’s personal information for as long as the account is active, unless we are required by law to retain it, need it to enforce our policies or to ensure the security of our community.

Additionally, we protect children and learners with the additional policies: (1) we require Zoom to automatically delete tutoring session Zoom recordings after 14 days (unless noted above), (2) within this 14-day retention period, Dojo Tutor may either download, store and retain the recordings (or elect to have Zoom retain these) for up to an additional 30 days to provide and maintain the service, conduct internal analysis, and keep our platform safe and secure, and (3) Dojo Tutor deletes Learners’ Accounts if they’re inactive for more than twelve months. Please see our Information Transparency chart and AI Transparency chart for more details on specific retention periods.

Parental Choices and Controls

At any time, you have the right to:

• Access, review and correct your child's information
• Direct us to delete your child’s personal information
• Refuse to permit us to collect further personal information from your child and request that we delete the personal information that we have already collected from your child
• Agree to the collection and use of your child’s personal information, but choose not to allow disclosure to certain third parties (unless disclosure is integral to the Service)

Please keep in mind that a request to delete information or a refusal to permit disclosure of the information to third parties may affect your child’s ability to access the Services or use certain features. To exercise any of these rights, please see below.

Access, Correction, and Deletion Rights under COPPA

We support access to, correction, and deletion of your children’s personal information by directly responding to requests from parents or legal guardians. You may access, review, correct, or delete any of your child’s personal information in the Service by contacting us at tutoring-privacy@classdojo.com once you are signed into your parent account or by emailing tutoring-privacy@classdojo.com with the same email used to create your parent account. In addition to the choices provided to you as a parent under COPPA, you may also have certain rights relating to your personal information, subject to local data protection laws and the jurisdiction you reside in. See the “Dojo Tutor’s Commitments to Providing Transparency and Your Rights?” Section in our Services Privacy Policy for more information on your rights.

We will use commercially reasonable efforts to process such requests in a timely manner consistent with applicable law. We will need to verify your identity, for example by requiring that you provide acceptable forms of personal identification as set forth in our FAQ.

When you delete your child's account, we delete the content or personal information uploaded as set forth in our FAQ. For additional information on what happens when an account is deleted, please see our section “What happens when I delete my account (Tutoring).”

Stop Collecting Further Personal Information or Restrict Disclosure under COPPA

Additionally, at any time, for Learner Accounts, you can refuse to permit us to collect further personal information from your child by emailing tutoring-privacy@classdojo.com from the same email used to create your parent account or by contacting at tutoring-privacy@classdojo.com once you are signed into your parent account and request that we delete the personal information that we have already collected from your child as set forth above. Please keep in mind that deleting records may require us to terminate the account in question.

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We believe parents who have set up their child’s Learner Account, or otherwise allow their child access to the Service, should always be able to review their child's account, request for us to delete their child’s personal information, obtain a copy of their child's personal information, or stop us from further collecting their personal information. Just email us at tutoring-privacy@classdojo.com from the same email used to create your parent account or contact us at tutoring-privacy@classdojo.com once you are signed into your parent account and we’ll be happy to help. In addition to the choices provided to you as a parent under COPPA, you may also have certain other rights relating to your personal information, subject to local data protection laws and the jurisdiction you reside in. See our Dojo Tutor’s Commitments to Providing Transparency and Your Rights” Section in our Services Privacy Policy for more information on your rights.

How Does ClassDojo Obtain Consent

Dojo Tutor follows the U.S. FTC COPPA rules for parental consent. More detail on how Dojo Tutor obtains parental consent and what type of parental consent is used can be found in our FAQ. Although not required under COPPA, we may choose to impose parental consent requirements on Learner Accounts 13 and above at our discretion. ClassDojo extends the U.S.-based COPPA consent protections in all jurisdictions, even if not legally required to do soto provide these privacy protective measures to children worldwide. If we rely on other legally applicable grounds for processing children’s personal information (e.g. if we rely on legitimate interest in the European Union and the United Kingdom) when acting as a Controller, we will still use the FTC COPPA consent methods described above to provide further transparency and privacy protections for both parents and schools.

Parents may choose to link their ClassDojo Services account with a Dojo Tutor account. If a parent signs up for Dojo Tutor using their ClassDojo account, ClassDojo may share and use the parent’s ClassDojo Services login credentials (e.g., ClassDojo email address, user name) and their child’s name (and possibly other limited fields of Student Data or personal information of the child that the parent allows) to pre-populate the parent’s Dojo Tutor profile. Parents will have been prompted with Direct Notice of, and will have consented to that use and sharing of your child’s Student Data and personal information for this use on their ClassDojo Services account. While the child’s personal information (e.g., name) and tutoring information (e.g., tutoring assessments) will be linked and accessible in both the parent’s Dojo Tutor and ClassDojo Services accounts, the child’s Student Account information on ClassDojo will remain separate and viewable only through the parent’s ClassDojo Services login, ensuring that school information remains segregated and separate from non-school information.

Additionally, certain Dojo Tutor tutoring information, such as tutor assessments, feedback and other session information (e.g. session recordings) (“Dojo Tutor Information”) may be shared at the direction of the parent to their child’s teacher with the parent’s approval to the main ClassDojo Services (“Dojo Tutor Information Sharing”). When this Dojo Tutor Information Sharing occurs with the ClassDojo Services, a copy of the Dojo Tutor Information will be made to share. This is a copy of the assessment and only this copy will become Student Data once the teacher has elected to save and bring this information into either their account or the student’s Student Account in the main ClassDojo Services. The child’s Student Account information on ClassDojo will remain separate, ensuring that school information remains segregated and separate from non-school information. For more information, please see our FAQ.

While Dojo Tutor may match the teacher’s first and last name, school information, and email address from an existing in-school ClassDojo Services account to enable the Dojo Tutor Information to be shared, Dojo Tutor will not make this Dojo Tutor Information downloadable to the teacher or accessible in any in-school ClassDojo account unless the Dojo Tutor Information was shared at the direction of (or by) the parent, nor will it treat such Dojo Tutor Information as an education record or student data under the Family Educational Rights and Privacy Act of 1974 (“FERPA”) until such time as Dojo Tutor has entered into a contractual relationship to provide such Dojo Tutor Services to the school or district.