Coderz
Family Educational Rights and Privacy Act Policy
Intelitek, Inc. (the “Company“, “we“, “us” or “Intelitek“) does not maintain, and will not agree to accept, student educational records in any form on behalf of schools, educational institutions, or other clients of the Company.
Nonetheless, there may be instances in which students’ personally identifiable information (“PII”) is provided by Intelitek’s clients to the Company as part of signing up for or using our Coderz™ site and Coderz application (the “Application”). This Family Educational Rights and Privacy Act Policy explains our collection, transparency, and data security policies with respect to such PII, and uses terms that are defined in our general Privacy Policy. This policy is in accordance with the Family Educational Rights and Privacy Act Policy (“FERPA”), and outlines our practices in the United States regarding students’ PII.
What Information is Collected and How it is Used
In registering students for the Application, schools may provide the Company with students’ basic identifying information, such as student name, contact information, and birth dates (for purposes of age validation). In addition, the App may generate metadata or user content, which in some instances may be considered PII if it can be used to identify students indirectly (see “Persistent Identifiers”, below).
In any instance that we collect PII, we will use such PII only for the purposes for which it was provided by our FERPA-regulated clients. PII will not be used for marketing new products or services to the student, targeting individual students with directed advertisements, selling the information to a third party, or any other purpose prohibited by state or federal law.
Intelitek may, in a manner consistent with FERPA, use de-identified PII provided by a school for product development, research, or other purposes. In the event of such use, de-identified data will have all direct and indirect personal identifiers removed. This includes, but is not limited to, name, ID numbers, date of birth, demographic information, location information, and school ID. We will not attempt to re-identify de-identified data and not to transfer de-identified data to any party unless that party agrees not to attempt re-identification.
Persistent Identifiers
When students interact with us, certain information may automatically be collected, both to make the Application more interesting and useful to students and for various purposes related to our business. Examples include the type of computer operating system, the student’s IP address or mobile device identifier, the web browser, the frequency with which the student visits various parts of our sites or applications, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers.
This information may be collected by Intelitek or by a third party. This data is principally used for internal purposes only, in order to:
- provide students with access to features and activities on our sites and applications
- customize content and improve our sites and applications
- conduct research and analysis to address the performance of our sites and applications
- generate anonymous reporting for use by Intelitek.
The list of third-party operators who collect persistent identifiers on our sites and applications may be found here. Unless such data has been de-identified, it will not be used for any other purpose:
- Jaco Analytics – More information on their privacy terms can be found at https://www.getjaco.com/privacy.html
Please contact us at the mailing address, email, or phone number below with questions about the operators’ privacy policies and collection and use practices:
Intelitek
Attention: Management
18 Tsienneto Road
Derry, NH 03038
United States of America
Toll Free: 800-221-2763 / Phone: 603-413-2600 / Fax: 603-437-2137
Email: privacy@gocoderz.com
When Information Collected From Students Is Available To Others
Intelitek’s policy is not to use or re-disclose non-anonymized PII without the permission of our FERPA-regulated clients. Consistent with applicable law and our agreements with Company clients, we also may share or disclose personal information collected from children in a limited number of instances, including the following:
- We may, subject to FERPA’s requirements, share information with our service providers if necessary for them to perform a business, professional, or technology support function for us
- We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
Data Mining and Scanning
If the Company engages in data mining and scanning of PII stored in the Application, such activities will be limited to necessary and permitted purposes such as malware/spam detection or personalization tools. Under no circumstances will PII be used for targeted advertising directed to students or their parents or for any other purpose prohibited by law or by our user agreement.
Data Security and Destruction
Intelitek has in place robust checks and controls to ensure data security for itself, its customers, and any other third party whose data may be accessed through Intelitek’s servers and systems. In the event of a breach, Intelitek will promptly notify any affected party of such data breach and work with all relevant parties, including its FERPA-regulated clients, its own and/or outside cybersecurity teams, and law enforcement, to limit the impact of such breach and prevent future data breached. Intelitek will cooperate with its FERPA-regulated customers to confirm that policies and procedures to ensure the security and confidentiality of the data are being followed.
Upon the completion of Intelitek’s contractual relationship with its FERPA-regulated clients, we will retain PII only so long as reasonably necessary to fulfill the activity request or allow the student to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. Any other PII will be promptly destroyed in accordance with industry-standard practices subject to verification by our clients.
Transparency
Intelitek does not maintain education records on behalf of FERPA-regulated clients. If any parent believes that Intelitek possesses PII relating to his or her child, the parent should notify Intelitek and Intelitek shall, as relevant, comply with FERPA and all applicable laws and regulations in providing the parent with access to such records through the FERPA-regulated client from which such records were received.
All communications from parents should be directed to:
Intelitek
Attention: Management
18 Tsienneto Road
Derry, NH 03038
United States of America
Toll Free: 800-221-2763 / Phone: 603-413-2600 / Fax: 603-437-2137
Email: privacy@gocoderz.com
The End
Last updated: December 6th, 2021
