Overview

Character Lab is a non-profit organization that connects researchers with educators, students, and other youth to create greater knowledge about the conditions that lead to social, emotional, academic, and physical well-being for young people throughout the country.  We use the information we collect to fulfill our mission to advance scientific insights that help kids thrive.

Character Lab is committed to protecting our users’ privacy.  This Privacy Policy (the “Policy”) provides information about how we collect, store, use, and disclose information when you use or access our website located at characterlab.org and any of our other websites, their respective subdomains, and software applications operated by or on behalf of Character Lab (collectively, our “Sites”) and the services available on the Sites (“Services”).  When personally identifiable information is collected, used, or disclosed in relation to the Character Lab Research Network, which is one of our Services, it is subject to additional protections as detailed below in the Character Lab Research Network Privacy Policy.

If you have any questions about our privacy practices, please contact us directly at privacy@characterlab.org.

What information is collected through the Sites and Services?

Character Lab collects any information that you provide when you use the Sites and Services, including when you use our web applications, sign up for a newsletter, or contact us with a question.  This information may include your contact information, and information that you enter to complete a web application.

In addition, we may collect certain technical information about your use of the Sites, such as:

• browser type, language, plug-ins, Internet domain and operating system;
• Internet Protocol (IP) address;
• unique identifiers, including mobile device identification numbers, that may identify the physical location of such devices;
• information collected through cookies, which are small text files stored on users’ computers to save information about the use of websites, such as our web applications; and
• information related to your interactions with the Sites, such as the type of content viewed on the Sites.

How does Character Lab use and disclose information collected through the Sites and Services?

We may use this information to provide you with the products, services, or information you request; deliver communications that you request or which may be of interest to you; maintain, develop, support, improve, analyze, and troubleshoot the Sites and the Services; customize the content you see when you use the Sites; and when we believe in good faith it is necessary to protect the safety of users or others, or to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Sites or Services.

Character Lab will not disclose your information to any third party except as otherwise stated in this Policy and in the following circumstances:

• when directed or consented to by you;
• to service providers who work on our behalf and will use the information in furtherance of our operations, and in accordance with our privacy commitments;
• in response to subpoenas, court orders, or legal process, or to comply with government reporting obligations pursuant to law;
• when we believe in good faith it is necessary to protect the safety of users or others, or to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Sites or Services; or
• to service providers, advisors, potential transaction partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets in bankruptcy or otherwise.  If some or all of our assets are acquired or otherwise transferred, including in bankruptcy, the acquirer will be permitted to maintain the information transferred, subject to confidentiality agreements, the terms of this Policy, and applicable law.

Character Lab may post testimonials from users, in the form of written materials or videos, reflecting a user’s individual experience in using the Sites.  If a user testimonial includes information identifying you, Character Lab will obtain your consent prior to posting such testimonial on the Sites.

The Sites or Services may contain links to websites or apps, or contain integrated content (like embedded videos) provided by third parties.  For example, video content on the Sites may be provided by services such as Vimeo or YouTube.  The information practices of those third parties may differ from ours.  You should consult the privacy policies of any such third party that links from the Sites or provides content that you access through the Sites or Services, as we do not control and are not responsible for the information that they collect, use, or share.  Because your web browser may obtain integrated content directly from third-party servers, the third parties may be able to collect information as if you had visited their websites directly.

How does Character Lab secure information collected through the Sites and Services?

We maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of personally identifiable information collected through the Sites against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.

Character Lab may use one or more third-party service providers (“Vendors”) to help host the services.  Each Vendor has been vetted by Character Lab with respect to the Vendor’s representations about how personally identifiable information is transmitted, stored, processed, and maintained by the Vendor.

Will Character Lab make changes to this Policy?

We will not make changes to this Policy that would give Character Lab the ability to use information collected from users through the Sites in a way materially inconsistent with this Policy, without first providing prominent notice to users to allow them to choose whether to continue to use the Sites in accordance with the new Policy.  Similarly, we will not make changes that would give Character Lab the ability to use PII, as defined below, in a way materially inconsistent with the privacy provisions below or any contractual requirements, without first providing notice to schools at the contact information specified in our agreements with those schools, or to parents or research participants as applicable, to allow them to choose whether to continue to use Character Lab Research Network in accordance with these changes.

Character Lab Research Network Privacy Policy

Research Network seamlessly connects researchers with students and other youth research participants to collect research data in a privacy-protective way.  Researchers create activities that they make available through Research Network, which come in various forms including surveys, open-ended responses, short video clips, and gamified tasks. Schools and parents consent to make Research Network available to their students and children, who can then participate in those activities while limiting the amount of personally identifiable information provided back to the researchers.

There are three means through which activities are made available to youth research participants through the Research Network platform: through schools, through parents, or directly to the participant if the participant has reached the age to consent for themselves (18 in most states). No youth participant under the age of consent will be able to sign up for the Research Network without the authorization of either their school or parent.

What personally identifiable information is collected through Research Network?

Through the Research Network platform, we collect information from youth research participants that are linked to those participants in a way such that they can be identified with reasonable certainty (“personally identifiable information” or “PII”). The PII we collect may depend on whether a research participant is accessing the platform through a school, parents, or themselves:

• To participate in Research Network research activities and access the platform through our partnership with schools, students at those schools are asked to create accounts by providing their school email address, student ID number, and school information. Schools may also create accounts for students by providing their name and/or student ID number, and may input other information related to their students’ character development through Research Network.
• To participate in Research Network research activities and access the platform outside of our partnerships with schools, youth participants may be asked to create accounts by providing their email address, first and last name, birth date, state and zip code of residence, and the email address of their parent or legal guardian in addition to basic demographic information. After completing an age verification process, we will contact the parent or legal guardian of those youth participants who are 17 years or younger to obtain parental consent.

Research participants will use the platform to complete the research activities.  Through the research activities, participants may provide responses to research questions related to kids thriving (e.g., grit, growth mindset, gratitude), perform tasks (e.g., trace a star backwards, identify missing pieces of a matrix), or provide responses to questions after taking part in some sort of task (e.g., watch a video, write a letter).  Their participation is voluntary, and they may stop at any time.

In addition, we may collect certain technical information about use of Research Network, such as browser type, Internet Protocol (IP) address, and information collected through cookies.  For more details on the technical information collected through Research Network, please refer to the “What information is collected through the Sites and Services?” section above.

In an effort to implement best practices to protect youth research participants’ privacy, we make a number of commitments related to PII:

• We will not collect, use, share, or retain PII for any purpose other than as authorized.
• We will not share PII with a researcher unless authorized, and then only subject to strict protections.
• We will not partner with any for-profit entity to provide it with PII  collected through Research Network. 
• We will not sell PII. 
• We will not use or disclose PII for commercial purposes.
• We will not build a personal profile of a student other than to facilitate our scientific services, which in the case of research undertaken through schools support educational/school purposes.
• We will support access to and correction of PII by research participants or their parents.
• We will maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of PII against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.

How does Character Lab use and disclose personally identifiable information?

We use the PII collected through Research Network to provide our research services, including as needed to maintain, develop, support, improve, analyze, or troubleshoot those services.  We will not use or disclose a research participant’s PII for any purpose other than as authorized by the participant’s school or parent, including those purposes described in this Character Lab Research Network Privacy Policy.

This is how it works.  Information collected from research participants through Research Network is stored by Character Lab, and may include PII. As a default rule for research authorized by schools, Research Network anonymizes PII before providing it to researchers, so that researchers cannot identify research participants with reasonable certainty when conducting their research.

It is possible that some research participants may volunteer PII in a free-form response that is provided to a researcher, or that some schools or parents will authorize research involving the collection of PII, for example during participation in a video interview. Whenever a researcher receives PII, the researcher is required to use the information only in support of the study and consistent with our policies.

Otherwise, Character Lab will not use or disclose PII collected through Research Network except in the following circumstances:

• when directed or consented to by the parents (or the research participant, if they have reached the age to consent for themselves), or by the administrator of a school’s account;
• to service providers who work on our behalf and who will use the PII in furtherance of our operations, in accordance with our privacy commitments;
• in response to subpoenas, court orders, legal process, or to comply with government reporting obligations pursuant to law;
• when we believe in good faith it is necessary to protect the safety of research participants or others, or to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of Research Network;
• to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets in bankruptcy or otherwise.  This means that if some or all of our assets are acquired or otherwise transferred, including in bankruptcy, the acquirer will be permitted to maintain the PII transferred, subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law.

We will not use or disclose research participant PII for commercial purposes, sell research participant PII, or partner with any for-profit entity to provide it with research participant PII.

How does Character Lab secure PII collected through Research Network?

We maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of PII against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.  Our risk management includes maintaining a comprehensive security program, providing resources to schools on protecting the privacy of PII, and periodically evaluating our information systems to mitigate potential vulnerabilities.

Character Lab may use one or more third-party service providers (“Vendors”) to help host the Services.  Each Vendor has been vetted by Character Lab with respect to the Vendor’s representations about how PII is transmitted, stored, processed, and maintained by the Vendor.  For PII collected through our partnership with schools (“Student PII”), Character Lab will enter into an appropriate agreement with each Vendor that comports with Character Lab’s role as a School Official and as a Research Studies provider under FERPA.

What rights do schools and parents have with respect to personally identifiable information collected through Research Network?

Student PII collected through Research Network for research authorized by schools remains under the direct control of the school, and we use Student PII only for purposes authorized by the school.  Therefore, schools retain the right to ask Character Lab to access, correct, or delete Student PII, and Character Lab will always support access to and correction of Student PII by parents consistent with legal requirements. Because Student PII collected through Research Network remains under the direct control of the school, parents who may have any concerns about the collection or use of Student PII through Research Network should contact their school.  If you are not sure who at your student’s school will be able to help, feel free to contact us at privacy@characterlab.org.

For research authorized by parents, the parents may contact us using the information provided below to review and/or request that we delete the PII we have collected from research participants under their consent. Parents may also refuse to permit further collection or use of the PII.

To exercise these rights, or if you have questions about our verifiable parental consent process, please contact us as described below.

What is the Student Privacy Pledge?

Character Lab is a proud supporter of the K-12 School Service Provider Pledge to Safeguard Student Privacy 2020 (“Student Privacy Pledge”).

The Student Privacy Pledge is a voluntary and legally enforceable pledge by K-12 education service providers to carry out responsible stewardship and appropriate use of Student PII.

By taking the pledge, service providers agree to certain rules which govern their collection, use, and disclosure of Student PII, both to support the effective use of Student PII and to safeguard student privacy and information security.  The Federal Trade Commission or state Attorneys General have legal authority to ensure signatories to the pledge maintain their commitments. 

Character Lab is a signatory of the Student Privacy Pledge, and we commit to comply with all of the requirements of the Student Privacy Pledge.

Can schools use Research Network in compliance with FERPA?

Yes.  Research Network enables schools to comply with FERPA. 

FERPA applies to “educational agencies and institutions” that receive federal funding from the Department of Education.  For example, most K-12 public schools are subject to FERPA.  Because Character Lab is not an “educational agency or institution,” it is not directly subject to FERPA.  However, to the extent that Character Lab collects student PII, FERPA may require the school to impose certain restrictions on how Character Lab can use and disclose that information.

Under FERPA, schools can permit third parties like Character Lab to collect Student PII on its behalf, without parental consent, in limited circumstances, including:  (1) where Character Lab serves in the role of a “School Official” as defined by FERPA, and (2) where Character Lab facilitates particular research studies under FERPA.

What obligations does Character Lab have with respect to students’ civil rights?

Although civil rights obligations under federal or state law apply to the schools that partner with Character Lab, Character Lab will use commercially reasonable efforts to provide any legally required accommodations under such legal requirements, including those that prohibit discrimination against students with disabilities and English Language Learners.

Contact us

If you have any questions about this Character Lab Research Network Privacy policy, please visit our Frequently Asked Questions or contact us at:

Character Lab
PO Box 37635
PMB 47960
Philadelphia, PA 19101-0635 US
privacy@characterlab.org

This Privacy Policy is effective as of June 2023.