Overview

Character Lab is a non-profit organization that connects researchers with educators 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 student 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 section on Character Lab Research Network Student Privacy.

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 student PII in a way materially inconsistent with the student privacy provisions below or any contractual requirements with schools, without first providing notice to schools at the contact information specified in our agreements with those schools to allow them to choose whether to continue to use Character Lab Research Network in accordance with these changes.

Character Lab Research Network Student Privacy

Character Lab is a proud supporter of the Student Privacy Pledge.  This section explains how information is collected, used, protected, and disclosed through our Character Lab Research Network (“Research Network”) platform, which is one of our Services. 

What is the 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 “personally identifiable information”—as that term is defined under the Family Educational Rights and Privacy Act (“FERPA”)—and other information protected by similar state student data privacy laws that is collected through the Research Network (“student PII”).  Student PII includes identifiable information that is maintained in a student’s education records and includes (1) direct identifiers, such as student name or student ID number, and (2) indirect identifiers, such as student’s date of birth or place of birth.

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.

What student PII is collected through Research Network?

Research Network seamlessly connects schools with character development researchers.  Researchers create activities that they make available through Research Network, which come in various forms including but not limited to surveys, open-ended responses, short video clips, and gamified tasks.  Schools that connect with those researchers make Research Network available to their students, who can then participate in those activities.

To participate in Research Network research activities and access the platform, students will be asked to create accounts by providing their school email address, student ID number, and school information.  Teachers 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.

Students will log on to the platform with their email address or ID number and a password, and will use the platform to complete the research activities.  Through the research activities, students may provide responses to research questions related to character development (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 a more details on the technical information collected through Research Network, please refer to the section 

In an effort to implement best practices to protect student privacy, we make a number of commitments:

  • We will not collect, use, share, or retain student PII for any purpose other than as authorized by the school.
  • We will not share student PII with a researcher unless authorized by the school, and then only subject to strict protections.
  • We will not partner with any for-profit entity to provide it with student PII  collected through Research Network. 
  • We will not sell student PII. 
  • We will not use or disclose student PII for commercial purposes.
  • We will not build a personal profile of a student other than to facilitate our scientific services, which support educational/school purposes.
  • We will support access to and correction of student PII by students or their parents.
  • We will maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of student 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 student PII?

We use the student 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 student PII for any purpose other than as authorized by the school.

Because Research Network was created to connect schools and researchers, information collected through Research Network is provided to researchers, as authorized by the school, in order for them to conduct their research.  However, Character Lab does not disclose student PII – such as names and contact information – to researchers unless authorized by the school.

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

In some limited circumstances, and only when authorized by the school, Character Lab will disclose student PII to a researcher.  Additionally, it is possible that some students may volunteer student PII in a free-form response that is provided to a researcher.  Whenever a researcher receives student 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 student PII collected through Research Network except in the following circumstances:

  • when directed or consented to by the student (or the student’s parent or guardian) or teacher who input the information, or by the administrator of a school’s account;
  • to service providers who work on our behalf and who will use the information 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 students 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 student PII transferred, subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law.

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

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.

How does Character Lab secure student information collected through Research Network?

We maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of student 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 student 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 student PII is transmitted, stored, processed, and maintained by the Vendor.  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 student PII?

Research Network remains under the direct control of the school for the student PII it receives, and uses 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 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.

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 Student Privacy policy, please visit our Frequently Asked Questions or contact us at privacy@characterlab.org.

This Privacy Policy is effective as of January 2022.