Student Privacy Policy

Student privacy is important to us. We want to be transparent with you on what personal data we collect, why we collect it, and what we do with it. Moreover, we want you to know your rights regarding this personal data. Therefore, we strongly recommend that you read this Privacy Policy carefully before registering your child in Bold Idea. If you have any questions, you can contact us at boldidea.org/contact.

Bold Idea Privacy Principles

Our Privacy Policy is grounded in our commitment to the following Privacy Principles:

We are deeply committed to creating a safe and secure learning environment for our students. We take the protection of this information seriously.
We collect no more data than what is absolutely necessary for the delivery and evaluation of our educational programs.
We do not sell your Personal Information or exploit it for financial gain; we do not sell ads. We established Bold Idea as a nonprofit organization so that our mission and your trust will not be in conflict with a for-profit motive.
We take steps to ensure the security of any personally identifiable information. We do not, under any circumstances, share personally identifiable information with third parties.
It is important that our students understand how to take privacy seriously and how to protect their own data. We take steps to ensure students are conscientious of the data they generate and its impact on their privacy.
We provide parents and legal guardians full access to any student data collected, as well as any data or content generated by that student during our sessions.
We hold our partners to privacy and security practices no less stringent than our own.

Privacy Policy

We are deeply committed to creating a safe and secure learning environment for our students as they interact with our online learning platforms and mentor communication tools (our “Online Systems”). Students registered in a Bold Idea program are referred to as “Student” and collectively as “Students”. Bold Idea volunteers who sign up as mentors in the program are vetted through background-check and are referred to as “Mentors”. Bold Idea employees are referred to as “Staff”. As a not-for-profit, 501(c)(3) organization, we use the data we receive only insofar as it helps our mission of increasing access and interest in computer science for all students regardless of race, gender, or socioeconomic status. We established ourselves as a not-for-profit organization so that a for-profit motive will not interfere with our mission of providing a trusted educational resource.

Our Privacy Policy describes what information we gather from our Users, how we use that information, and what we do to protect it. Bold Idea takes steps to minimize the collection of personal data from students. Our Online Systems are used to deliver Bold Idea’s educational programs. Authorized program representatives such as Staff and Mentors may also be able to connect with students through these systems in order to provide tutorial, educational and similar services. Express consent from a parent or legal guardian will allow us to register the child for these Online Services in connection with the registration. Legal Guardians may request access to these systems at any time, and are authorized to view or change any data collected or entered by registered Students.

Collection and Use of Student Information

The sections below describe the ways Bold Idea collects and uses personal data, which refers to any information that identifies a student as an individual (directly or indirectly). This includes things like the name, birth date, zip code, grade level, etc. from Students as well as the name, email and phone of the parent or guardian (“Personal Information”), persistent cookies or IP addresses (“Persistent Identifiers”), as well as some of the non-Personal Information and technical information (described below) we collect. We collectively refer to any of this data we collect from Students, along with any Student information, Student records, and Student-generated content as “Student Data.”

Our collection, use, and disclosure of Student Data are governed by our Privacy Policy and also by the provision of the Family Educational Rights and Privacy Act (FERPA), the Children's Online Privacy Protection Act (COPPA), and applicable state laws that relate to the collection of Student Data. Bold Idea shall not use Student Data for any purposes other than those authorized pursuant to our Privacy Policy.

The following table describes the data that Bold Idea collects from registered students

Data stored by Bold Idea	How and when is the data collected?	How this data is used
Parent/guardian name, email, and phone number	Required on registration	Used by program volunteers or staff to contact parents with announcements, reminders, or questions regarding the Student’s involvement in Bold Idea.
First and last name	Required on registration	We use names to create student rosters and to help Mentors keep track of attendance. This data is only accessible to Bold Idea staff and authorized volunteers. Student names are printed on their folders, which are kept at the school or program site.
Date of birth	Required on registration	Student date of birth is used to determine the age of the student. It is also used in combination with first and last name to uniquely identify students in our system in order to prevent duplicate records.
Zip code and county	Optional on registration	Zip code and county data is aggregated into our reporting. This helps us track progress toward our goal of making sure every student can access a technology mentor within five miles of home or school.
Grade level	Required on registration	Grade level helps give mentors an understanding of the Student’s learning level, and allows them to pair them with other Students at similar levels. This information is also aggregated in our reporting to give us more insight into how students progress through our program from 5th through 8th grade and beyond.
T-shirt size	Optional on registration	Bold Idea provides free t-shirts to students once every year.
Race, ethnicity, gender, and family income information	Optional on registration	We encourage families to provide information on the student's racial background, ethnicity, gender, and family income level. This helps to improve our outreach efforts, making our program accessible to ALL students regardless of race, gender, or socioeconomic status.
Bold Idea Student ID and password	Created the first time Student attends a session	A unique identifier is created for every student along with a randomized password. This allows Students to log into our Online Systems. Usernames and passwords are printed on student folders and kept at the school. No personal information is tied to these ID’s in the context of our online learning platforms and mentor communication tools.
Bold Idea Google login	Created the first time Student attends a session	A Google “G-Suite” account under the boldidea.org domain is created for each student for the purpose of authentication with other authorized third-party sites, such as Repl.it. We restrict these accounts to only allow authentication on authorized sites as well as access to a Google Drive (a cloud-based file storage service). Students are NOT given access to email and cannot send or receive emails using this account. Access to all other Google services (such as YouTube) are turned off.
Attendance data	Recorded each session	Mentors track attendance data for every student registered in the program. This helps to track and measure student engagement at our individual program sites.
Login time, IP address, and other technical data	Automatically collected as students use a Bold Idea online service	This helps Bold Idea troubleshoot any problems in user experience. It also helps Bold Idea understand usage patterns, ensure our Online Services can support all users, and enable site updates with minimal service disruption. See section below on “technical information” for more details.
Pre- and post-survey data	Collected at the beginning and end of the school year	During the beginning and end of each school year we ask for responses to attitudinal questions that measure students interest in computer science, attitudes toward learning (growth mindset), and interest and awareness in technology careers and college majors.
Assessment data	Collected during each Bold Idea session	Student learning is assessed at each session. This used to help students and mentors gauge student learning, and to help inform the design of future curriculum. We also use this information to track overall skill development during a student’s time with Bold Idea.
Student projects (apps, games, websites, etc)	Collected as Students create such projects	The code and underlying assets for these projects are stored by Bold Idea, so that Students can retrieve their projects as needed. Students are advised never to include any Personal Information in their projects. Select student projects may be featured on the Bold Idea website. Featured projects are posted with Student’s first name and grade. Featured projects are reviewed by Bold Idea staff to ensure no other personally identifiable information is present in the projects.
Student-uploaded images, sounds, or videos	Collected if Students choose to upload custom files.	Students are advised never to upload any media containing Personal Information. These files are not used by Bold Idea for any purpose other than within these projects.
Data collected by Student-created apps	Collected if users of a code project created by the Student choose to enter data into the app.	Depending on the author’s project design, a Student-created app may in turn collect data by prompting other Users (anybody who tries using the Student-created app) to enter information, such as a favorite movie. If a Student creates an app that collects and stores data in this fashion, all data entered by Users of the app may be accessed and possibly shared publicly by the app author, the app itself, and potentially anybody with a link to view the app. Bold Idea does not itself use or share this data outside of the program. Before using a Student-created app that collects data, Users are shown a clear warning that any data they enter may be shared publicly and that they should not share anything personal to them or to others.

All above data is securely stored in Bold Idea’s database. It can only be accessed by Bold Idea staff and authorized volunteer Mentors. These authorized parties may create, update, or delete Personal Information as needed.

A parent or legal guardian of a Student under the age of 18 may also review Personal Information and correct erroneous information or remove any data by contacting Bold Idea Staff directly at boldidea.org/contact. If you are a parent or legal guardian of a Student, you can ask us to deactivate the Student’s accounts, delete any logins, Personal Information, or Persistent Identifiers, and request that we no longer allow the Student’s information to be stored with Bold Idea. To make such a request, please contact us at boldidea.org/contact. Before processing your request, we may verify your identity and your relationship with the Student.

Services Provided by Bold Idea

Student Portal (my.boldidea.org)
This is an portal used by students to view curriculum materials, track their learning progress, and access other Bold Idea resources. Students also use this system to keep track of their digital portfolio of projects as well as certain learning achievements (also known as “badges”).

Coding Environment
The Student Portal also includes a web-based coding application which allows students to write code and test their projects. This application contains only the tools necessary for coding projects, such as an editor and project previewer. The code and underlying assets for student-created projects are stored by Bold Idea, so that Students can retrieve their projects as needed.

Third Party SERVICES and websites Used by Bold Idea Students

Zoom (zoom.us)
Zoom is a video/webcam conferencing system used by students and mentors during Bold Idea @ Home sessions. Only background-checked mentors are given access to video conferencing. “Break-out rooms” are used to group students into one-on-one sessions. All break-out rooms are visible by multiple authorized personnel at any given time. Students join using a meeting link that is only accessible by logging into the Bold Idea student portal. Students do not need a Zoom account to participate, however, they must provide their first name when joining the meeting in order for the host to admit them.

Google Forms (forms.google.com)
Students submit pre- and post-survey information using Google Forms. This may require students to log in using their Bold Idea Google account (see table in the “Collection and Use of Student Information” section above). Survey submissions are private and are only seen by Bold Idea Staff.

Kenney.nl
Kenney.nl is a free-to-use website that provides digital artwork for use in video games or other visual projects. This site has been deemed as appropriate for children of all ages, and does not require students to log in or submit any personal information.

Jfxr.frozenfractal.com
This website is a free-to-use sound effect generator that allows students to create and download sound effects for use in their projects. It does not require students to log in or submit any personal information.

Technical Information

To provide a personalized learning and high-quality experience for our Students, we may use various technologies that automatically record certain technical information from your browser or device, including browser language settings, standard log files, web beacons, or pixel tags. This technical information may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system, and the dates and times that you visit the Website. This information assists us in understanding how our Online Services are being utilized.

To track information about use of our Online Services, we use various technological tools. For example: Like most websites, whether or not you are a registered member, we may send one or more cookies – small text files containing a string of alphanumeric characters that save to your computer or mobile device when students use our Online Services. Cookies remember information about your activities on a website and enable us to provide Students with a more personalized learning experience. We collect this information for various purposes:

Essential cookies: these ensure the Website works properly for Users. As one example, when you authenticate and log in, thanks to essential cookies you aren’t prompted to re-enter your password on every single page you visit during your browsing session.
Functional cookies: these help us personalize the Website and make it faster or more user-friendly. For example, thanks to functional cookies the Website may remember your language setting (English, Spanish, etc).

Bold Idea may use both session cookies and persistent cookies. A session cookie disappears automatically after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Website. You can, however, remove a persistent cookie at any time. Please review your web browser Help file, Tools menu, or other similar menu options to learn the proper way to modify your cookie settings, or visit www.allaboutcookies.org. Please note that without cookies you will not have access to certain services and features on our websites.

Third Party Service Providers

Bold Idea may use a variety of third-party service providers, such as cloud hosting, email services, analytics for website usage, and social networking platforms to host our videos. We may allow third-party service providers to place and read their own cookies, web beacons, and similar technologies to collect information through the Website. This technical information is collected directly and automatically by these third parties.

We use third party services to implement our Website and all of its associated services and features, including (but not limited to) Amazon Web Services and Azure (for website hosting and data storage) and Google G Suite (for authentication using “Sign In with Google” or Chromebook login). Personal data will be used and stored by these third parties solely in context as an implementation services provider to Bold Idea, but these third parties will not receive any ownership or have any other rights to access or use this personal data.

Bold Idea does not allow advertising on our Website or Online Services, and we do not have the ability to collect your web search history across third-party Internet websites or search engines.

Uploading Custom Content

As part of our coding curriculum, Registered Students can upload custom images, text, sound, and videos to Bold Idea’s platforms to use within applications or “apps” that they create. These files are stored by Bold Idea, and are not used by Bold Idea for any purpose other than within the applications created by Students.

Students are instructed to never type, submit, or upload personal information or photos when using our Online Systems. Volunteer mentors are also trained to make sure students do not disclose any personal information online during the course of a Bold Idea program.

Testing and Staging websites

For the purposes of testing our Online Services before releasing them into production for broad usage, we run staging and testing versions of our services for internal testing purposes only. These are meant only for experimental use by Bold Idea employees, contractors, volunteers, or agents, and not considered part of our Online Services as defined in this agreement. Any information, including Personal Information or Persistent Identifiers provided while using these staging or testing versions of our services is not governed by this Privacy Policy.

Information We Do NOT Collect

Bold Idea does not directly collect or store payment instruments. Donations to Bold Idea are processed via third parties, and although Bold Idea receives a receipt for donations (for tax purposes), we never receive the payment instrument (such as credit card or wallet information).

Limitations on Access to your Personal Information by Employees and Authorized Parties

Bold Idea’s officers, directors, employees, volunteers, and contractors must have a legitimate business reason (related directly to furthering our charitable, nonprofit education-focused mission) to access Personal Information you provide to Bold Idea. Bold Idea will require our officers, directors, employees, agents, volunteers, and contractors to comply with this Privacy Policy, and to treat any Personal Information of Bold Idea Students as confidential information.

How We Share or Transfer Data

We do not rent or sell Personal Information, Persistent Identifiers, or any other information that we collect from Users, or exploit it for financial gain in any other way. Bold Idea will never share or grant rights to Personal Information with other third-party organizations to use without your consent, except as part of a specific program or feature for which you will have the explicit ability and choice to opt-in.

Whenever we share Student personal data, we hold our partners to privacy and security practices no less stringent than our own.

In particular, we do not share any Personal Information you provide with our donors or sponsors (other than the "Public Reporting" of de-identified reports as described below).

We may share de-identified information with our Local Partners
Our Local Partners will be able to see de-identified demographic information, attendance, and survey data from Students. They will not see names or parent contact information of any Student.

Public reporting on Student demographics and outcomes
We may publish de-identified information about Student demographic information, attendance, and survey responses. However, we will never publicly disclose Personal Information in these reports. Data about Students will remain de-identified. Aggregated, de-identified data over large populations of Students may be reported by demographic criteria such as age, general location, gender, ethnicity, and socioeconomic status.

We will share data when required by law
Bold Idea may also disclose Student data including Personal Information or Persistent Identifiers if required to do so by law, or if we have a good-faith belief that such action is necessary to comply with local, state, federal, international, or other applicable laws or respond to a court order, judicial or other government order, subpoena, or warrant, or administrative request. In some cases, we may make such disclosures without first providing notice to Student, Teachers, schools, parents or legal guardians.

We may share data in the context of a change of business, including a merger or acquisition
In the event that Bold Idea is acquired by, combined or merged with another entity, we may transfer or assign the Personal Information and Persistent Identifiers that we have collected from Students as part of such merger, acquisition, sale, or other change of control. Our promise to you is that any Personal Information and Persistent Identifiers we have collected from Students would be safeguarded by the acquiring organization under the same level of safety and privacy as afforded by this Privacy Policy.

Our Approach to Data Security

Online security is important to you, and to us
To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your Personal Information. If you have any questions about how we handle or protect your personal data, please contact us.

We try to ensure that our Website and information sent to us are safe, but no security measures are perfect
Bold Idea uses certain physical, administrative, and technical safeguards designed to reasonably protect the confidentiality, availability, integrity and security of your Personal Information, Student Data, and other information we maintain in connection with our Online Services in such a manner that processing will meet the requirements of national laws and ensure the protection of your rights. These safeguards include restrictions on physical access to the data center, hardened system configuration, patch management, disaster recovery process, employee/volunteer security and privacy training, and employee/volunteer background checks. We cannot, however, ensure or warrant the security of any or all of the Personal Information and other information you transmit to Bold Idea, and you do so at your own risk. Once we receive your transmission of information, Bold Idea maintains and enforces commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such Personal Information and other information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If we learn of a data security incident that compromises or appears to compromise your Personal Information or that of our Students, then we will attempt to notify you electronically so that you can take appropriate protective steps.

Conditions of Use and Notices

If you choose to register your Student in our programs, visit our Website, or use our Online Services, any dispute over privacy is subject to this Privacy Policy, including limitations on damages, arbitration of disputes, application of the law of the State of Texas and venue for all disputes in Dallas, Texas.

If any provision of this Privacy Policy is held invalid by a court of competent jurisdiction, the remainder of this Privacy Policy will remain in full force and effect.

You can review or delete Personal Information at any time

We keep your personal data only as long as necessary or for the purposes for which it was collected or as required under any contract or by applicable law.

If, at any point, you wish to access, amend, delete, export (i.e., data portability), or object to or restrict the processing of Personal Information collected via our Website, send us a request at https://boldidea.org/contact. We will promptly review all such requests in accordance with applicable laws.

Updates to our Privacy Policy

From time to time our Privacy Policy will change. Bold Idea will notify users and parents of registered Students of any change to our Privacy Policy by posting the revised Privacy Policy with an updated date of revision on our Website. If we make any significant changes to the policy these will be called out with a short notice of the revision conspicuously posted on the Website homepage. We may also contact users and notify them of the changes if required by law. We stand behind the promises we make, and will not change how we use any Personal Information we have already collected from Students in any material way without also providing notice of the change via email, through this Website, or through other means, and obtaining consent via your continued use to any new policies. We take the protection of the personal data you provide to us very seriously, and we strive to put you in control of decisions around your personal data.

Contacting Bold Idea

Please contact Bold Idea with any questions or comments about this Privacy Policy, your Personal Information, our third-party disclosure practices, or your consent choices by visiting https://boldidea.org/contact, or writing us at PO Box 140904, Dallas, TX 75214.