Privacy Policy

Product: CodaClass (by Codachord Inc.) Applies to: CodaClass accounts used by early childhood programs, schools, and their invited staff and parents/guardians

Effective: November 5th, 2026

This Privacy Policy explains how Codachord Inc. (“we,” “Codachord,” “us”) handles personal information in connection with CodaClass, our software for early childhood programs.

This Policy supplements the CodaClass Terms of Use. Annex A of the Terms contains contractual data processing protections applicable to all Customers, together with additional education-record protections where FERPA or other identified school privacy requirements apply. Whether a particular educational institution or record is subject to FERPA depends on the applicable legal requirements and circumstances.

This Policy covers product use with program data. It is not the website / public-demo privacy notice at codaclass.app/privacy or codachord.com/privacy.

Summary of key points in this Policy

1. Your center owns child, family, and staff data. Codachord processes it to run CodaClass. We do not own it, sell it, or share it for marketing, and we do not use it to train AI models.

2. Parents only see children they are linked to, and family-visible updates staff share.

3. The center ordinarily administers family notices, educational permissions, and media authorizations for its programs. Codachord remains responsible for any privacy notices, consents, and processing obligations imposed directly on Codachord by applicable law. Accepting the Terms or acknowledging this Policy does not replace a legally required parental consent.

4. Questions about a child’s data go to the center first; Codachord assists the center.

5. Staff-directed AI features currently use Microsoft Azure as an AI subprocessor, and CodaClass uses Amazon Web Services for hosting, including operation of its existing self-hosted speech-to-text model, and may use that infrastructure for additional Codachord-operated AI models. Codachord may change models within an already listed provider or operate models on existing listed infrastructure without adding a new subprocessor, subject to the safeguards described in the Terms and Annex A. Adding or replacing a third-party entity receiving Customer Data is subject to the applicable subprocessor notice procedure. AI prompts may be subject to limited provider security or abuse-monitoring processing according to the applicable configuration and contractual restrictions. Codachord does not authorize Customer Data to be used for AI model training or third-party marketing.

6. Following account termination, we ordinarily target deletion of Customer Data from active systems within 30 days, subject to lawful retention and authorized transition arrangements. Restricted backup copies are removed under the documented backup deletion cycle described in Section 7.

7. If a security incident compromises Customer Data, we notify the center within 72 hours of becoming aware.

1. Who this Policy covers

1.1 Customer / Center. The organization or person that creates or controls a CodaClass account (for example a center, school, program, or director) is the “Customer.” The Customer decides what child, family, and staff data goes into CodaClass.

1.2 Authorized Users. Staff and other people the Customer invites under the account, and parents/guardians (“Parents”) the Customer invites and links to specific children, are Authorized Users.

1.3 Who controls child data. The Customer determines which child, family, staff, and educational information is submitted to or generated through its CodaClass account (“Customer Data”) and how that information is used for authorized educational or childcare purposes. Codachord processes Customer Data as a contracted service provider or processor to provide and maintain CodaClass, support the Customer, secure the service, and perform other specifically authorized purposes described in the Terms and Annex A. Codachord does not claim ownership of Customer Data and does not sell it, use it for independent marketing, or disclose it for targeted advertising or AI model training. Codachord may separately control limited information collected for its own account administration, billing, legal compliance, and security purposes, subject to applicable law and the disclosures in this Policy.

1.4 Family notice and consent. The Customer ordinarily provides family notices and obtains permissions or consents for its educational activities, including permissions associated with photographs, video, voice recordings, and communications. Codachord does not supply the Customer's enrollment, media-release, or childcare licensing documents. Invited Parents accept the user provisions of the Terms and acknowledge this Policy when activating their accounts. That acknowledgment does not itself constitute verifiable parental consent under COPPA, an authorization to disclose education records, or a media release. Where applicable law imposes separate obligations directly on Codachord, Codachord will comply with those obligations. Where a school authorization is relied upon under COPPA, that authorization must satisfy the applicable requirements and limitations.

2. Information we process

Depending on how the Customer uses CodaClass, we may process:

2.1 Account and login information: names, emails, roles (director, teacher, parent, etc.), passwords (stored hashed), invite/accept status, and similar account metadata.

2.2 Child and classroom records: children's names and identifiers, classroom and roster assignments, attendance and check-in or check-out records, observations and developmental or skills assessments, standards tags, activity plans, daily logs, photographs, videos, family notes and communications, schedules, and other classroom records submitted or generated by authorized users. Depending on the Customer's use, these records may contain food allergy information, health or safety notes, incident reports, disability-related information, or other sensitive information about children. Authorized staff may initiate voice input solely for speech-to-text transcription. CodaClass processes that audio through a Codachord-operated speech-to-text model hosted on Amazon Web Services and deletes the audio immediately after transcription without retaining an audio recording. The resulting text may become Customer Data if saved by authorized staff. CodaClass does not create voiceprints, biometric templates, or speaker identification profiles.

2.3 Family / Parent information: parent names, emails, which children they are linked to, and messages or notes they exchange through CodaClass.

2.4 Staff and program information: staff profiles, room assignments, and program settings needed to run the account.

2.5 Optional sensitive educational content: Customers may enter IEP summaries, accommodations, disability-related notes, developmental assessments, allergy information, incident records, or other sensitive educational and child-related content. Such information is processed as Customer Data under the applicable Terms and Annex A. Where authorized staff deliberately use AI features with relevant text, some sensitive educational content may be included in AI prompts or supporting context, subject to the restrictions described in Section 5. CodaClass provides drafting and administrative assistance only and is not an IEP eligibility, placement, diagnosis, or clinical decision system.

2.6 Technical and security data: IP address, device/browser type, approximate timestamps, authentication events, and operational logs needed to run and secure the service. We design operational logs to avoid carrying children’s names, IEP text, or full request bodies where practical.

2.7 AI prompts and outputs: when authorized staff use AI-assisted features, CodaClass may transmit the staff's instructions, relevant classroom text, and context needed for the selected function to an authorized AI subprocessor. AI functions may support observation tagging, family-message drafting, lesson planning, translation, and staff chat referencing program records. Generated drafts return to the staff user for review. Relevant context may include identifiable or sensitive educational information where that information is necessary to the requested function and has not been removed by an applicable privacy gateway. Codachord does not intentionally transmit stored photographs or videos to these AI features. Staff are required to review and approve outputs before saving them to records, sending them to families, or relying on them in decisions about children. AI inputs and outputs remain subject to the no-training and other restrictions in Section 5 and the Terms.

We do not require Parents to provide more than the Customer needs to invite them and link them to their child(ren).

3. How we use information

We use personal information and Customer Data to:

3.1 Provide, operate, and maintain CodaClass for the Customer’s account (including parent messaging, check-in, and other features the Customer enables);

3.2 Authenticate users, enforce access controls, and keep the service secure;

3.3 Support the Customer (for example troubleshooting, export, or deletion assistance);

3.4 Maintain service reliability, diagnose errors, protect security, and improve functionality within the permitted processing purposes and restrictions in the Terms and Annex A, without using identifiable Customer Data for independent commercial purposes or model training;

3.5 Comply with law, enforce our Terms, and respond to valid legal process;

3.6 Send service-related notices (for example security, account, or Terms/Privacy updates) to account contacts.

We do not sell Customer Data. We do not use Customer Data to train, fine-tune, or improve foundation or generative AI models (ours or a third party’s), and we do not provide Customer Data to others for their model training.

4. What Parents can see

4.1 Parents only see children the Customer has linked them to.

4.2 Parents see family-visible updates the Customer’s staff share (for example family notes, messages, and observations marked visible to family). Staff-only notes and internal content stay off the Parent view.

4.3 Photographs and videos of group activities may contain images or other identifying information about children in addition to the child associated with a particular Parent account. The Customer is responsible for determining which media may lawfully be collected and made visible to families, including any required permissions or restrictions concerning other children. Parents should not download, publish, forward, or otherwise disclose images of other children without appropriate authorization. Codachord provides the access and visibility functions described in this Policy and must comply with applicable privacy, security, and processing obligations. Acceptance of the Terms does not independently authorize the disclosure of another child's protected information.

4.4 Codachord does not expand Parent access beyond what the Customer configures.

5. AI, Azure, and other service providers

5.1 AI providers and model hosting. CodaClass currently uses Microsoft Azure services as a third-party subprocessor for staff-directed AI functions, including observation tagging, family communication drafts, activity planning, translation, and related assistance. Codachord currently operates a self-hosted speech-to-text model using Amazon Web Services infrastructure and may operate additional Codachord-controlled AI models on that infrastructure. Changing or routing between models within the same already listed and contracted provider legal entity, or using Codachord-operated models on already listed infrastructure, does not itself add a new third-party subprocessor. Such changes are permitted without the new-subprocessor notice procedure only where the conditions in the Terms and Annex A are satisfied, including restrictions on data recipients, processing purposes, data categories, processing locations, and data protection commitments. A new third-party entity receiving Customer Data is subject to the applicable subprocessor change process. Each authorized processing arrangement remains subject to the contractual restrictions on model training, marketing use, security, confidentiality, and retention. Current provider functions are identified in the register described in Section 5.2.

5.2 Service provider and subprocessor information. Codachord maintains an accessible, reasonably current register of third-party subprocessors receiving Customer Data for the contracted service and other providers handling account administration or payment information. The register identifies each provider, its relevant function, categories of information processed, and processing locations where available. Current service subprocessors include Microsoft Azure for staff-directed AI processing, Amazon Web Services for cloud hosting and infrastructure supporting Codachord's existing self-hosted speech-to-text model and any additional Codachord-operated AI models when deployed, and Resend for transactional email services, including invitations and account recovery communications involving staff and Parent email addresses and account identifiers. Resend does not receive classroom records, photographs, videos, or child educational records through those transactional email functions. Stripe is separately identified as a billing and payment service provider handling subscription payments, billing contact information, and related account administration information. Stripe is not used to process classroom or child records for the Customer.

Codachord may add or replace a third-party subprocessor legal entity receiving Customer Data subject to the notice, objection, and contractual protection provisions in the Terms and Annex A. Changes between models within the same already listed provider legal entity and deployment of Codachord-operated models on existing listed infrastructure do not themselves constitute adding a new subprocessor, provided no new entity receives Customer Data, the processing purposes and data categories are not expanded, no new processing location is introduced, and applicable protections remain unchanged. The register will be updated to reflect material changes in provider functions, including use of AWS for AI/model hosting. Changes outside these conditions remain subject to applicable legal and contractual notice or authorization requirements.

5.3 No model training or unrelated use. Codachord does not use Customer Data, including prompts, generated outputs, classroom records, photographs, videos, messages, voice recordings, or IEP-related text, to train, fine-tune, or improve foundation or generative AI models. Codachord does not sell Customer Data, disclose it for targeted advertising, use it for independent marketing, or authorize AI subprocessors to use it for their own model training or unrelated commercial purposes. Authorized providers may process prompts and outputs to provide the requested AI function and may perform limited service security or abuse-monitoring processing only as permitted by the applicable contract and law. Retention, access, and monitoring practices can vary by provider and deployment configuration. Codachord will maintain applicable provider restrictions consistent with its contractual commitments and will not treat a provider change as authorization for broader data uses.

5.4 Privacy gateways and content minimization. CodaClass uses privacy gateway measures intended to reduce identifying details in prompts where those measures are implemented for a particular feature, including replacement or removal of selected identifiers where technically supported. Such measures are not guaranteed to remove every identifier, sensitive detail, or contextual clue. Staff may limit the content submitted to available AI functions through applicable product controls. Identifiable or sensitive educational text may nevertheless reach an authorized AI subprocessor when a staff member uses a feature requiring that context. Codachord will not describe gateway processing as complete anonymization unless the applicable transformation meets that standard.

5.5 AI outputs are drafts/assistance only. The Customer’s staff remain responsible for what is saved, sent to families, or used with children.

6. Who we share information with

We share personal information / Customer Data only as needed to run CodaClass:

6.1 With the Customer and its Authorized Users, according to roles and links the Customer sets (staff see what their role allows; Parents see only linked children and family-visible content).

6.2 With authorized subprocessors identified under Section 5, only to the extent necessary to perform the contracted services and subject to applicable written confidentiality, security, purpose limitation, incident response, and deletion obligations. AI subprocessors are also subject to the model-training and marketing restrictions in Section 5.3. Material provider changes are governed by the Terms and Annex A.

6.3 With the Customer’s direction, for example exports the Customer requests, or support actions the Customer authorizes.

6.4 For legal and safety reasons, if required by law, valid legal process, or to protect the rights, safety, or security of users, Codachord, or others.

6.5 We do not sell Customer Data and do not share it for third-party advertising. One Customer’s account is isolated from another’s; we do not give Customer A access to Customer B’s children.

7. Retention and deletion

7.1 During the subscription. The Customer may submit authorized requests concerning export, correction, or deletion of Customer Data. Codachord will reasonably assist and ordinarily target completion of eligible requests within 30 days after receiving the information necessary to verify and process the request, subject to applicable law and technical limitations disclosed to the Customer. Deleted information may remain temporarily in restricted backup systems until the applicable backup deletion cycle, ordinarily targeted within 30 additional days after active deletion. Legally required preservation may extend limited retention. Information awaiting backup deletion will not be used for ordinary service or independent commercial purposes. The corresponding contractual provisions appear in Section 8 of the Terms and Annex A.

7.2 After cancellation or termination. Unless the Customer authorizes temporary transition retention under Section 7.3 or applicable law requires preservation, Codachord ordinarily targets deletion of Customer Data from active systems within 30 days after the termination becomes effective. Restricted backup copies are handled under the documented deletion cycle in Section 7.1. Access by staff and Parents associated with the terminated Customer account ends under the applicable termination process. Customer Data is not retained for independent product improvement after termination.

7.3 Optional transition retention. At the Customer's written request, Codachord may retain Customer Data for a specified period of up to 90 days following termination solely for authorized transition, export, restoration, or another specifically identified Customer-directed purpose. Such information remains subject to the Terms and Annex A and may not be used for independent product improvement, marketing, or model training. Codachord will delete the retained information when the authorized period ends or earlier following a valid Customer request, subject to lawful preservation obligations and restricted backup procedures.

7.4 Codachord may retain product metrics derived from Customer Data only where the information has been appropriately deidentified or aggregated, cannot reasonably identify or be linked to a Customer, child, family, or staff member, and is maintained subject to reasonable restrictions against reidentification. Identifiable AI prompts, student records, photographs, and other Customer Data do not become deidentified merely because direct names have been removed.

7.5 Pilot accounts. If the Customer is on a signed Pilot Agreement, that agreement’s retention choices (delete vs ≤90-day non-training retention after pilot end) control for that pilot period to the extent they differ from this Section.

8. Security

8.1 Codachord uses reasonable administrative, technical, and organizational measures appropriate to early childhood data, including access controls, encryption in transit and at rest, and tenant isolation for the Customer’s account.

8.2 If Codachord determines that a security incident has resulted in unauthorized access to, acquisition of, or disclosure of Customer Data, Codachord will notify the affected Customer without undue delay and within 72 hours after that determination, subject to any shorter applicable legal or contractual deadline. Codachord will provide available information concerning the incident and reasonable updates as the investigation progresses, and will cooperate with the Customer concerning containment, investigation, remediation, and legally required notifications. Relevant incidents involving subprocessors are subject to the same contractual reporting framework.

8.3 The Customer is responsible for staff device security, password hygiene, promptly removing access when someone leaves, and choosing which Parents and staff to invite.

9. Your choices and how to contact us

9.1 Parents and guardians. For questions about the Customer's classroom records, authorized users, group media, correction, deletion, or educational permissions, Parents should ordinarily contact the center or school that invited them. The Customer directs Codachord's processing of those records, and Codachord will reasonably assist the Customer in responding to appropriate requests. Parents may also contact privacy@codachord.com concerning Codachord's own information practices, suspected unauthorized processing, or rights that applicable law permits them to exercise directly against Codachord. Where law imposes an independent obligation on Codachord, including any applicable COPPA obligation, Codachord will respond as required by that law rather than automatically referring the entire request to the Customer.

9.2 Customers (centers / schools). For export, deletion, subprocessor lists, security notices, or privacy questions about your account, contact Codachord at the support or privacy email published with this Policy (or the contact in your Pilot / order documents).

9.3 Your login profile. You may update your own login details in CodaClass when the product offers that. Parents and staff who need help with access should ask their center. Center account owners who need help with the account should contact Codachord.

9.4 Closing a Parent login does not by itself delete the child’s classroom records; those remain under the Customer’s control until the Customer requests changes or the account is deleted under Section 7.

10. Children

CodaClass is designed primarily for use by adult staff members and invited Parents of children served by participating educational and childcare programs. The service is not intended to provide independent child accounts or direct child access. Codachord processes information about children in connection with authorized Customer activities and the contractual purposes described in this Policy and Annex A. Codachord does not market the service directly to children or use their information for targeted advertising or AI model training. Whether particular features or information-collection practices are subject to COPPA depends on the statutory requirements and actual operation of the service. Where COPPA applies, Codachord will provide legally required notices, honor applicable parental rights, and obtain or rely upon legally sufficient authorization as permitted by law. A center's general consent representation or a Parent's Terms acceptance does not independently satisfy every applicable statutory consent requirement.

11. International and state privacy notes

11.1 CodaClass is offered primarily for U.S. early childhood programs. Hosting and subprocessors may process data in the United States or other locations where those providers operate.

11.2 Where an applicable state privacy law treats Codachord as a service provider or processor acting for a Customer, Codachord processes the relevant personal information for the specified contracted purposes and under the applicable restrictions in the Terms and Annex A. Codachord does not sell or share Customer Data for cross-context behavioral advertising or use protected child information for independent marketing. The applicable roles and rights depend on the statutory definitions and circumstances of each processing activity. To the extent Codachord independently controls other personal information, such as particular account, billing, or security records, applicable individual rights and notice obligations will be addressed under the relevant law. California, Oregon, and Illinois protections are considered in the contractual provisions where applicable; this Policy does not constitute a comprehensive jurisdiction-by-jurisdiction compliance determination.

11.3 FERPA and education records: when Annex A of the Terms applies, Codachord acts as the Customer’s processor / school official as described there.

12. Changes

Codachord may update this Privacy Policy to reflect changes in services, information practices, or applicable requirements. Codachord will post the updated Policy with an updated effective date and will provide reasonable advance notice of material changes affecting Customer Data practices where practicable or required by law. Changes that require affirmative consent or other authorization under applicable law will not become authorized solely because an individual continues using CodaClass. Material changes in subprocessor arrangements are governed by the Terms and Annex A. Changes will not retroactively authorize materially different uses of previously collected Customer Data without a lawful basis and any required notice or consent.

13. Contact

For child / family data questions: contact your center or school (the Customer who invited you to CodaClass).

Codachord: Codachord Inc. Email: privacy@codachord.com