Codon Learning Privacy Policy
Introduction
Codon Learning (“Codon Learning” or “we” or “us”) has created this Privacy Policy in order to disclose its use of consumer data collected about you. This Privacy Policy is effective as of Jan 29, 2026. This policy was last updated on Jan 29, 2026. Any questions regarding this policy should be directed by email to privacy@codonlearning.com. You may also contact Codon Learning at the following address:
Codon Learning - 607 10th St. Suite 303 - Golden, CO 80401
The following discloses Codon Learning’s information gathering and dissemination practices for its applications and website.
Our Role: Controller vs. Processor
Depending on the context, Codon Learning may act as a "Controller" or a "Processor" of your personal data.
When you interact directly with our public website (e.g., for marketing purposes) or if you are an individual user purchasing access directly, Codon Learning typically acts as the Data Controller.
When an educational institution contracts with Codon Learning to provide services like the Codon Platform for its students and staff, Codon Learning typically acts as a Data Processor (or "school official" under FERPA/FIPPA). In these cases, the educational institution is the Data Controller, and we process personal data according to their instructions and our contractual agreement with them, in compliance with laws like FERPA or FIPPA.
If you use the Codon Learning service, you consent to this policy and the use/sharing of your personal data as described herein. You have the choice to opt-out of certain data sharing, as described below, and rights to control how we use and share your data.
Information Collected and Received
Codon Learning may collect or receive personal information about you, including, but not limited to, first and last name, email address, password and instructor educational information (such as school name and location, and course information). You can choose what information you want to share with Codon Learning, however, if you choose to withhold any personal data requested by us, it may not be possible for you to gain access to certain parts of the Codon Learning website and/or applications. We collect personal information from you at several different points, including but not limited to the following:
when we correspond with you as a customer or prospective customer;
when you visit the website and/or application;
when you register as an end-user of our service and an account is created for you;
when you provide information, such as survey information;
when you contact us for help; and
when the website and/or application sends us error reports or application analytics data.
when interacting with integrated third-party systems like a Learning Management System (LMS).
We also collect data implicitly through your use of the Services, such as device type, browser information, operating system, usage timestamps, and general activity patterns within the Services. When integrated with an LMS via LTI, we may receive user identifiers, roles, and course context, and may send back grade or completion data as configured by the institution.
You can choose what information you want to share with Codon Learning (e.g., optional fields in a profile); however, if you choose to withhold any personal data essential for the service, it may not be possible for you to gain access to certain parts of the Codon Learning website and/or applications.
Codon Learning does not require you to include sensitive information (e.g. racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic data, biometric data, data concerning health or data concerning sexual orientation). In the event that you provide such sensitive information as listed above you acknowledge that you have provided Codon Learning explicit consent to receive such information.
Lawful Basis for Processing
We will only collect and process your personal data where we have a lawful basis. Our lawful basis includes consent (where you have given it), where processing is necessary for the performance of a contract with you, and for the purposes of our legitimate interests or the legitimate interests of our third parties, provided that such interest does not outweigh your rights and freedoms. Examples of legitimate interest include but are not limited to: (i) complying with applicable law, (ii) protecting against security or other threats, (iii) administration of our business interests, including improvements and enhancements of our business, and (iv) customer relationship issues.
Your Rights: Access, Correction, Deletion
Data Retention: We retain the personal data you provide to us when you registered with the Codon Learning website and/or application, or any other information generated or volunteered while using the service, based on the following principles:
(i) Active Accounts: As long as your account is active and necessary to provide you with the requested services.
(ii) Fulfillment of Purpose: For a limited period as long as we need it to fulfill the purposes for which we initially collected it (e.g., completing a course term).
(iii) Contractual Obligations: Crucially, when providing services to an educational institution (where we act as a Data Processor), our data retention and deletion schedules for student and institutional data are primarily governed by our contractual agreement with that specific institution. This means data may be retained or deleted according to timelines specified by your institution. Our default policy in these cases is to retain data for a period of 5 years from course completion, but this may vary, as noted, from institution to institution.
(iv) Legal Requirements: As otherwise required or permitted by applicable law (e.g., FERPA record-keeping requirements, legal holds, statute of limitations).
We retain usage information and other data as described in the "How We Use Your Information" section.
Your Rights: You generally have the right to request access to, correction of, or deletion of the personal information that Codon Learning holds about you.
How to Exercise Rights: You can initiate these requests by contacting us at privacy@codonlearning.com.
Identity Verification: To comply with your request, we may need to take steps to verify your identity.
Important Note for Students/Users via Educational Institutions: If you are using the Codon Learning platform through your educational institution, the institution is typically the Data Controller for your educational records and related personal data within our system.
Requests via Institution: Requests regarding access, correction, or deletion of your personal data should generally be directed to your educational institution. They have the primary responsibility for managing your data under laws like FERPA/FIPPA.
Codon's Role: As a Data Processor acting under contract, Codon Learning will cooperate with verified requests from your institution to access, correct, or delete personal data as stipulated in our agreement with them and as required by applicable law. Data deletion will occur based on the schedules and triggers defined in our contract with your institution.
Direct Student Requests: While you can contact us, for data controlled by your institution, we may need to redirect you to your institution or require their authorization before fulfilling certain requests, especially regarding deletion during active service periods defined by the institution's contract.
Deletion Limitations: Once data is deleted according to institutional contracts or direct user requests (where applicable), it may not be recoverable. Furthermore, Codon Learning may not be able to fulfill deletion requests for depersonalized data (data that has been anonymized or aggregated and is no longer linked to an identifiable individual), as this data is outside the scope of personal data rights.
How We Use Your Information
Codon Learning may use personal information that we collect about you to:
deliver the products and services that you have requested;
manage your customer relationship and provide you with customer support;
perform analysis about your use of the website and/or application;
communicate with you by e-mail or within application messaging features;
enforce our terms and conditions and other agreements between Codon Learning and you;
manage our business;
respond to investigation, court orders, legal process, or to investigate, prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, or as otherwise required by law; and
perform functions as otherwise described to you at the time of collection.
for users who registered for more information on the website or attended an informational webinar about Codon Learning, we may send occasional marketing material.
Codon Learning occasionally uses other companies to perform services necessary to our operations. In the course of providing these services, those companies may have access to your personal information. By contractual agreement, those companies must treat your information in accordance with this Privacy Policy.
How We Share Your Information
(a) Personally Identifiable Information
Codon Learning will never sell your email address or any other personally identifiable information to any third party. We do not disclose your personally identifiable information to any third party except in the following limited circumstances:
With your explicit permission.
To trusted third-party service providers (subprocessors) working on our behalf to operate the service (e.g., cloud hosting providers like Amazon Web Services) who are bound by strict confidentiality and data protection agreements.
To consultants working on our behalf, who are bound by confidentiality obligations.
As required by law or legal process (see section (c) below).
In connection with a change of control (see section (d) below).
When integrated with a third-party Learning Management System (LMS) at the direction of your institution, we may receive information from and send information (such as identifiers, roles, course context, assignment/grade data) back to the LMS. This sharing is governed by the LTI standard and our agreement with the institution. We are not responsible for how the third-party LMS itself uses or protects your information once it is transferred back to them.
Any personally identifiable information you elect to make publicly available on our websites and/or applications (such as posting public comments, reviewing items, etc., if such features exist and are used) will be available to others.
(b) Non-Personally Identifiable Information
Codon Learning has the right to retain records of usage data pertaining to the use of the website and applications including, but not limited to, feature usage, activity logs, and click-throughs. This data, when anonymized and aggregated (meaning it cannot be used to identify any individual user), may be used for internal purposes such as platform improvement, analyzing trends, and reporting general usage statistics. We do not share personally identifiable information derived from site registration for marketing purposes.
(c) We May Be Required to Share Your Information
Codon Learning reserves the right to disclose information when required by law, such as by a subpoena or other legal proceedings. Codon Learning may also disclose your information if we reasonably believe it necessary to (i) comply with requests of law enforcement or other applicable law; (ii) to enforce any agreement between you and us; (iii) to protect the security and integrity of our site, applications, or services; and/or (iv) to protect us, our users or others.
(d) What Happens in the Event of a Change of Control
We may be involved with an acquisition or divestiture of our business, products or services. Information we maintain including names and email addresses, and other information related to the Codon Learning service may be sold or transferred in connection with such a transaction. We may also sell, assign or otherwise transfer such information in connection with a sale of all or substantially all of our business or assets. You will be notified via email and/or a notice on our site of any applicable change in ownership or uses of your information.
(e) Testimonials
We may also disclose, on an anonymous basis, statements made by our users. However, with your consent, we may post your testimonial along with your name. If at any point you wish to update or delete your testimonial, please contact us at privacy@codonlearning.com.
How We Store and Process Your Information
The information collected by Codon Learning is primarily processed and stored in the United States on secure cloud infrastructure provided by Amazon Web Services (AWS).
For Canadian Users: To comply with Canadian data privacy laws, personal information of users accessing the service from Canada is stored and managed entirely on separate Canadian servers hosted by AWS.
Subprocessors: We utilize vetted third-party subprocessors for specific functions like payment processing (e.g., Stripe) and cloud hosting (AWS). These subprocessors may operate in the United States or other countries. We maintain contractual agreements with subprocessors requiring them to uphold strict data protection standards.
International Transfers: By using our services, you acknowledge that your information may be transferred to, stored, and processed in the United States and potentially other countries where our subprocessors operate. If you are located in the European Union, or other regions with laws governing data collection and use, please note that we comply with laws applicable to us regarding international data transfers and implement appropriate safeguards. United States law may not offer the same privacy protections as the law in your jurisdiction.
How We Protect Your Information
Codon Learning is concerned with protecting your privacy and data. We implement and maintain reasonable administrative, technical, and physical security measures designed to protect the information under our control from loss, misuse, unauthorized access, disclosure, alteration, or destruction. These measures include:
Using industry-standard technologies such as encryption for data at rest and in transit (e.g., TLS).
Implementing strict access controls based on the principle of least privilege.
Conducting regular vulnerability management and security assessments .
Adhering to secure coding practices.
Regularly backing up data and having disaster recovery plans in place.
Training our employees on data security and privacy best practices.
Our servers are protected by security systems and regularly backed up. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot ensure or guarantee the absolute security of any information you transmit to us. If you have any questions about security, you can contact us at privacy@codonlearning.com.
We use third-party, PCI-DSS compliant payment processors (like Stripe) to handle payments. We do not directly collect, store, or retain full credit card information. Payment processing is handled via secure integrations provided by the payment processor.
Cookies
“Cookies” are small pieces of information stored by your browser. The Codon application for students and instructors does not currently use cookies. However, we reserve the right to use cookies in the future to operate and improve the content and service. The Codon website does use cookies. Examples include:
Essential Cookies: Necessary for basic site functionality, like maintaining your login session.
Analytics Cookies: Help us understand website and application usage (e.g., which features are popular) so we can improve the service. Data collected is typically aggregated and anonymized.
You have choices regarding cookie management. All major browsers allow you to view, block, or delete cookies. Please consult the privacy features in your browser to learn more. Choosing not to accept cookies may prohibit use of the Codon Learning platform.
Links
Codon Learning may create links to other web sites. Codon Learning will make a reasonable effort to link only to sites that meet similar standards for maintaining each individual's right to privacy. However, many other sites that are not associated or authorized by Codon Learning may have links leading to our site. Codon Learning cannot control these links and Codon Learning is not responsible for any content appearing on these sites.
Children’s Privacy
Our website and/or applications are intended for use by students enrolled in university or college courses, and the university employees involved in teaching those courses. We do not knowingly collect any information from anyone who we know to be under the age of 13. If you are under the age of 18, you should use this website only with the involvement of a parent or guardian and should not submit any personal information to us. If we discover that a person under the age of 13 has provided us with any personal information, we will use commercially reasonable efforts to delete such person's personal information from all Codon Learning systems.
Compliance With the Family Education Rights & Privacy Act (FERPA) / Freedom of Information and Protection of Privacy Act (FIPPA)
When processing student education records on behalf of educational institutions in the United States, Codon Learning complies with the Family Educational Rights & Privacy Act (FERPA), 20 U.S.C. § 1232(g). When processing student personal information on behalf of educational institutions in Canada, we comply with applicable provincial Freedom of Information and Protection of Privacy Acts (FIPPA).
In these contexts, Codon Learning acts as a "school official" (under FERPA) or service provider (under FIPPA) with legitimate educational interests. We maintain the confidentiality of student data covered by these laws and use this information solely to deliver and improve the services provided to the institutions and their students, as permitted by our agreements and the law. We do not use FERPA or FIPPA-protected data for other purposes, such as targeted advertising. Students may have specific rights related to accessing and/or updating their personal information under these laws, which should typically be directed to their educational institution (see "Your Rights" section). For further information about FERPA/FIPPA compliance, please contact us at privacy@codonlearning.com.
Your California Privacy Rights
Codon Learning does not currently respond to browser “Do Not Track” (DNT) signals or other mechanisms. Third parties may collect personal information about your online activities over time and across sites when you visit the website and/or application.
If you are a California resident, California Civil Code Section 1798.83 permits you to request certain information regarding our disclosure of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us by sending an e-mail to privacy@codonlearning.com.
Our website and/or application are not intended to appeal to minors. However, if you are a California resident under the age of 18, and a registered user of our website and/or application, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an e-mail with a detailed description of the specific content or information to privacy@codonlearning.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
Under California law, California residents who have an established business relationship with us may opt-out of our disclosing personal information about them to third parties for their marketing purposes.
Amendments
Codon Learning may amend this policy at any time. If Codon Learning is going to use personally identifiable information collected through the Codon Learning site in a manner materially different from that stated at the time of collection, Codon Learning will notify users via email and/or by posting a notice on the Codon Learning site for thirty (30) days prior to such use. This Privacy Policy may not be otherwise amended except in a writing that specifically refers to this Privacy Policy and is physically signed by both parties. If you are interested in a previous version of the privacy policy, please contact us at privacy@codonlearning.com
Successors and Assigns
This Privacy Policy inures to the benefit of successors and assigns of Codon Learning.
Contacts
If you have any questions about this Privacy Policy, the practices of this site, your dealings with this website, or request access, changes, or deletion to information we have about you, you can contact privacy@codonlearning.com. Upon request, Codon Learning will provide you with access to information (e.g., name, address, phone number) that Codon Learning collects and maintains about you. This site gives you the following options for changing, modifying, or removing information previously provided: (i) email: privacy@codonlearning.com; or (ii) visit www.codonlearning.com.
Opt Out
The Codon Learning site provides users the opportunity to opt out of receiving communications from Codon Learning, except transactional correspondence. To opt out of receiving our communications, you can (i) send an email to privacy@codonlearning.com; or (ii) send postal mail to: Codon Learning, 607 10th Street, Suite 303, Golden, CO 80401.