Privacy Policy
Last updated: March 26, 2026
This Privacy Notice for Cody Reading Inc. ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
- Visit our website at https://www.codyreading.com or any website of ours that links to this Privacy Notice
- Use Cody Reading, a solution designed specifically for reading specialists, educators, tutoring centers, and literacy professionals. Our service provides advanced tools and artificial intelligence capabilities to support the creation of customized educational materials for reading instruction and intervention.
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@codyreading.com.
Summary of Key Points
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions. We process sensitive personal information, including student educational data, when necessary with your consent or as otherwise permitted by applicable law.
Do we collect any information from third parties? We do not collect any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us.
Table of Contents
- What Information Do We Collect?
- How Do We Process Your Information?
- When and With Whom Do We Share Your Personal Information?
- Do We Use Cookies and Other Tracking Technologies?
- Do We Offer Artificial Intelligence-Based Products?
- How Long Do We Keep Your Information?
- How Do We Keep Your Information Safe?
- Children's Privacy and COPPA Compliance
- What Are Your Privacy Rights?
- Controls for Do-Not-Track Features
- Do United States Residents Have Specific Privacy Rights?
- Do We Make Updates to This Notice?
- How Can You Contact Us About This Notice?
- How Can You Review, Update, or Delete the Data We Collect From You?
1. What Information Do We Collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- Names
- Phone numbers
- Email addresses
- Usernames
- Passwords
- Contact preferences
- Contact or authentication data
- Billing addresses
Student information collected on behalf of educators and parents
Our platform is designed for use by reading specialists, educators, tutoring centers, and parents ("Authorized Users") to support literacy instruction for students, including children under the age of 13. Authorized Users may enter the following student information into the platform:
- Student first name (and optionally, last name)
- Grade or reading level
- Reading assessment results and progress data
- Phonics and decoding skill profiles (e.g., known/unknown letter patterns, sight words, error patterns)
- Session notes entered by the student's tutor or educator
Students do not directly access or interact with the Cody Reading platform. All student data is entered and managed by Authorized Users. We collect only the minimum student information necessary to provide personalized reading instruction and progress tracking.
Student information is processed in accordance with the Children's Online Privacy Protection Act (COPPA) and applicable state student privacy laws. See Section 8 ("Children's Privacy and COPPA Compliance") for full details.
Sensitive information
When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
- Student educational records, including reading assessment data and skill profiles for children under 13, when entered by an Authorized User with parental consent
- Account login information
- Audio recordings used for reading assessment purposes, where applicable
Payment data
We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice at: https://stripe.com/privacy.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files.
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.
Google API
Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
2. How Do We Process Your Information?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, including:
- To facilitate account creation and authentication and otherwise manage user accounts
- To provide personalized reading instruction: we process student information, including reading levels, skill profiles, and assessment data, to generate customized educational materials, track student progress, and support literacy intervention. When student data is processed by our AI Service Providers (see Section 5), it is transmitted in de-identified form with no student names or other direct identifiers.
- To respond to user inquiries/offer support to users
- To send administrative information to you
- To send you marketing and promotional communications
- To protect our Services
- To evaluate and improve our Services, products, marketing, and your experience
- To identify usage trends
3. When and With Whom Do We Share Your Personal Information?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
AI Service Providers. We share limited, de-identified student data with our AI Service Providers solely to power the platform's reading instruction features. Specifically:
- We do not transmit student names or direct identifiers to AI Service Providers. Student data is de-identified before any API call.
- AI Service Providers process data solely to generate a response to our platform's request and do not use this data for model training.
- AI Service Providers retain data only temporarily for security and abuse monitoring purposes, in accordance with their respective data retention policies, after which it is automatically deleted.
- We maintain Data Processing Agreements (DPAs) with our AI Service Providers that contractually prohibit the use of our data for model training.
A list of our current sub-processors is available upon request by contacting privacy@codyreading.com.
Tutoring Centers and Educators. Authorized Users (tutoring centers, educators, and parents) can access only the student data associated with their own accounts. We do not share student data across tutoring centers or with any unaffiliated third parties for marketing, advertising, or any purpose unrelated to the educational services described in this Notice.
4. Do We Use Cookies and Other Tracking Technologies?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services.
Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout.
5. Do We Offer Artificial Intelligence-Based Products?
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.
As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). We provide AI Products through third-party service providers ("AI Service Providers").
How student data is handled by AI Service Providers
When our platform uses AI Service Providers to support reading instruction:
- De-identification. Student names and other direct identifiers are removed before data is transmitted to any AI Service Provider. Only reading patterns, skill data, and instructional context are shared.
- No model training. Our AI Service Providers do not use data submitted through our platform to train their AI models. This is enforced through our contractual agreements with each provider.
- Limited retention. AI Service Providers retain data only temporarily for security and abuse monitoring purposes, in accordance with their respective data retention policies, after which it is automatically deleted.
- No secondary use. AI Service Providers are contractually prohibited from using student data for any purpose other than providing services to our platform.
AI product functions
Our AI-powered features include:
- Generation of leveled reading passages and decodable texts
- Analysis of student reading error patterns
- Personalized instructional recommendations based on skill profiles
- Natural language processing for reading assessment support
6. How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user's account.
Student data retention
Student data is retained for as long as the student's profile is active on the platform. Authorized Users (tutoring centers, educators, or parents) may delete a student's profile at any time, which will result in the permanent deletion of all associated student data within thirty (30) days.
Parents or legal guardians may request review or deletion of their child's data at any time by contacting us at privacy@codyreading.com or by notifying their tutoring center, which will relay the request to us. We will fulfill deletion requests within thirty (30) days of receipt.
Upon termination of a tutoring center's account, all student data associated with that account will be deleted within ninety (90) days.
7. How Do We Keep Your Information Safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.
8. Children's Privacy and COPPA Compliance
Overview
Cody Reading is an educational platform that stores and processes personal information of children, including children under the age of 13, for the sole purpose of providing personalized reading instruction. We are committed to complying with the Children's Online Privacy Protection Act (COPPA) and applicable state student privacy laws.
Children do not directly access or use the Cody Reading platform. All student data is entered and managed by authorized adults, specifically reading specialists, tutoring center staff, educators, and parents or legal guardians ("Authorized Users").
Information we collect about children
The following categories of information about children may be entered into the platform by Authorized Users:
- First name (and optionally, last name)
- Grade or reading level
- Reading assessment scores and progress data
- Phonics and decoding skill profiles (known/unknown patterns, sight words, error patterns)
- Session notes from tutoring sessions
- Audio recordings of reading sessions (where applicable, for assessment purposes)
We collect only the information necessary to provide the educational services described in this Notice.
Parental consent
We require that appropriate parental consent is in place before any child's personal information is entered into the platform.
- Tutoring center and educator users: As a condition of using the platform, tutoring centers and educators are responsible for ensuring that appropriate parental consent has been obtained before entering student information.
- Parent users: When a parent or legal guardian directly creates a student profile, the disclosures provided during the profile creation process and the parent's decision to proceed serve as consent under applicable law.
How children's information is used
Children's personal information is used solely to:
- Provide personalized reading instruction and generate customized educational materials
- Track reading progress and assessment results
- Generate reports for the child's tutor, educator, or parent
- Improve the educational effectiveness of the platform
Children's personal information is never used for marketing, advertising, or any commercial purpose unrelated to the educational services described in this Notice.
How children's information is shared
We share children's personal information only as follows:
- With AI Service Providers: In de-identified form only. Student names and direct identifiers are removed before transmission. AI Service Providers are contractually prohibited from using this data for model training. See Section 5 for details.
- With the child's Authorized Users: Tutors, educators, and parents associated with the child's profile can view the child's data within the platform.
- As required by law: We may disclose children's information if required by law, regulation, or legal process.
We do not sell children's personal information. We do not share children's personal information with third parties for marketing or advertising purposes.
Parental rights
Parents and legal guardians have the following rights regarding their child's personal information:
- Right to review. You may request to review the personal information we have collected about your child.
- Right to deletion. You may request that we delete your child's personal information from our platform. We will fulfill deletion requests within thirty (30) days.
- Right to revoke consent. You may revoke your consent for the continued collection and use of your child's personal information at any time. Upon revocation, we will delete your child's data within thirty (30) days.
- Right to refuse further collection. You may refuse to permit any further collection of your child's personal information without requiring deletion of information previously collected.
To exercise any of these rights, please contact us at privacy@codyreading.com or notify your child's tutoring center, which is required to relay the request to us promptly.
Data security for children's information
Children's personal information is protected by the same security measures described in Section 7 of this Notice, including encryption in transit and at rest, access controls, and secure U.S.-based hosting.
Data retention for children's information
Children's personal information is retained only for as long as the child's profile is active on the platform. See Section 6 for detailed retention and deletion timelines.
9. What Are Your Privacy Rights?
In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time.
Account Information. If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided.
If you have questions or comments about your privacy rights, you may email us at privacy@codyreading.com.
10. Controls for Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals.
11. Do United States Residents Have Specific Privacy Rights?
In Short: If you are a resident of certain US states, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.
Depending on where you live, you may have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
Categories of personal information we collect
The table below shows the categories of personal information we have collected in the past twelve (12) months.
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, real name, postal address, telephone number, unique personal identifier, online identifier, IP address, email address, account name | YES |
| B. Personal information as defined in CA Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
| C. Protected classification characteristics | Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data | YES |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | NO |
| E. Biometric information | Audio recordings of student reading sessions, where applicable, for assessment purposes | YES |
| F. Internet or network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
| G. Geolocation data | Device location | NO |
| H. Audio, electronic, sensory information | Images and audio, video or call recordings created in connection with our business activities | YES |
| I. Professional or employment-related information | Business contact details to provide Services at a business level or job title, work history, and professional qualifications | NO |
| J. Education information | Student reading levels, assessment results, skill profiles, and progress data | YES |
| K. Inferences drawn from personal information | Inferences drawn from any collected personal information to create a profile or summary about preferences and characteristics | YES |
| L. Sensitive personal information | Account login information and personal data of children under 13 collected with parental consent for educational purposes | YES |
Your rights
These rights include:
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
- Right to non-discrimination for exercising your rights
- Right to limit use and disclosure of sensitive personal data
Depending on where you live, you may also have additional rights under applicable state privacy laws, including the right to obtain lists of third parties to whom personal data has been disclosed, the right to question how personal data has been profiled, and the right to opt out of sensitive data collection.
How to exercise your rights
To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at security@codyreading.com, or by visiting https://www.codyreading.com/contact.
Under certain US state data protection laws, you are also permitted to designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will only accept requests from an authorized agent if you have verified your identity with us, provided the authorized agent written permission to submit such requests on your behalf, and your authorized agent additionally has valid power of attorney pursuant to the applicable state's laws.
Request verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at security@codyreading.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of those third parties. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
12. Do We Make Updates to This Notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.
13. How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may contact us by post at:
Cody Reading Inc.
2810 North Church Street, PMB 936381
Wilmington, DE 19802
United States
Email: privacy@codyreading.com
14. How Can You Review, Update, or Delete the Data We Collect From You?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please fill out and submit a data subject access request or contact us at privacy@codyreading.com.