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Why does Khan Academy process my personal data?

Updated

Overview

This article analyzes the legal bases on which Khan Academy generally relies when processing personal data of individual customers.  

Data privacy laws in many jurisdictions require organizations acting as data controllers to identify a valid legal basis before carrying out any processing of personal data.  For example, under the EU General Data Protection Regulation (GDPR), data controllers may rely on six lawful bases for processing personal data:

  • contractual necessity (processing required to provide our services under our Terms of Service, a school services contract or other contract)
  • legal obligation (processing required by law)
  • vital interests (life-or-death situations) 
  • public tasks (public interest or official authority)
  • legitimate interests (controller’s interests balanced against data subject rights)
  • consent (affirmative agreement for specific purposes)

Many countries, including the UK, use the GDPR framework or a substantially similar framework under their local privacy laws.  

GDPR Framework

The table below sets out the legal basis generally relied on by Khan Academy for each processing purpose, in accordance with the GDPR framework.  In many cases, more than one basis is available, depending on the specific context of the processing, the relationship with the individual customer, and applicable regulatory requirements in jurisdictions whose data protection frameworks differ from, or only partially align with, the GDPR.  In cases where legitimate interests serve as the basis of our processing, we conduct an assessment to weigh Khan Academy’s legitimate interests against our customer’s individual privacy rights and interests.  

The categories of data described in the table are further detailed in the “Collection of Information” section of our privacy policy.

PurposeCategory of DataGDPR Legal Basis
To provide our Service. Khan Academy uses your information to operate, maintain, and provide all of the features of our Services.
  • Account ownership and contact  information, such as user name and email address
  • Information from Single Sign On (SSO) authentication services; 
  • Information obtained from a school, or from other users, that is required to establish an account or enroll in a program, including class roster data
  • Learning activity associated with your account
  • Usage and device information
  • Necessary to provide our services or otherwise perform a contract.
To personalize your experience. We use your information to personalize your experience while using the Service, including on various devices you may use to access the Service.  For instance, Khan Academy remembers your recent activity so we can recommend the most appropriate content for you and provide personalized learning experiences.
  • Information about your use of our platform, including learning activity and associated insights
  • General location information
  • Usage and device information
  • Necessary to provide our services or otherwise perform a contract.  Personalization is inherent in the learning experience we deliver.
  • Our legitimate interests to personalize your experience. 







 

To communicate with you about your account. We use your information to communicate with you about your account and respond to your inquiries. We may also communicate with you to let you know about account features and help you get the most of your account.
  • Email address
  • Information about your use of our Service, such as videos watched or skills attained 
  • Your communications with us, including support requests
  • Necessary to provide our services or otherwise perform a contract.  Certain communications are a core part of our Service.  
  • Our legitimate interests to inform you about our Services, respond to and, where necessary, investigate your inquiries about the Services.
To communicate with you about our services and our mission. We may use your information to communicate with you about our mission and fundraising for our mission.
  • Email address
  • Information about your use of our Service, such as using videos watched or skills attained to suggest additional learning activities you may be interested in
  • Donation information
  • Our legitimate interest in communicating with you regarding our mission and philanthropic fundraising, including your prior support.
  • Your consent.
To enable the customer's participation in Khan Academy partnership arrangements. We use your information to enable you to participate in programs or features we may offer in partnership with third parties, to the extent you decide to participate in such programs.
  • Email address 
  • User type (student vs parent or teacher, grade level)
  • Information we collect to enable your participation in special programs or features
  • Information provided by partners and other sources
  • Necessary to provide our services or otherwise perform a contract.
  • Your consent. 
To understand, improve, and develop our Service. Khan Academy uses information to understand and analyze the usage trends, learning behaviors, and preferences of our users, to improve the way the Service works and looks, and to create new features and functionality.  In most cases, we use de-identified, anonymized or aggregate information for these purposes.
  • Information about your use of our Service,  such as videos watched, features used or other learning activities you engage in
  • Usage and device information
  • Your communications with us
  • Feedback you may provide to us
  • Our legitimate interests in improving our Service.
  • Your consent.
To develop new educational offerings. We may use information to maintain, develop, support and improve our Service and other educational products and services, and for educational research.   In most cases, we use de-identified, anonymized or aggregate data for this purpose.
  • Information about your  use of our Service, such as videos watched, features used or other learning activities you engage in; 
  • Usage and device information
  • Your communications with us 
  • Feedback you may provide to us
  • Our legitimate interests in developing our Service.
  • Your consent. 
For legal, compliance or safety reasons. We may use or share information to comply with applicable laws, rules, or regulations, and our Terms of Service, including protecting the safety and rights of Khan Academy, users, and the general public.
  • Your contact and account owner  information and account and account usage data, to the extent necessary for such purposes
  • Necessary for a legal obligation, including maintenance of financial and compliance records 
  • Our legitimate interests to maintain the safety and security of our platform and defend against legal claims.

Global application

While the legal basis framework established under the GDPR has influenced privacy legislation worldwide, there is no uniform global standard.  Some countries use different terminology to describe what is essentially the same legal basis; others do not require a legal basis at all or impose more restrictive requirements, including a greater reliance on consent and the exclusion of certain bases, such as legitimate interest.  

If you reside in a country outside the US and EU, we will process personal data according to the legal basis requirements of the country in which you habitually reside.  In most cases the basis of processing will follow similar principles as set forth in the GDPR table above.  When the specific legal bases vary from the GDPR (e.g., Brazil’s LGPD, India’s DPDP Act), the following general principles apply:

  • In countries where one of the bases available under the GDPR is not recognized, we rely on alternate available bases under the relevant applicable law.
  • We are generally able to provide our core educational services under Khan Academy's Terms of Service in reliance on bases relating to contractual necessity or equivalent concepts. 
  • When we offer supplemental programs or activities beyond our core educational services, we may rely on other available bases of processing, obtain your explicit consent, or we may refrain from providing that program or activity if no lawful basis exists. 
  • We limit our use of data for ancillary uses (such as analytics and product development) to uses for which a lawful basis exists, or limit our use to aggregate, anonymized or de-identified data.
  • We limit marketing activities to those permitted under applicable law, including by obtaining explicit consent if required, or we may refrain from marketing activities.  You can opt out of communications and marketing activities that are not part of the core service.

School Services

Khan Academy offers structured educational programs to schools and educational institutions in select countries outside the United States, principally through our subsidiary in Brazil and other partner entities such as our “KhanX” partners (independent nonprofit organizations authorized to provide school programs in select countries).  In cases where we support institutional use in formal school programs, we process student data at the direction of the school customer, as the data controller, as provided under our services contract with the school or partner entity.  We will process data as necessary to provide our services under the school contract and to support programs and activities requested or approved by the school.   The school or other educational institution is responsible for obtaining any parent or guardian consent required to process the data of minor students, and for informing parents about processing of student data and as required under applicable law and our Terms of Service.  

Automated Decision-Making

Khan Academy’s AI-enabled features are used solely for informative and educational purposes, with use by students and children under the supervision of a teacher, parent or other responsible adult.   These tools are not intended to be used to make decisions that produce legal or similarly significant effects on data subjects. While our AI-Enabled learning solutions include features that provide AI-powered feedback to learners and educators, consequential decisions regarding educational progress are made by the teacher or other supervising adult in the broader context of overall student performance.  

AI-enabled features are not offered in all jurisdictions or to all types of users.  AI-enabled features for students are available outside the United States only though school partnerships in select jurisdictions.