Child Privacy Policy

Last updated: October 1, 2026

SAM Labs Inc. ("SAM Labs," "we," "us," or "our") is committed to protecting the privacy and safety of children and students who use SAM Labs products and services.

This Child Privacy Policy explains how we collect, use, share, retain, and protect personal information from children under 13 in the United States, and student information provided or authorized by schools, teachers, districts, parents, or guardians.

This Policy applies to our websites and to SAM Studio, FRST (Future-Ready Skills Tracker), SAM Code, and other SAM Labs apps and educational services that link to it (the "Services"). For our general privacy practices, see our Privacy Policy.

1. Children's Privacy and COPPA

In the United States, the Children's Online Privacy Protection Act ("COPPA") applies to the online collection of personal information from children under 13.

Our Services are designed for use by schools, teachers, and districts. In school settings, schools or teachers may provide consent on behalf of parents where permitted by COPPA, but only when student information is used for school-authorized educational purposes and not for any other commercial purpose.

If SAM Labs collects personal information from a child under 13 outside of a school-authorized educational context, we will seek verifiable parental consent where required by law. If we learn that we have collected personal information from a child under 13 without appropriate authorization or consent, we will delete it.

2. How Each Service Works for Students

• SAM Studio. Students access SAM Studio through accounts created or rostered by their teacher, school, or district. Students create code and projects and may connect SAM Labs hardware.
• FRST. FRST is used by teachers and school staff to record observations of students' future-ready skills. Students do not have FRST accounts and do not use FRST directly. Teachers may record notes, scores, audio observations, and images or files as evidence of learning.
• SAM Code. SAM Code is a Scratch-based coding platform. Only teachers and authorized school staff can sign up. Students access SAM Code through their teacher's class.

3. Information We May Collect

Depending on the Service and how the school uses it, we may collect:

• Student account information, such as first name, last name, school-issued email address, username, classroom, group, school, district, or teacher association.
• Optional account information, such as nicknames or display names.
• Educational activity information, such as lessons accessed, projects and code created, program activity, assignment progress, and learning-related interactions.
• Skill observations (FRST), such as teacher-entered observations, scores, and notes about future-ready skills, and related progress reports.
• Images, audio, and files, such as audio observations or images uploaded by teachers in FRST, or content a student adds to a project.
• Technical information, such as IP address, device type, browser type, operating system, log data, timestamps, and product usage data.
• Login information from school-approved providers, such as Google, Microsoft, Clever, or ClassLink, where enabled by the school or district.
• Support information provided by a teacher, school, parent, guardian, or authorized user.

We do not require students to provide more personal information than is reasonably necessary to use the Service. Where possible, schools and teachers may use nicknames or limited identifiers instead of full student names.

4. How We Use Children's and Student Information

We use children's and student information only to provide the Services to the school, including to:

• Provide access to SAM Labs Services, lessons, and educational features.
• Create and manage student accounts, classrooms, and groups.
• Allow teachers and administrators to assign, view, manage, and support student work.
• Save projects, code, lesson progress, and skill observations.
• Show student progress and growth over time to authorized teachers, administrators, and district staff.
• Provide technical support and fix problems.
• Keep the Services secure and reliable, and improve how they work for schools.
• Comply with applicable laws and our agreements with schools.

We do not:

• use student personal information for advertising or marketing;
• sell student personal information;
• build student profiles for non-educational purposes;
• use student personal information to train artificial intelligence models;
• use images or audio for facial recognition, voice recognition, or any other biometric identification.

5. Images, Audio, and Student Content

Student content and FRST evidence are for educational use within the applicable class, school, or district. We do not make it public.

Teachers and schools are responsible for making sure they have any notice, consent, or authorization required by school policy or applicable law before recording or uploading images or audio of students, and for uploading only what is needed for an educational purpose. Students should not include unnecessary personal information in projects, such as home addresses, phone numbers, or private photos.

Teachers should not enter sensitive information about students, such as health, disability, or disciplinary details, unless the school has authorized it and it is needed for an educational purpose.

A school or district may ask us to remove specific content at any time. Parents and guardians should contact the school, or contact us at info@samlabs.com and we will work with the school. We will remove content without undue delay once a request is verified.

6. Third Parties That Receive Children's Information

We share children's and student information only with the school or district that authorized its collection, and with service providers that process it on our behalf to run the Services. Our service providers are contractually required to use the information only to provide services to SAM Labs, to keep it confidential, and to protect it.

When a school enables an integration such as Google Classroom, Microsoft, Clever, or ClassLink, we receive information from that provider as directed by the school. Those providers are governed by the school's own agreements with them.

We may also disclose information if required by law, court order, subpoena, or government request, or where necessary to protect the safety, rights, or security of students, schools, SAM Labs, or the public.

7. School and Teacher Consent

In educational settings, COPPA allows schools and teachers to consent to the collection of personal information from children under 13 on behalf of parents, provided the information is used only for school-authorized educational purposes.

SAM Labs relies on schools, districts, teachers, or administrators to provide appropriate authorization when they create accounts, roster students, enable integrations, record observations, or let students use our Services. Schools and districts should give parents appropriate notice about the educational technology used in the classroom, including SAM Labs.

8. Parent and Guardian Rights

Parents and guardians may have the right to review, request deletion of, or refuse further collection or use of personal information collected from their child.

Because student accounts and records are created and managed by the school or district, parents should first contact the child's teacher, school, or district to request access, correction, or deletion. Parents may also contact SAM Labs at info@samlabs.com. We may need to verify the requester's identity and authority, and we will work with the school or district to respond.

9. FERPA and State Student Privacy Laws

Where FERPA applies, SAM Labs acts as a "school official" with a legitimate educational interest and processes student education records only on behalf of, and under the direct control of, the school or district. Parents seeking access to education records should contact the school or district.

We also comply with applicable state student privacy laws, such as California's SOPIPA, New York Education Law § 2-d, and Illinois' SOPPA.

10. Data Retention Policy

We keep children's and student information only as long as reasonably necessary for the purposes described in this Policy, and we do not keep it indefinitely. Our retention periods are:

We may keep information longer only where a school's agreement requires it or where the law requires us to. De-identified information is kept and used only in de-identified form, and we will not attempt to re-identify it.

11. Security

SAM Labs maintains a written information security program with administrative, technical, and organizational safeguards designed to protect children's and student information. These include access controls, encryption in transit and at rest, secure authentication, and monitoring. More information is available on our Trust & Security page.

No method of transmission or storage is completely secure. If a security incident affects student information, we will notify the affected school or district without unreasonable delay, as required by applicable law and our agreements.

12. Changes to This Policy

We may update this Child Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page. If changes materially affect how we collect, use, or disclose children's personal information, we will notify schools and provide notice and obtain consent where required by law.

13. Contact Us

If you have questions about this Child Privacy Policy, contact us at:

SAM Labs Inc.
1321 Upland Dr. PMB 17412
Houston, Texas, 77043
United States
Email: info@samlabs.com