Privacy statement
Effective
1. Scope
This statement describes the information practices of ChirpWater LLC ("ChirpWater", "we", "us") with respect to the Clean Page writing application at cleanpage.app (the "Application") and the informational website at cleanpage.org (the "Website"), together the "Service". It applies to all users of the Service, including students, teachers, parents, and educational institutions.
ChirpWater LLC is a Washington limited liability company and is the sole operator of the Service and the party responsible for the practices described here.
2. Summary
The Service does not collect, receive, store, or transmit outside the user's device any information that a user types, opens, saves, downloads, prints, or chooses in settings; the hosting provider receives the IP address of the user's device in order to deliver the Service, as described in Section 10. The Service has no user accounts, no registration, no sign-in, and no login credentials. Text entered into the Application remains on the user's device and is not transmitted to ChirpWater or to any other party. ChirpWater holds no records about any user of the Service.
3. Information we do not collect
ChirpWater does not collect, and the Service is not designed to collect, any of the following from any user, regardless of age:
- Names, email addresses, postal addresses, telephone numbers, or other contact information.
- Usernames, passwords, account identifiers, or credentials of any kind, including school-issued credentials.
- Student identification numbers, grade level, school or district affiliation, enrollment information, or any education record.
- Dates of birth, age, gender, or other demographic information.
- The text a user writes, opens, saves, downloads, or prints.
- Persistent identifiers, device identifiers, advertising identifiers, or cookies (other than the IP address described in Section 10).
- Geolocation information.
- Photographs, audio, video, or biometric information.
- Browsing history, search history, usage analytics, or behavioral information.
- Information about political affiliation, religious beliefs, mental or physical health, sexual behavior or attitudes, illegal or self-incriminating behavior, family relationships, income, or any other category of sensitive information.
The Service contains no surveys, questionnaires, forms, or fields that request personal information from users.
4. Information processed on the user's device
The Application operates entirely within the user's web browser. The following information exists only on the user's device and is never transmitted to ChirpWater:
- Writing. Text entered into the Application is held in the open browser tab for the duration of the session. It is not saved automatically. Closing or reloading the tab discards it. The user may keep a copy by saving or downloading a plain text file to a location of the user's choosing, by printing, or by copying the text to another program.
- Display preferences. The user's choices for letters, font size, on-screen colors, and spelling are stored in the browser's local storage under the key
cleanpage:settings:v1so that they persist between visits. No writing is stored with these preferences. The preferences can be removed at any time using the browser's site data controls. - Offline copy. The browser may retain a copy of the Application's own files so that the Application continues to function without a network connection. This copy contains no user writing and no user information.
Files that a user saves or downloads are stored wherever the user or the user's institution directs, under the policies of that location. ChirpWater does not receive, access, or retain any copy of such files.
5. Cookies, tracking, and advertising
The Service does not set cookies. The Service does not use analytics, tracking pixels, beacons, session recording, heat mapping, fingerprinting, or any other user monitoring technology. The Service does not display advertising of any kind and does not engage in targeted advertising, behavioral advertising, or contextual advertising. The Service does not load any content, script, font, or resource from a third party.
Because the Service does not track users, browser signals such as "Do Not Track" and Global Privacy Control do not alter its behavior. There is no tracking to opt out of.
6. Communication and social features
The Service contains no chat, messaging, commenting, sharing, collaboration, publishing, or social networking features. Users cannot communicate with one another through the Service, and no user content is visible to any other user or to ChirpWater.
7. Children's privacy
The Children's Online Privacy Protection Act (COPPA) and its implementing rule, 16 CFR Part 312, govern the online collection of personal information from children under the age of 13. The Service is suitable for use by children, including children under the age of 13, because it collects no personal information from any user other than the IP address described in Section 10. Apart from that IP address, ChirpWater does not knowingly collect, use, or disclose personal information from children, does not create or maintain any record associated with a child, and does not condition any part of the Service on the disclosure of personal information.
The only personal information involved in use of the Service is the IP address that the hosting provider receives, as described in Section 10. It is used solely to support the internal operations of the Service. For that reason, no parental consent and no school consent on a parent's behalf is required for a child to use the Service under 16 CFR 312.5(c)(7). There is no separate version of the Service for children; all users receive the same Service with the same practices.
If ChirpWater were ever to change the Service in a way that would involve collecting any other personal information from children, ChirpWater would first update this statement and would obtain any consent required by applicable law before doing so.
8. Use in schools and educational institutions
The Service may be used by schools, school districts, and other educational institutions. In such use:
- ChirpWater does not receive, access, maintain, or have any ability to access student education records, personally identifiable information from education records, or any other student information.
- All student writing remains under the direct control of the student and the institution. ChirpWater exercises no control over, and holds no copy of, any student work.
- ChirpWater does not use, and has no means to use, any student information for any purpose, including product improvement, marketing, or the development of new products or services.
- ChirpWater does not disclose student information to any third party, because it holds none.
- ChirpWater does not create profiles of students, does not build or maintain any record of individual students, and does not use any information about students for any purpose other than the purpose for which the institution uses the Service.
- ChirpWater does not create, use, or share de-identified or aggregated student data, because it holds no data from which such information could be derived.
- Upon termination of an institution's use of the Service, no student information remains in ChirpWater's possession to be returned or deleted.
- Requests from parents or eligible students to inspect, review, or correct education records should be directed to the institution. ChirpWater holds no records to which such a request could apply.
ChirpWater will, on request, review and execute a reasonable student data privacy agreement required by an institution's policies, including the Washington standard student data privacy agreement (WA-NDPA Standard, Version 1.0), and its Exhibit E general offer of terms to other Washington districts. ChirpWater will also provide written confirmation of the practices described in this statement on request. Information for school and district reviewers is on the For schools page.
9. Commitments regarding personal information and student information
ChirpWater makes the following commitments with respect to any personal information or student information, notwithstanding that ChirpWater holds none:
- ChirpWater will not sell, rent, lease, trade, or otherwise disclose personal information or student information to any third party for any consideration.
- ChirpWater will not use personal information or student information to engage in targeted advertising or to serve advertising of any kind.
- ChirpWater will not use personal information or student information to build a profile of any user.
- ChirpWater will not use personal information or student information to train, develop, or improve any product, service, model, or algorithm.
- ChirpWater will not transfer personal information or student information to any successor, acquirer, or other entity in connection with a merger, acquisition, bankruptcy, or other business transaction.
- ChirpWater will not retain personal information or student information for any period, because it holds none.
- ChirpWater will not change the practices described in this statement in a manner that reduces the protections described here without first posting a revised statement with a new effective date.
10. Hosting and service providers
The Application and the Website are delivered by Cloudflare, Inc., which provides the infrastructure that serves the Service's files to users' browsers. ChirpWater has disabled the analytics, monitoring, and user tracking features offered by Cloudflare. In addition, the Service is delivered with a content security policy under which the browser loads scripts, styles, fonts, and images only from the Service's own address and sends data only to that address.
As is inherent in delivering any web page, the hosting provider receives the network connection information necessary to serve the requested files, such as the requesting IP address, and processes that information as ChirpWater's service provider, as described below. Requests to the Service carry no user writing, no display preferences, and no user information. ChirpWater does not access, retain, or use connection information held by the hosting provider.
This section is the notice required by 16 CFR 312.4(d)(3). The IP address is used only for the following internal operations of the Service:
- Delivering the Service's files to the user's browser (network communications).
- Protecting the Service and its users from attacks and abuse (security and integrity).
The following measures keep the IP address from being used for any other purpose:
- ChirpWater does not request, access, export, or use connection records.
- ChirpWater does not combine IP addresses with any other information.
- ChirpWater does not use IP addresses to contact, track, or profile anyone.
- ChirpWater has turned off Cloudflare's optional analytics and monitoring features.
- Cloudflare processes the data as ChirpWater's service provider under its Data Processing Addendum. The addendum limits Cloudflare's use of the data to providing and securing the service and prohibits its use for marketing or advertising.
GitHub, Inc. stores the Application's source code and builds and publishes it. GitHub receives no information about users of the Service. ChirpWater uses no other service provider in the operation of the Service. Connections to the Service are encrypted in transit.
11. Disclosure of information
ChirpWater does not disclose personal information or student information to any third party. ChirpWater holds no such information and therefore has none to disclose in response to a subpoena, court order, legal process, or governmental request. Should ChirpWater receive such a request, it will respond that it holds no responsive information. Cloudflare's handling of legal requests for data it processes for ChirpWater is governed by its Data Processing Addendum.
12. Data retention and deletion
ChirpWater retains no personal information and no student information. The hosting provider processes IP addresses only as long as necessary to deliver and secure the Service, as provided in its Data Processing Addendum. ChirpWater does not copy or export them. Information that exists on a user's device, as described in Section 4, is under the user's control and may be removed by the user at any time using the browser's site data controls or by deleting saved files.
13. Security
The Service's design, under which nothing a user writes or chooses leaves the user's device, is the primary security measure protecting users. There is no ChirpWater database, server, or account system that could be compromised to expose user information. ChirpWater maintains administrative control of the Service's hosting configuration and its published files.
The main risk to users is an unauthorized change to the Application's files. Publishing is limited to ChirpWater's owner. The GitHub and Cloudflare accounts that can publish the Service are protected with two-factor authentication.
In the event ChirpWater becomes aware of a security incident affecting the Service in a manner that could affect users or institutions, ChirpWater will notify affected institutions that have identified themselves to ChirpWater or signed a data privacy agreement with ChirpWater, and any other affected parties as required by applicable law, without unreasonable delay and within the time required by applicable law.
14. Independent review
The source code of the Application is publicly available under an open source license so that the practices described in this statement can be independently reviewed by any institution or individual.
15. Links to other sites
The Website contains links to the Application's source code repository, hosted by a third party. That site is governed by its own privacy policy. ChirpWater is not responsible for the practices of third-party sites.
16. Changes to this statement
ChirpWater may update this statement from time to time. Any revision will be published at this address with a new effective date. Continued availability of the Service under a revised statement does not retroactively alter the practices that applied before the revision. Before a material change to these practices takes effect, ChirpWater will notify any institution that has identified itself to ChirpWater or signed a data privacy agreement with ChirpWater, at least 30 days in advance.
17. Contact
Questions, requests for written confirmation of these practices, and requests to review or execute data privacy agreements should be directed to:
ChirpWater LLCWashington limited liability company, UBI 606118714
522 W Riverside Ave Ste N, Spokane, WA 99201
Jeffrey Green, owner
Telephone (916) 776-6167
jeff@chirpwater.com
Correspondence should not include user writing or personal information about students.