If you are curious, WPI's IRB has approved ASSISTments under the exemption categories of "comparing normal instructional strategies" and exemption number 2 And under 45 CFR 46.101(b)(2): related to the fact that you will never know who these students are. If WPI thinks your study is "comparing normal instructional strategies. See the approval letter we operate under. By signing this form, you show us you understand that you are not allowed to try to re-identify participants (we don't think you could, but WPI needs you to agree to not to try). It also tells your IRB that you have agreed to that as well.
These Terms of Use governed three grants
#15-161 Virtual Online Learning Testbed (VOLT)
#14-128 Adding Research Accounts to the ASSISTments Platform: Helping Researchers Do Randomized Controlled Studies with Thousands of Students
#15-141 BIGDATA: F: IA: Smart Crown-Sourced Interventions to Maximize Long-Term Outcomes in Scale Educational Platform