Privacy Evaluation for Adobe Spark EDU
Adobe Spark is an integrated web and mobile solution that enables everyone, especially teachers and their students of all ages to easily create and share impactful visual stories. Adobe Spark provides a free, premium, and education version of its product with two different account types: an Adobe ID, or an Enterprise or Federated ID. The account and content of Adobe IDs are owned and controlled by the student, not the school and are better suited to higher education or adult students over 18 years of age. The Enterprise or Federated ID accounts and content are owned and controlled by the school, not the student, and they are required if used by primary or secondary schools with students in K-12 under 18 years of age.
Adobe Spark's terms state they may market, track, and profile students with Adobe IDs, but these features are turned off by default for Enterprise or Federated ID accounts. Adobe's terms state they provide reasonable administrative, technical, and physical security controls to protect a user’s personal information and content. The terms state users must be 13 or older to register for an individual Adobe ID. Lastly, the terms state schools that use the primary and secondary education product are required to register an enterprise-level Adobe ID for a child under 13, but only after obtaining express parental consent.
Adobe Spark can be accessed through its website and supports three different story applications:
Spark Video lets users turn their story into a captivating animated narrated video in just minutes and is available for download at the iOS App Store.
Spark Page turns stories into modern, professional, attention-grabbing web pages and is available for download at the iOS App Store.
Spark Post enables users to create stunning graphics in seconds and is available for download at the iOS App Store, and the Google Play Store.
Additionally, other policies used for this evaluation include:
- Student Policy
- Adobe Spark– A Guide for Schools & Educators
- K-12 (Primary and Secondary) Education Named User Additional Terms
- California Consumer Privacy Rights
- Guidelines for law enforcement seeking customer data
- Adobe Cloud Services Compliance Overview
- Adobe marketing and advertising practices
- Cookies Policy
- Opt-Out Policy
The terms state that Adobe Spark EDU provides interactive features for users to login and engage with social media sites, such as Facebook, Twitter, or Google. If users use these features, these sites may send Adobe Spark personal information about a user. Schools can also block access to Behance which is a platform that allows users to showcase and discover creative work. Further, Internet image search and Adobe Stock are turned off in Adobe Spark by default for Enterprise or Federated ID accounts. In addition, Adobe Spark allows users to post comments, upload pictures, or submit content which may be publicly available to others. Adobe recommends users be careful when they share their personal information with others and do not share anything they wouldn’t want publicly known unless they are sure they have control over who sees what they post. Lastly, the terms state users are responsible for determining the privacy limitations that are placed on their content and for applying the appropriate level of access to their content. If users do not choose an access level to apply to their content, Adobe Spark may default to its most permissive setting.
Adobe Spark's terms state they may market, track, and profile students with Adobe IDs, but these features are turned off by default for Enterprise or Federated ID accounts. However, the terms state Adobe does not share personal information about users with third parties for their own marketing purposes unless the consumer agreed to that sharing. Lastly, the terms also state Adobe will not sell student data from any type of student account to third parties and will not use personal information in student records to target advertising to any type of account.
Adobe's terms state they provide reasonable administrative, technical, and physical security controls to protect a user’s personal information and content. The terms also state users' personal information and files are stored on Adobe’s servers and they support encryption of personal information while in transit and at rest. Lastly, Adobe's terms state they will notify the student or school in accordance with the relevant breach notification law.
Adobe Spark provides a free, premium, and education version of its product with two different account types: an Adobe ID, or an Enterprise or Federated ID. The account and content of Adobe IDs are owned and controlled by the student, not the school and are better suited to higher education or adult students over 13 years of age. The Enterprise or Federated ID accounts and content are owned and controlled by the school, not the student, and they are required if used by primary or secondary schools with students in K-12 under 18 years of age.
The terms state Adobe cannot agree to act as a ‘school official’ for FERPA purposes as the user agreement is with the individual student, not with the school. However, Adobe's terms state they will respond to data access, correction, and deletion requests about user account information made by an authenticated student. In addition, students can self-access, correct, delete, and export their own stored content at any time.
Enterprise or Federated ID
The terms state Adobe contractually agrees to act as ‘school official’ for FERPA purposes, and to secure student data accordingly. As a data processor for the school, Adobe's terms state they give schools the tools they need to promptly respond to account data access, correction, and deletion requests submitted to them by students or their parents. However, only schools, not students, are empowered to access, correct, and delete student accounts and stored content.
Educators should be aware the FTC’s guidance indicates that an operator such as Adobe acting as a ‘school official’ does not need to obtain direct consent from parents of students using the service—even if they are under the age of 13. COPPA allows schools to act as either as an intermediary for parental consent or “the parent’s agent in the process of collecting personal information online from students in the school context,” where the operator collects users’ personal information only for the use and benefit of the school.
What data does it collect?
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Collection or use of data is limited to product requirements.
- Unclear whether this product collects geolocation data.
- Unclear whether this product collects biometric or health data.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are not collected.
- Data is automatically collected.
- Opt-in consent is requested from users at the time personal information is collected.
- Personal information of users is collected by a third party.
What data does it share?
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
- The purpose for sharing a user's personal information with third parties is indicated.
- The categories of third parties that receive data are indicated.
- Data are shared for analytics.
- Unclear whether data are shared for research and/or product improvement.
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
- Third-party login is supported.
- Contractual limits are placed on third-party data use.
How does it secure data?
- A user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Multi-factor account protection is available.
- Third-parties with access to information are required to provide the same security protections as the company.
- Reasonable security practices are used to protect data.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- Unclear whether all data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Users can create or upload content.
- Users retain ownership of their data.
- Processes to access or review user data are available.
- Processes to modify data are available for authorized users.
- A data-retention policy is available.
- Processes for authorized users to delete data are available.
- A user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Methods are available to restrict who has access to data.
- Processes to download user data are available.
Is the data sold?
- Personal information is not sold or rented to third parties.
- Users can opt out from the disclosure or sale of their data to a third party.
- User information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
- Unclear whether users are notified if their information is transferred to a third party.
- Unclear whether user information can be deleted prior to its transfer to a third party.
- Unclear whether third-party transfers are contractually required to use the same privacy practices.
- User information that is shared is shared in an anonymous or de-identified format.
- Unclear whether the company describes their de-identification process of user information.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
How safe is this product?
- Users can interact with trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Users can control how their data are displayed to others.
- User-created content is reviewed, screened, or monitored by the company.
- User-created content is filtered for personal information before being made publicly visible.
- Social interactions between users are moderated.
- Unclear whether social interactions of users are logged.
- Users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Personal information is not shared for third-party marketing.
- Traditional or contextual advertisements are displayed.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- Users's information is not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for personalised advertisements.
- The company can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected.
- Intended for parents or guardians.
- Company does have actual knowledge that personal information from users under 13 years of age is collected.
- The company does provide a section, heading, or separate policy for children in their policies.
- Parental consent is required before personal information is collected or disclosed.
- Unclear whether this product limits parental consent with respect to third parties.
- Unclear whether this product allows parents to withdraw consent for the further collection of their child's information.
- Unclear whether this product deletes children's personal information if collected without parental consent.
- Parental consent notice and method for submission are provided.
Is the product intended for school?
- Intended for students.
- Personal information or education records are collected from preK-12 students.
- Unclear whether intended for teachers.
- Product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Processes to enter education records into the product are not described.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Company is designated as a school official.
- Parental consent obligations are transferred to the school or district.
Can I control the use of my data?
- Users can control the use of their information through privacy settings.
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- Company may combine data with additional data from third-party sources.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Unclear whether notice is provided if the context in which data are collected changes.
- Unclear whether consent is obtained if the practices in which data are collected change.
- A grievance or remedy mechanism is available for users to file a complaint.
- Unclear whether users can request to know what personal information has been shared with third parties.
- Unclear whether notice is provided in the event the company receives a government or legal request for a user's information.
Common Sense Standard Privacy Report (SPR)
The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.
About Privacy Evaluations
The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.
Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.