Privacy Evaluation for Alison
Overview
Alison is one of the world’s largest free learning platforms for education and skills training. It is an advertising supported platform that makes it possible for anyone to study anything, anywhere, at any time, for free online and at any subject level. The terms state that users can interact with trusted and untrusted users and/or students on the platform. The terms state that in order to use certain features of the services, such as registering for a course, a user is required to register for an account. Lastly, the terms state that children under the age of 13 are not allowed to use the services. If Alison learns that it has collected personal information from a child under 13 they will take steps to delete the information immediately.
Alison can be accessed through its website. The Privacy Policy and Terms of Use used for this evaluation can be found on Alison’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service. The terms do not state whether Alison sells user data to third parties, but does disclose they use a user's personal information to send them third-party marketing communications.
Safety
The terms state that users can interact with trusted and untrusted users and/or students on the platform. Users can post, share, communicate or otherwise transmit content publicly, such as by posting comments in a Course page, sending messages to others, submitting testimonials or posting photos. Users should keep in mind shared content or public postings may be publicly available or viewable by others depending on where content is posted.
Privacy
The terms state the service will collect and store any registration information a user provides, such as e-mail address, password, date of birth, and age, and the service will assign users a unique identifying number for their coursework. The service also tracks and collects usage data that includes statistics about a user's interaction with the services, including courses accessed, time spent on pages, pages visited, search queries, click data, portions of the services used, date and time, and other information regarding a user's use of Alison.
The terms do not state whether Alison sells user data to third parties, but does disclose they use a user's personal information to send them third-party marketing communications. In addition, the terms state the service may display targeted ads to users based on collected information such as the content of the pages a user is visiting, information a user enters in their coursework, a user's age and gender, their searches, demographic data, user-generated content, and any other information Alison collects about a user. The terms state the service also uses third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to track users and their devices in order to deliver targeted advertising on other websites and in mobile applications across the internet.
Security
The terms state that in order to use certain features of the services, such as registering for a course, a user is required to register for an account. In addition, the terms state Alison takes appropriate security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of users's data. However, the terms do not provide any additional information about the security procedures used to protect personal information and do no not disclose whether notice is provided to users in the event of a data breach.
Compliance
The terms state that children under the age of 13 are not allowed to use the services. If Alison learns that it has collected personal information from a child under 13 they will take steps to delete the information immediately. In addition, the terms state the service allows users to access, modify, and delete their personal information at any time. If the service is used in a school or district to allow students to create education records, then educators should check with their local school or district student data privacy compliance obligations before use.
Rating
- Unclear whether data are sold or rented to third parties.
- Data are shared for third-party advertising and/or marketing.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for data enhancement, and/or targeted advertisements.
Data Collection
SCORE: 30%
What data does it collect?
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Unclear whether the collection or use of data is limited to product requirements.
- Geolocation data are collected.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- Unclear whether this product collects sensitive data.
- Non-personally identifiable information is collected.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Unclear whether this product collects personal information online from children under 13 years of age.
Data Sharing
SCORE: 80%
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.
- Unclear whether use of information is limited to the purpose for which it was collected.
- Data are shared for analytics.
- Data are shared for research and/or product improvement.
- Data are shared with third-party service providers.
- The roles of third-party service providers are indicated.
- Social or federated login is supported.
- Contractual limits are placed on third-party data use.
Data Security
SCORE: 20%
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Account creation is required.
- Unclear whether parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
- Unclear whether third-party contractual security protections are required.
- Industry best practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
- Unclear whether this product encrypts all data in transit.
- Unclear whether this product encrypts all data at rest.
- Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 75%
What rights do I have to the data?
- Opt-in consent is requested from users at the time personal information is collected.
- Users can control their information through privacy settings.
- Users can create or upload content.
- Unclear whether users retain ownership of their data.
- Processes to access and review user data are available.
- Processes to modify inaccurate data are available.
- A data-retention policy is available.
- Processes for the school, parents, or students to delete data are available.
- Processes to delete user data are available.
- Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 30%
Is the data sold?
- Unclear whether data are 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.
- 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 is shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification process of user information.
- Data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 35%
How safe is this product?
- Users can interact with trusted users and/or students.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
- Personal information is displayed publicly.
- Users can control how their data are displayed.
- Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
- Unclear whether user-created content is filtered for personal information before being made publicly visible.
- Unclear whether social interactions between users are moderated.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 60%
Are there advertisements or tracking?
- Data are shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are displayed.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for data enhancement, and/or targeted advertisements.
- The vendor can send marketing messages.
- The vendor does provide promotional sweepstakes, contests, or surveys.
- Users can opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 50%
Can I provide parental consent?
- Not intended for children under 13.
- Unclear whether intended for parents or guardians.
- Vendor does not have actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- Unclear whether this product indicates COPPA parental consent exceptions.
- Unclear whether this product requires parental consent.
- Unclear whether this product limits parental consent with respect to third parties.
- Parents can withdraw consent for the further collection of their child's information.
- Children's personal information is deleted if collected without parental consent.
- Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 20%
Is the product intended for school?
- Intended for students.
- Unclear whether personal information or education records are collected from preK-12 students.
- Unclear whether intended for teachers.
- Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Product does create education records.
- Unclear whether this product provides notification of a contract or additional rights.
- Unclear whether this product designates the vendor as a school official.
- Unclear whether this product transfers parental consent obligations to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory 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.