Privacy Evaluation for Alison
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.
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.
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.
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.
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.
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.
- Interactions, behaviors, or usage analytics data are collected.
- Unclear whether this product collects sensitive data.
- Data is automatically collected.
- Opt-in consent is requested from users at the time personal information is collected.
- Personal information of users is not 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.
- 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?
- Unclear whether a user's identity is verified with additional personal information.
- Account creation is required.
- Unclear whether managed accounts are available.
- Unclear whether multi-factor account protection is available.
- Unclear whether 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.
- Unclear whether this product limits employee or physical access to user information.
- Unclear whether this product encrypts all data in transit.
- Unclear whether all data are stored in an encrypted format.
- Unclear whether this product provides notice in the event of a data breach.
What rights do I have to the data?
- Users can create or upload content.
- Unclear whether 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.
- Unclear whether this product deletes data when no longer necessary.
- Unclear whether methods are available to restrict who has access to data.
- Unclear whether this product provides users the ability to download their data.
Is the data sold?
- Unclear whether personal information is 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.
- 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.
- Unclear whether user-created content is reviewed, screened, or monitored by the company.
- 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
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Traditional or contextual advertisements are displayed.
- Personalised advertising is displayed.
- Data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for personalised advertisements.
- The company can send marketing messages.
- The company does provide 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?
- Not intended for children under 13.
- Unclear whether this product collects personal information from children under 13 years of age.
- Unclear whether intended for parents or guardians.
- Company does not 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.
- Unclear whether parental consent is required before personal information is collected or disclosed.
- 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.
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.
- Processes to enter education records into the product are described.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Unclear whether the company is designated as a school official.
- Unclear whether this product transfers parental consent obligations to the school or district.
Can I control the use of my data?
- Users can control the use of their information through privacy settings.
- Unclear whether 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.
- Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
- 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.