Privacy Evaluation for Amazon Alexa
Amazon describes its Alexa product as allowing users to instantly connect to Alexa to play music, control your smart home, and get information, news, weather, and more using just your voice. For Alexa, Amazon's policy states that it will store user messages in the cloud so that they’re available on the user's Alexa App and select Alexa Enabled Products. Amazon's policy explains that it will gather personal information, and the information it learns from customers helps them personalize and continually improve the user's Amazon experience. While the policy describes an account for the initial setup, for "hands free" devices, like the Amazon Echo, a user can access Alexa by saying the wake word (Alexa, Echo, Amazon, or Computer). The policy indicates that parental controls are available, and parents can add or update certain information.
Amazon's policy explains that it will gather personal information, and the information it learns from customers helps them personalize and continually improve the user's Amazon experience. For example, the Echo Look device uses photos to recommend new garments that will pair well with the tops and bottom the user wore. In order to receive recommendations, the photo must be taken with the Echo Look device and contain a visible outfit with a top and bottom (they can't currently provide pairing recommendations for dresses). With regard to third parties, Amazon's policy states that they do not have access to, or control over, cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by their Privacy Notice or this Interest-Based Ads page.
However, Amazon's policy explains that it intends transparency in that a user can tell when a third party is involved, and it intends to minimize sharing in that it shares customer information related to those transactions with that third party. Also, Amazon's policy states that it does not provide any personal information to advertisers or to third party sites that display interest-based ads. Third party providers have access to personal information needed to perform their functions, but may not use it for other purposes. Advertising preferences and customer communication preferences are available to adjust settings for personal information.
For Amazon Alexa products, the policy states that users provide their phone number when registering for Alexa Communication. For security purposes, the policy notes that Amazon will verify this number by sending the user an SMS message (carrier charges may apply). The policy explains that other users who know the user's contact details will be able to contact them using Alexa Communication, and that registration name and contact details may be used to identify the user to other users, and that the user's phone number also may be displayed as a caller ID on outbound calls. While the policy describes an account for the initial setup, for "hands free" devices, like the Amazon Echo, a user can access Alexa by saying the wake word (Alexa, Echo, Amazon, or Computer). For other devices, like certain Fire tablets, the policy details that a person can access Alexa by pressing a button. Amazon's policy states that it works to protect the security of user information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information the user inputs.
Amazon's policy notes that they offer some services intended for children, and in some cases they may know a child is using the services (for example, when using a child profile). In these situations, the policy notes that children may share and Amazon may collect personal information that requires verifiable parental consent under the Children's Online Privacy Protection Act (collectively, "Child Personal Information"). However, its policy states that Amazon.com does not sell products for purchase by children, they only sell children's products for purchase by adults. If a user is under 18, the policy insists that user may use Amazon.com only with the involvement of a parent or guardian. In addition, by default, approval will be required for each voice purchase from Amazon through a kid skill before the purchase will be completed. Parents can allow purchases in kid skills without additional approval by changing this default setting in their Alexa app.
Further, Amazon's policy reserves the right (but not the obligation) to remove or edit such content, but also notes that it does not regularly review posted content. The policy indicates that parental controls are available, and parents can add or update certain information. However, Amazon notes that when a user updates information, it usually keeps a copy of the prior version for its records. Finally, the policy details that the company will use child personal information to provide and improve products and services, including personalizing offerings and recommendations for children, communicating information, enforcing parental controls, and giving parents visibility into how their children use products and services.
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 not limited to product requirements.
- Geolocation data are collected.
- Biometric or health data are collected.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are 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.
- 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.
- Unclear whether this product supports third-party login.
- 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.
- 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.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- 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.
- Data are deleted when no longer necessary.
- Unclear whether 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.
- Unclear whether 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.
- 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.
- 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.
- Unclear whether 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.
- Parents can withdraw consent for the further collection of their child's information.
- Children's personal information is deleted if collected without parental consent.
- Parental consent notice and method for submission are provided.
Is the product intended for school?
- Unclear whether 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 not 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.
- Unclear whether company may combine data with additional data from third-party sources.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Notice is provided if the context in which data are collected changes.
- Consent is obtained if the practices in which data are collected change.
- A grievance or remedy mechanism is not 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.