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Privacy Evaluation for Amazon Alexa

Last updated October 7, 2019

Overview

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 Alexa can be accessed through its website, and is available for download at the iOS App Store, the Google Play Store, and/or Amazon Appstore. The Privacy Policy and Terms of Use used for this evaluation can be found on Amazon Alexa’s website, iOS App Store, the Google Play Store, and/or Amazon Appstore. Additionally, other policies used for this evaluation include: Children's Privacy Disclosure. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Amazon's privacy policy notes that users may post reviews, comments, photos, videos, and other content; send e-cards and other communications; and submit suggestions, ideas, comments, questions, or other information. Amazon's policy states that it reserves the right (but not the obligation) to remove or edit such content, but does not regularly review posted content. 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. For children using FreeTime on Alexa, Alexa will play music, answer questions, read stories, tell jokes, and more with younger ears in mind. The policy explains that a parent user can set up and manage their child's FreeTime on Alexa experience by visiting Settings > FreeTime in the Alexa app, and the Amazon Parent Dashboard allows parents to see their child's FreeTime on Alexa activity, including which skills their child has used. Like other voice recordings with Alexa, the policy explains that parents can review and delete FreeTime on Alexa voice recordings by visiting Settings > Alexa Account > History in the Alexa app.

Privacy

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.

Security

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.

Compliance

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.

Data Collection
SCORE: 35%

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).
  • Personal information from children under 13 years of age is collected online.
Data Sharing
SCORE: 75%

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.
  • Use of information is not 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.
  • Unclear whether this product supports social or federated login.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 25%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Unclear whether this product requires account creation.
  • 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.
  • All data in transit are encrypted.
  • 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: 55%

What rights do I have to the data?

  • Unclear whether 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.
  • Unclear whether a user can delete all their data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 30%

Is the data sold?

  • Data are 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.
  • 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 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: 40%

How safe is this product?

  • Unclear whether this product supports interactions between 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.
  • Unclear whether this product allows users to control how their data are displayed.
  • User-created content is not reviewed, screened, or monitored by the vendor.
  • User-created content is not filtered for personal information before being made publicly visible.
  • Social interactions between users are not moderated.
  • Social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 65%

Are there advertisements or tracking?

  • Data are not 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: 70%

Can I provide parental consent?

  • Intended for children under 13.
  • Intended for parents or guardians.
  • Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
  • Children's privacy is applicable.
  • COPPA parental consent exceptions are indicated.
  • Parental consent is required.
  • 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.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 0%

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.
  • Unclear whether the product creates 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.