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Privacy Evaluation for Amazon Fire TV

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Overview

Amazon Fire TV is a video streaming device that integrates Amazon Prime Video and lets users watch other favorites from Netflix, YouTube, Disney+, AppleTV+, HBO Max, and more. Amazon's terms state that users may provide various personal information such as their name, birthdate, address, phone number, voice, photos, videos, and location when creating their Amazon.com account. In addition, on both Amazon sites and unaffiliated sites, Amazon displays interest-based advertising using information users make available when they interact with the sites, content, or services. The terms state that Amazon works to protect the security of users' information during transmission by using Secure Sockets Layer (SSL) software, however, the terms do not describe whether users' data is encrypted while at rest. Lastly, the Amazon terms state they offer services intended for children, and in some cases may know a child is using the services (for example, when using a child profile).

Amazon Fire TV can be accessed through its website. The Privacy Policy and Terms of Use used for this evaluation can be found on Amazon’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Additionally, other policies used for this evaluation include:

Safety

Amazon's policy says a child may be able to share information publicly and with others depending on the products and services used. In addition, the terms say Amazon has the right to monitor and edit or remove any activity or content.

Privacy

The terms say that users may provide various personal information such as their name, birthdate, address, phone number, voice, photos, videos, and location when creating their Amazon.com account. The service may also collect non-personal usage information automatically of certain user activity on the services that include, device information, browser information, and other types of information.

The terms say the service may receive information about users’ location and their mobile device, including a unique identifier for their device which may be used to provide users with location-based services. On both Amazon sites and unaffiliated sites, Amazon displays interest-based advertising using information users make available when they interact with the sites, content, or services. Interest-based ads are displayed to users based on information from activities such as purchasing on the sites, visiting sites that contain Amazon content or ads, interacting with Amazon tools, or using payment services. In providing interest-based ads, the terms say the service follows the self-regulatory principles for online behavioral advertising developed by the Digital Advertising Alliance.

In addition, some third parties may provide Amazon information about users (such as the sites where users have been shown ads or demographic information) from offline and online sources so that the service can provide users advertising, search results, and other personalized content. The terms say the service does not provide any personal information to advertisers or to third party sites that display their interest-based ads and users can generally opt-out of receiving personalized ads from third party advertisers and ad networks. Also, the service does not associate users’ interaction or profile with unaffiliated sites with their identity in providing users with interest-based ads. However, the service does not serve interest-based ads to children when they are using a registered Amazon child profile.

Lastly, the terms say the service uses child personal information to provide and improve their products and services, including personalizing offerings and recommendations for children, communicating information, enforcing parental controls, and giving parents visibility into how their children use the services.

Security

The terms say that Amazon works to protect the security of users' information during transmission by using Secure Sockets Layer (SSL) software. Additionally, the terms say Amazon maintains physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal customer information. However, the terms do not describe whether notification is provided to users in the event of a data breach.

Compliance

The Amazon terms say they offer services intended for children, and in some cases may know a child is using the services (for example, when using a child profile). In addition, the service would likely appeal to children under 13 years of age, which take into account several factors that include subject matter, visual content, age of models, and the activities provided.

The terms specify that Amazon does not sell products to children, but it does sells products to adults, who can purchase products with a credit card or other permitted payment method. If a user is under 18, they may use the services only with involvement of a parent or guardian who must provide verifiable parental consent. In addition, parents and guardians may create profiles for teenagers. The terms state the service does not knowingly collect, use, or disclose child personal information without parental consent and parents may withdraw consent provided for their child or request deletion of child personal information at any time.

Rating

This product received a Warning rating based on the following details:
  • Personal information is not sold or rented to third parties.
  • Unclear whether personal information are shared for third-party marketing.
  • 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.
Data Collection
SCORE: 55%

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.
  • 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.
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.
  • 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.
  • Unclear whether this product supports third-party login.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 55%

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.
  • Unclear whether this product limits employee or physical access to user information.
  • 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.
Data Rights
SCORE: 55%

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.
  • Unclear whether 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.
Data Sold
SCORE: 35%

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.
  • Third-party transfer is 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.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 25%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether 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
SCORE: 50%

Are there advertisements or tracking?

  • Unclear whether personal information are 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.
Parental Consent
SCORE: 65%

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.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Parental consent notice and method for submission are provided.
School Purpose
SCORE: 13%

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 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.
Individual Control
SCORE: 45%

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.