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Privacy Evaluation for Amazon Kids+

Last updated May 20, 2021

Overview

Amazon Kids+ is an all-in-one subscription service for kids that offers unlimited access to over 10,000 kids’ books, movies, and TV shows for children 3–12 years old. This educational app is filled with content from brands like Disney, Nickelodeon, Sesame Street, PBS Kids, National Geographic and Amazon Originals for Kids. Amazon's privacy policy notes that users may post reviews, comments, photos, videos, and other content. Amazon's policy explains personal information from children may be used to provide and improve Amazon's 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 products and services.

However, Amazon's terms say they will not serve interest-based ads to children when they are using an Amazon child profile. Amazon's policy also says 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 Amazon may collect personal information from children that requires verifiable parental consent under the Children's Online Privacy Protection Act (COPPA).

Amazon Kids+ can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Amazon’s website, iOS App Store, and the Google Play Store. 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 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 children using Kids+ with Alexa enabled, 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 Kids+ experience by visiting Settings > Kids+ in the app, and the Amazon Parent Dashboard allows parents to see their child's Kids+ on Alexa activity, including which skills their child has used.

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. 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. Amazon's terms state they will not serve interest-based ads to children when they are using an Amazon child profile, which includes prohibitions on tracking.

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

Amazon's policy states they maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal customer information. In addition, the terms say Amazon works to protect the security of users' personal information during transmission over the internet by using encryption protocols and software. However, the terms do not say whether Amazon provides notice to users in the event of a data breach.

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. However, Amazon's policy states that it 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 products only with the involvement of a parent or guardian. In addition, by default, approval will be required for each 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 Kids+ app.

Further, Amazon's policy reserves the right (but not the obligation) to remove or edit 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: 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.