Privacy Evaluation for Amazon Kindle
The Amazon Kindle app puts millions of books at children's' and student's fingertips. The app is great for every reader, whether they are a book reader, magazine reader, or newspaper reader—and they don’t need to own a Kindle to use it. The Amazon Kindle app allows children to share information publicly with others and post comments or book reviews on other user's profiles through the use of a GoodReads account. The Amazon Kindle 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. The terms state that Amazon Kindle 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 Kindle 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).
Additionally, other policies used for this evaluation include:
- Protecting Your Privacy
- Interest-Based Ads
- EU-US and Swiss-US Privacy Shield
- Children's Privacy Disclosure
- California Consumer Privacy Act Disclosures
Amazon's policy says it allows children to share information publicly with others and post comments or book reviews on other user's profiles through the use of a GoodReads account. The terms state Amazon has the right, but not the obligation to monitor and edit or remove any activity or content posted on the Service.
The terms state 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 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 state 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 state 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.
The terms state 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.
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). 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 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.
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 limited to product requirements.
- Geolocation data are collected.
- Biometric or health data are collected.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is 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 personal information are indicated.
- Data are shared for analytics.
- Unclear whether 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.
How does it secure data?
- A user's identity is verified with additional personal information.
- Account creation is required.
- 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.
- Employee or physical access to user information is limited.
- 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.
What rights do I have to the data?
- Users can create or upload content.
- 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's data are deleted upon account cancellation or termination.
- Unclear whether this product deletes data when no longer necessary.
- Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
- Processes to download user data are available.
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.
- 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 is shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification process of user information.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
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.
- Users can control how their data are displayed.
- User-created content is reviewed, screened, or monitored by the vendor.
- 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?
- Data are 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.
- Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
- Users can opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Not intended for children under 13.
- Personal information from children under 13 years of age is collected online.
- 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.
- 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.
- 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.
- 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.