Privacy Evaluation for Apple Watch
Apple Watch is a smartwatch app that incorporates fitness tracking and health-oriented capabilities. Apple’s terms state that protecting children is an important priority for everyone at Apple. Apple believes in transparency and giving parents the information they need to determine what is best for their child. In addition, Apple's terms state that security and privacy are fundamental to the design of all Apple hardware, software, and services. Lastly, Apple's terms state they understand the importance of taking extra precautions to protect the privacy and safety of children using Apple products and services.
Additionally, other relevant policies used for this evaluation include:
- Privacy Principles
- Approach to Privacy
- Family Privacy Disclosure for Children
- Apple Media Services Terms and Conditions
- iCloud Terms and Conditions
- iCloud Security Overview
- iOS Security Guide
- Your California Privacy Disclosures
- iOS Software License Agreement
Apple’s terms state that protecting children is an important priority for everyone at Apple. Apple believes in transparency and giving parents the information they need to determine what is best for their child. The terms state Apple works hard to offer controls for parents that are intuitive and customizable. By creating an Apple ID for their child, a parent enables them to enjoy the same Family Sharing features as the parent and other family members. A child's Apple ID allows them to share music, movies, TV shows, books, applications, photos, calendars, location data and complete tasks with parents and their family. A child is also able to have their own personalized Apple ID experience using all of the services and content available to an Apple ID account holder.
However, parents should be aware that their child may share information with others depending on the Apple features and services that he or she uses, that may include their child’s name and contact information. Apple's terms state they offer interactive services which allow users to post content to share publicly and that personal information and content users share may be visible to other users and can be read, collected, or used by them. Lastly, the terms state there may be times when parents want to limit their child's access to certain types of content or resources available to the rest of the Family. To help parents manage their child's access to Apple ID services and features, Apple offers a few different sets of controls for parents that include Restrictions, Screen Time, and Family Sharing.
Apple's terms state they believe privacy is a fundamental human right, and build privacy and security into all their products from the ground up, including their apps and services. When a parent creates an Apple ID, the terms state Apple may collect a variety of information, including their name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information and credit card information. In addition, when a parent creates an Apple ID for their child, Apple may collect device identifiers, cookies, IP addresses and the geographic locations and time zones in which his or her Apple device is used.
The terms state personal information will only be shared by Apple to provide or improve their products, services and advertising by third party apps. Personal information will not be shared with third parties for their own marketing purposes. However, Apple may use, transfer and disclose non-personal information for any purpose. This means that Apple’s websites, online services, interactive applications, email messages, and third-party app advertisements may use tracking technologies to help Apple better understand user behavior, tell the company which parts of their websites people have visited, and facilitate and measure the effectiveness of advertisements and searches. In third-party apps, users may see ads based on other information, but a child's Apple ID may still be able to receive non-targeted advertising on those devices.
Apple's "Limit Ad Tracking" control is enabled by default for all devices associated with a child's Apple ID, to ensure they do not receive targeted advertising from third-party apps. In addition, third-party apps in the Kids Category of the App Store are prohibited from serving behavioral advertisements to children. Lastly, Apple's terms state they do not track their customers over time and across third party websites to provide targeted advertising, and do not take any decisions involving the use of algorithms or profiling that would significantly affect users.
Apple's terms state that security and privacy are fundamental to the design of all Apple hardware, software, and services. Apple takes an integrated approach to ensure that every aspect of the user's experience has security and privacy built in. The terms state that when personal data is stored by Apple, they use computer systems with limited access housed in facilities using physical security measures. Apple's terms state they communicate privacy and security guidelines to all Apple employees and strictly enforce privacy safeguards within the company.
Additionally, the terms state iCloud is built with industry-standard security practices and employs strict policies to protect data. iCloud secures user data by encrypting it when it’s sent over the Internet, storing it in an encrypted format when kept on the server, and using secure tokens for authentication. The terms specify this means that user data is protected from unauthorized access both while it is being transmitted to devices and when it is stored in iCloud. iCloud uses a minimum of 128-bit AES encryption, and never provides encryption keys to any third parties. Apple retains the encryption keys in our own data centers and iCloud also stores Apple ID passwords and credentials in such a way that Apple cannot read or access them.
Lastly, Apple's terms state that end-to-end encryption requires that users have two-factor authentication turned on for their Apple ID. Keeping software up-to-date and using two-factor authentication are the most important things that users can do to maintain the security of their devices and data.
The terms state that in order to comply with the Children's Online Privacy Protection Act (COPPA), which covers the online collection of data from children, Apple may take additional steps to verify that the user granting permission for the creation of a child's Apple ID is his or her parent or legal guardian. Accordingly, parents will be asked to verify their current iTunes, iCloud or Apple Store payment method. Depending on the payment method, this may be done by methods such as the security code from a credit card or a round-trip SMS verification. The terms state Apple requests this information so that they may verify a parent's identity as the Family Organizer and obtain their consent to the collection of personal information from their child. If at any time a parent would like to access, correct or delete data associated with Family Sharing or their child's Apple ID, they should contact Apple.
Lastly, Apple's terms state it is important for parents to be aware that third-party apps may be collecting data about children. Parental consent does not apply to the data collection practices of any third parties. Third parties, including the developers of apps downloaded by any Family member and accessible by a child through Family Sharing, may collect, use, or disclose a child's information, and these third parties are responsible for obtaining separate verifiable consent. Apple's terms encourage parents to ask their child to check with them before they grant access to any of their personal information to third-party apps.
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.
- Combined information is treated as personally identifiable information (PII).
- Personal information from children under 13 years of age is collected online.
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 limited to the purpose for which it was collected.
- Unclear whether data are shared for analytics.
- Data are not shared for research and/or product improvement.
- Data are shared with third-party service providers.
- The roles of third-party service providers are indicated.
- Social or federated login is not supported.
- 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.
- Two-factor account protection is available.
- 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.
- All data at rest are encrypted.
- Unclear whether this product provides notice in the event of a data breach.
What rights do I have to the data?
- 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.
- 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.
- Processes to delete user data are available.
- 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.
- 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.
- User information is shared in an anonymous or deidentified format.
- The vendor describes their deidentification process of user information.
- Data are not shared for research and/or product improvement.
- Contractual limits prohibit third parties from reidentifying deidentified information.
How safe is this product?
- Users can interact with 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.
- User-created content is not filtered for personal information before being made publicly visible.
- Unclear whether social interactions between users are moderated.
- Social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
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 not displayed.
- Data are not collected by third-party advertising or tracking services.
- Data are not used to track and target advertisements on other third-party websites or services.
- Data profiles are not 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.
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.
- Unclear whether this product indicates COPPA parental consent exceptions.
- Parental consent is required.
- Unclear whether this product limits parental consent with respect to third parties.
- Unclear whether this product allows parents to 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.
- Product does create 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.