Privacy Evaluation for Calm
45%
Overview
Calm is a relaxation and self-improvement service. The terms indicates that Calm monitors user content to ensure it is compliant with the Terms of Service. The Privacy Policy clearly discloses that Calm collects personal information, including identifiers, geolocation data, sensitive information, commercial information, internet network activity, audio electronic and visual information, and professional, employment, and education information. The terms fail to disclose what information is shared with third parties and state that third parties may gather information from various partners and websites, including Calm, to serve users with targeted advertisements. The terms do not disclose what security measures are implemented by Calm, if any, to protect users’ personal information. The Terms of Service clearly prohibit individuals who are under the age of 13 from using Calm’s services.
Calm 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 Service used for this evaluation can be found on Calm’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Cookie Notice. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The terms do not clearly indicate whether users may interact with other users, whether users’ personal information can be displayed publicly in any way, or whether users have control over the visibility of their personal information. The Terms of Service indicate that Calm monitors user content for compliance with its terms. The terms do not indicate whether users can report inappropriate content, harassment, or cyberbullying.
Privacy
The Privacy Policy discloses that Calm collects identifiers, including names, phone numbers, email addresses, social media handles, and unique identifiers tied to the user’s browser or device; sensitive personal information including gender and age; payment information; approximate geolocation data; internet and other electronic network activity, such as browsing behavior and information about a user’s usage and interactions with Clam’s Services. The Privacy Policy further states that third parties collect users’ personal information and that Calm shares users’ personal information with third parties. The Privacy Policy does not disclose what categories of personal information are disclosed to third parties.
The Privacy Policy provides that Calm shares users’ personal information to its parents, affiliates, subsidiaries, and other companies, along with its third-party service providers. The Privacy Policy discloses that Calm shares personal information to third parties for analytical purposes, research and product improvement, and for marketing purposes. The Privacy Policy indicates that users may login through social media platforms, and that Calm collects information from the associated platform and shares personal information with the platform. The Privacy Policy explains that the California Consumer Privacy Act provides consumers the right to opt out of "sales" that may be occurring, however, the Privacy Policy does not clearly indicate whether Calm complies by providing this right to its consumers. The Privacy Policy states that users are subject to targeted advertising both on and off of Calm’s services, and that users can opt out of certain targeted advertising companies. The Privacy Policy clearly provides that Calm may send promotional messages to users, and that users can opt out of receiving promotional messages.
Security
The Privacy Policy states that Calm will verify user privacy requests by asking users to provide information that matches the information Calm has on file. The Terms of Service indicate that an account is not required to use Calm’s services, however, that certain features of the services will require an account. The terms otherwise fail to disclose whether reasonable security measures are implemented to protect the confidentiality of users’ personal information, or whether Calm encrypts user data in storage or in transit. The terms do not indicate whether the security of a user’s account is protected by multi-factor authentication, or whether physical access controls are utilized to protect user data. The terms fail to address whether Calm provides users with notice in the event of a security breach. The terms have no section detailing Calm’s security practices.
Compliance
The Terms of Service clearly provide that users can create or upload content to Calm, and that Calm does not claim any ownership rights in any user content. The Privacy Policy states that users, and a designated agent, can access, correct, erase, or download the user’s personal information. The Privacy Policy does not clearly indicate whether users’ personal information is deleted upon account deletion, or how long any privacy request may take.
The Terms of Service clearly prohibit children under the age of 13 from using Calm’s services, however, the Privacy Policy indicates that Calm may collect information about teachers and other administrators in connection with the “Calm Schools Initiative.” Otherwise, the terms do not provide a section for Children’s Privacy, do not state whether Calm knowingly collects personal information from children under the age of 13, and fail to provide any method for parents or schools to give consent for the collection of children’s personal information.
Data Collection
SCORE: 45%
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.
- Unclear whether 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: 70%
What data does it share?
- Collected information is shared with third parties.
- Unclear whether 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.
- 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.
- Third-party login is supported.
- Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 15%
How does it secure data?
- A user's identity is verified with additional personal information.
- Account creation is not required.
- Unclear whether 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.
- Unclear whether this product uses reasonable security practices to protect data.
- Unclear whether this product limits employee or physical access to user information.
- Unclear whether this product encrypts all data in transit.
- Unclear whether 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.
- Unclear whether the product provides a data-retention policy.
- 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.
- Processes to download user data are available.
Data Sold
SCORE: 20%
Is the data sold?
- Personal information is not sold or rented to third parties.
- Unclear whether 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.
- Unclear whether third-party transfers are 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.
- 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: 10%
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.
- Unclear whether personal information can be displayed publicly.
- Unclear whether this product allows users to 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: 55%
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- 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.
- The company does provide 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: 10%
Can I provide parental consent?
- Not intended for children under 13.
- Unclear whether this product collects personal information from children under 13 years of age.
- Unclear whether intended for parents or guardians.
- Unclear whether company has actual knowledge that personal information from users under 13 years of age is collected.
- The company does not provide a section, heading, or separate policy for children in their policies.
- Unclear whether parental consent is required before personal information is collected or disclosed.
- 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.
- 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: 38%
Is the product intended for school?
- Unclear whether intended for students.
- Unclear whether personal information or education records are collected from preK-12 students.
- Intended for teachers.
- 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: 20%
Can I control the use of my data?
- Unclear whether 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).
- Unclear whether notice is provided if the context in which data are collected changes.
- Consent is obtained if the practices in which data are collected change.
- Unclear whether a grievance or remedy mechanism is 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.