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Privacy Evaluation for 123 Toddler games for 3+ years

Last updated

Overview

Colors Train: Learning Colors - Interactive Fun Educational Games offers children an engaging way to master color identification and vocabulary by placing an object of a particular color into a train. The terms do not disclose whether any social interactions between users are available or whether a user can make personal information publicly visible to others. The terms also do not disclose whether the service sells a user's data to third parties, or whether it allows third-party advertising companies to collect a user's data through the service for ad targeting, tracking, or creating a profile for marketing purposes. In addition, the terms do not disclose sufficient details about data security standards that should be used to protect the confidentiality of a user's information. Lastly, the terms state the service does not knowingly contact or collect personal information from children under 13. However, teachers and parents should be aware that by providing permission for their child to use this app, they are potentially giving the service permission to collect and use data that would be considered personal information under COPPA.

Colors Train: Learning Colors is available for download at the iOS App Store. The Privacy Policy used for this evaluation can be found on Colors Train: Learning Color’s website, and the iOS App Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Colors Train: Learning Colors - Interactive Fun Educational Games does not provide any social interactions between users or make a user's personal information publicly visible to others.

Privacy

Colors Train: Learning Colors - Interactive Fun Educational Games states they do not collect personally identifiable information about users of their apps. In addition, the Company states they do not use or collect a user's precise geographic location.

The Company does collect usage information from users to help them improve their Services, and the Company may use third-party analytics to collect a user's mobile device type, unique device identifiers, app session time, events, and duration using the app. The terms also state that, in some circumstances, the Company might make identifiable and/or anonymous information available to third parties with a user's express consent. However, it is not clear whether or how the Company requests that express consent.

The terms state that the Company does not allow third-party advertising companies to collect a user's data through the service for ad targeting. However, the terms do not provide details about the behavioral data it may collect from learners' activities while using the app.

Security

The terms of Colors Train: Learning Colors - Interactive Fun Educational Games do not contain significant details about data security standards that should be used to protect the confidentiality of a user's information. The terms also lack detail about whether a user's data is encrypted while in transit or at rest.

Compliance

Colors Train: Learning Colors - Interactive Fun Educational Games is an app directed to children and students under the age of 13. The Company states they do not knowingly contact or collect personal information from children under 13. If a user believes the Company has inadvertently collected information from a child under 13 years of age, they should contact the Company so they can promptly obtain parental consent or remove the personal information. Parents should take note that free and paid apps from the Company may contain non consumable in-app purchases.

However, COPPA defines some persistent identifiers - such as IP address, some cookie values, and unique device identifiers - as personal information in some cases. Based on the information that is collected by the application and by third party service providers, COPPA could apply to this application. Accordingly, teachers and parents should be aware that by providing permission for their child to use this app, they are potentially giving the Company permission to collect and use information that would be considered sensitive under COPPA.

Rating

This product received a Warning rating based on the following details:
  • Unclear whether personal information is sold or rented to third parties.
  • Unclear whether personal information are shared for third-party marketing.
  • Unclear whether this product displays personalised advertising.
  • Unclear whether data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
Data Collection
SCORE: 40%

What data does it collect?

  • Personally identifiable information (PII) is not 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 not collected.
  • Unclear whether this product collects biometric or health data.
  • Unclear whether this product collects interactions, behaviors, or usage analytics data.
  • Unclear whether this product collects sensitive data.
  • 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: 10%

What data does it share?

  • Unclear whether collected information is shared with third parties.
  • Unclear whether the categories of information shared with third parties are indicated.
  • Unclear whether the purpose for sharing a user's personal information with third parties is indicated.
  • Unclear whether the categories of third parties that receive data are indicated.
  • Data are not shared for analytics.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether third-party services are used to support the product.
  • Unclear what the roles of third-party service providers are.
  • Unclear whether this product supports third-party login.
  • Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 5%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Unclear whether this product requires account creation.
  • 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: 0%

What rights do I have to the data?

  • Unclear whether users can create or upload content.
  • Unclear whether users retain ownership of their data.
  • Unclear whether this product provides processes to access and review user data.
  • Unclear whether this product provides processes to modify data for authorized users.
  • Unclear whether the product provides a data-retention policy.
  • Unclear whether authorzied users can delete data.
  • 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: 30%

Is the data sold?

  • Unclear whether personal information is sold or rented to third parties.
  • Users can opt out from the disclosure or sale of their data to a third party.
  • Unclear whether 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.
  • 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: 0%

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.
  • Unclear whether 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: 0%

Are there advertisements or tracking?

  • Unclear whether personal information are shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Unclear whether this product displays personalised advertising.
  • Unclear whether data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
  • Unclear whether this company can send marketing messages.
  • Unclear whether this company provides promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
  • Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 50%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is not collected.
  • Unclear whether intended for parents or guardians.
  • Company does not have 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.
  • 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.
  • Children's personal information is deleted if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 0%

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 not 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: 10%

Can I control the use of my data?

  • Unclear whether users can control the use of their information through privacy settings.
  • Use of information is limited to the purpose for which it was collected.
  • Unclear whether the conext 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.
  • Unclear whether 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.