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Privacy Evaluation for Coolmath

Last updated February 19, 2020

Overview

Coolmath Games is a brain-training site, for everyone, where logic & thinking & math meets fun & games. Coolmath's terms do not disclose whether they allow users to make information publicly available or provide social interactions between users. The terms of Coolmath specify that if a user is under 18 years of age, they should have their parent or guardian register, complete purchase, and agree to the terms on the child's behalf. In addition, the terms specify that interest-based advertising or "online behavioral advertising" is displayed to users that includes ad tracking that continues to serve ads to users after they leave the website, encouraging them to return. However, the terms do not disclose whether they provide notification to users in the event of a data breach or other reasonable security practices such as encryption. Lastly, the terms do not disclose additional compliance obligations under COPPA or FERPA if used in an educational institution, or whether users have the ability to access, modify, or delete their personal information.

Coolmath can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Coolmath’s website and the iOS App Store. Additionally, other policies used for this evaluation include: About Our Ads. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Coolmath's terms do not disclose whether they allow users to make information publicly available or provide social interactions between users.

Privacy

The terms of Coolmath disclose that personal and non-personal information are collected from use of the service. In addition, the terms specify that interest-based advertising or "online behavioral advertising" is displayed to users that includes ad tracking that continues to serve ads to users after they leave the website, encouraging them to return. Coolmath's terms state that interest-based advertising includes ads thought to be relevant to users based on their shopping habits or online activities. Lastly, the terms state third-party advertisers may serve interest-based advertising using personal and other information gathered about users over time across multiple websites or other platforms.

Security

The terms of Coolmath state it believes its information security practices reflect good practice, but there is no such thing as perfect information security. As such, the terms state users must assume the risk of security breaches and all consequences resulting from them. However, the terms do not disclose whether they provide notification to users in the event of a data breach or other reasonable security practices such as encryption.

Compliance

The terms of Coolmath specify that if a user is under 18 years of age, they should have their parent or guardian register, complete purchase, and agree to the terms on the child's behalf. However, the terms do not disclose additional compliance obligations under COPPA or FERPA if used in an educational institution, or whether users have the ability to access, modify, or delete their personal information.

Data Collection
SCORE: 15%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • Unclear if the categories of personally identifiable information collected are indicated.
  • Unclear whether the collection or use of data is limited to product requirements.
  • Unclear whether this product collects geolocation data.
  • Unclear whether this product collects biometric or health data.
  • Unclear whether this product collects behavioral data.
  • Unclear whether this product collects sensitive data.
  • Non-personally identifiable information is 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: 40%

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.
  • Unclear whether the categories of third parties that receive personal information are indicated.
  • Unclear whether 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.
  • Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 20%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Account creation is required.
  • Unclear whether 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.
  • Unclear whether this product limits employee or physical access to user information.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether this product encrypts all data at rest.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 20%

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 inaccurate data.
  • A data-retention policy is available.
  • Unclear whether the school, parents, or students can delete data.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 5%

Is the data sold?

  • Unclear whether data are 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.
  • 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 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.
Data Safety
SCORE: 0%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users and/or students.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information is shared for social interactions.
  • Unclear whether this product displays personal information publicly.
  • Unclear whether this product allows users to control how their data are displayed.
  • Unclear whether 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
SCORE: 35%

Are there advertisements or tracking?

  • Unclear whether 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.
  • Unclear whether this 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.
  • Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 50%

Can I provide parental consent?

  • Intended for children under 13.
  • Unclear whether this product collects personal information online from children under 13 years of age.
  • Unclear whether intended for parents or guardians.
  • Vendor does not 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.
  • 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: 30%

Is the product intended for school?

  • 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.
  • 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.

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.