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Privacy Evaluation for CoughDrop

Last updated March 16, 2021

Overview

CoughDrop is an augmentative and alternative communication app that can be installed on existing devices. The terms of CoughDrop do not disclose whether any social interactions are available between users, or whether any personal information or content may be made publicly visible to others. CoughDrop's terms do state they collect personal information such as name, postal address, email address, telephone number and biographic data, along with other information collected automatically when users visit the service. The terms are not clear whether the service will use any of the collected information to display advertisements on the service. However, CoughDrop's terms state they will not share or sell your information to any outside organization without your consent. Additionally, the terms of CoughDrop state children under the age of 13 may use the Site and/or the Product solely with the express consent of their parent or guardian, but are not clear how consent may be collected.

CoughDrop 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 Use used for this evaluation can be found on CoughDrop’s website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Data Collection
SCORE: 75%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • Collection or use of data is limited to product requirements.
Not yet answered
  • Did not evaluate whether the categories of collected personally identifiable information are indicated.
  • Did not evaluate whether this product collects geolocation data.
  • Did not evaluate whether this product collects biometric or health data.
  • Did not evaluate whether this product collects behavioral data.
  • Did not evaluate whether this product collects sensitive data.
  • Did not evaluate whether this product collects non-personally identifiable information.
  • Did not evaluate whether opt-in consent is requested from users at the time personal information is collected.
  • Did not evaluate whether personal information of users is collected by a third party.
Data Sharing
SCORE: 50%

What data does it share?

  • Collected information is shared with third parties.
  • The categories of information shared with third parties are indicated.
  • Unclear whether this product supports social or federated login.
  • Unclear whether contractual limits are placed on third-party data use.
Not yet answered
  • Did not evaluate whether the purpose for sharing a user's personal information with third parties is indicated.
  • Did not evaluate whether the categories of third parties that receive personal information are indicated.
  • Did not evaluate whether data are shared for analytics.
  • Did not evaluate whether data are shared for research and/or product improvement.
  • Did not evaluate whether data are shared with third-party service providers.
  • Did not evaluate whether the roles of third-party service providers are indicated.
Data Security
SCORE: 33%

How does it secure data?

  • Account creation is required.
  • Unclear whether parental controls or managed accounts are available.
  • Industry best practices are used to protect data.
  • 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.
Not yet answered
  • Did not evaluate whether a user's identity is verified with additional personal information.
  • Did not evaluate whether two-factor account protection is available.
  • Did not evaluate whether third-party contractual security protections are required.
  • Did not evaluate whether this product limits employee or physical access to user information.
Data Rights
SCORE: 63%

What rights do I have to the data?

  • Users can create or upload content.
  • Unclear whether this product provides processes to access and review user data.
  • Processes to modify inaccurate data are available.
  • Processes for the school, parents, or students to delete data are available.
Not yet answered
  • Did not evaluate whether users retain ownership of their data.
  • Did not evaluate whether the product provides a data-retention policy.
  • Did not evaluate whether a user's data are deleted upon account cancellation or termination.
  • Did not evaluate whether this product deletes data when no longer necessary.
  • Did not evaluate whether permissions, roles, or access controls are available to restrict who has access to data.
  • Did not evaluate whether this product provides users the ability to download their data.
Data Sold
SCORE: 75%

Is the data sold?

  • Data are not sold or rented to third parties.
  • User information can be transferred to a third party.
Not yet answered
  • Did not evaluate whether users can opt out from the disclosure or sale of their data to a third party.
  • Did not evaluate whether users are notified if their information is transferred to a third party.
  • Did not evaluate whether user information can be deleted prior to its transfer to a third party.
  • Did not evaluate whether third-party transfers are contractually required to use the same privacy practices.
  • Did not evaluate whether user information is shared in an anonymous or deidentified format.
  • Did not evaluate whether the vendor describes their deidentification process of user information.
  • Did not evaluate whether data are shared for research and/or product improvement.
  • Did not evaluate 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 this product displays personal information publicly.
  • Unclear whether user-created content is filtered for personal information before being made publicly visible.
  • Unclear whether social interactions between users are moderated.
Not yet answered
  • Did not evaluate whether users can interact with untrusted users, including strangers and/or adults.
  • Did not evaluate whether profile information is shared for social interactions.
  • Did not evaluate whether this product allows users to control how their data are displayed.
  • Did not evaluate whether user-created content is reviewed, screened, or monitored by the vendor.
  • Did not evaluate whether social interactions of users are logged.
  • Did not evaluate whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 42%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • Unclear whether this product displays behavioral or targeted advertising.
  • Unclear whether this product allows data collection by third-party advertising or tracking services.
  • Unclear whether this product uses data 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.
Not yet answered
  • Did not evaluate whether this vendor can send marketing messages.
  • Did not evaluate whether this vendor provides promotional sweepstakes, contests, or surveys.
  • Did not evaluate whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
  • Did not evaluate whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 83%

Can I provide parental consent?

  • Intended for children under 13.
  • Parental consent is required.
  • Parental consent notice and method for submission are not provided.
Not yet answered
  • Did not evaluate whether this product collects personal information online from children under 13 years of age.
  • Did not evaluate whether intended for parents or guardians.
  • Did not evaluate whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
  • Did not evaluate whether children's privacy is applicable.
  • Did not evaluate whether this product limits parental consent with respect to third parties.
  • Did not evaluate whether this product allows parents to withdraw consent for the further collection of their child's information.
  • Did not evaluate whether this product deletes children's personal information if collected without parental consent.
School Purpose
SCORE: 0%

Is the product intended for school?

  • Unclear whether intended for students.
  • Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
Not yet answered
  • Did not evaluate whether personal information or education records are collected from preK-12 students.
  • Did not evaluate whether intended for teachers.
  • Did not evaluate whether the product creates education records.
  • Did not evaluate whether this product provides notification of a contract or additional rights.
  • Did not evaluate whether this product designates the vendor as a school official.
  • Did not evaluate whether this product transfers parental consent obligations to the school or district.
  • Did not evaluate whether the vendor indicates FERPA parental consent exceptions.
  • Did not evaluate 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.