Privacy Evaluation for Curriki
Curriki is a community for teaching or studying that facilitates finding and sharing educational content. The terms of Curriki state the service is dedicated to supporting learning communities. Any comments, resources, content, and information users submit to the public areas of the services, such as the forums, can be read, collected, or used by other users and the public. The terms of Curriki state they collect personal information and non-personal information automatically from the use of the service. The terms of Curriki state they provide reasonable security to protect personal information submitted to the service Lastly, the terms of Curriki state they do not knowingly collect or maintain personal information from users under 13 years of age.
The policies indicate that Curriki provides a forum where PII and shared content can be made public. In order to interact with the service PII is collected and displayed publicly and users of the product have the potential to interact with untrusted users. Some information can be withheld (such as email addresses) but the policies are unclear as to how, and what, PII is shared and how it can be managed. The policy does indicate that PII “can be read, collected, or used by other users and the public.” Policies also state that the vendor does not screen, review or delete PII from user created content and moderating is not provided. In addition, the policies do not clearly state if social interactions are logged, if abusive behavior can be reported, or if tools and process for safe interactions are provided, or if users can interact with trusted users. Lastly, there is also no mention of an ability to block, filter, or monitor social interactions, however the policies do clearly state that the product is not intended for students.
The terms state user personal information is collected and includes automatically collected information. Collection of personal information is limited to only the data required to provide, operate and improve the services. In addition, the policies state that personal information is not sold or rented to third parties and information is not obtained on users from third party sources to be combined. Social federated login is supported and personal information is collected from those sources, but is not shared with third-parties unless user authorized. The policies indicate that contractual limits are placed on third-party vendor use of data and third parties are not authorized to access user PII.
In addition, the policies state behavioral ads are not displayed but there are no references to traditional ads. The policies clearly state Curriki is not intended for users under 13, minors or students and therefore ads and links are considered age-appropriate for adult users. Users can create and upload content and opt-in permission is required at time of upload but further opt-in consent is not sought.
The policies clearly indicate that the product is not intended for children under the age of 13 or teens between 13 and 18 years of age, but is aimed at adults such as educators and parents. Therefore student information is not collected and information on children under 13 or minors is not knowingly collected. The policies indicate that methods are not implemented to prevent children or minors from creating an account, but information will be deleted upon discovery or request. The policies also clearly state that, due to the fact Curriki is not aimed at minors or children, they do not obtain verifiable consent under COPPA or provide information about FERPA rights or disclose information under such requirements.
Furthermore, the policies state the product is not intended for students so information on restricting data, reviewing student information, maintaining accuracy of data or modifying / deleting student data are not provided in the policies. Policies do indicate a user may update their own information or request their account to be deleted (this will be processed within 14 days of request), however, user uploaded information and some PII (not specified in the policies) will remain on the service after account deletion. Policies also state that there is no time-period for automatically deleting or limiting information retention after inactivity.
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 not collected.
- Biometric or health data are not collected.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are not collected.
- Data is automatically collected.
- Opt-in consent is not requested from users at the time personal information is collected.
- Personal information of users is not collected by a third party.
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.
- Contractual limits are placed on third-party data use.
How does it secure data?
- A user's identity is not verified with additional personal information.
- Account creation is required.
- Managed accounts are not available.
- Multi-factor account protection is not available.
- Third-parties with access to information are required to provide the same security protections as the company.
- Reasonable security practices are used to protect data.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- Unclear whether all data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Users can create or upload content.
- Users do not retain ownership of their data.
- Processes to access or review user data are available.
- Processes to modify data are available for authorized users.
- A data-retention policy is available.
- Unclear whether authorzied users can delete data.
- A user's data are deleted upon account cancellation or termination.
- Data are not deleted when no longer necessary.
- Unclear whether methods are available to restrict who has access to data.
- Processes to download user data are not available.
Is the data sold?
- Personal information is not sold or rented to third parties.
- Users cannot 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.
- Users are not notified if their information is transferred to a third party.
- User information can not be deleted prior to its transfer to a third party.
- Third-party transfer is 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.
How safe is this product?
- Unclear whether this product supports interactions between trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Users can control how their data are displayed to others.
- User-created content is not reviewed, screened, or monitored by the company.
- User-created content is not filtered for personal information before being made publicly visible.
- Social interactions between users are not moderated.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Personal information is not shared for third-party marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- Users's information is not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for personalised advertisements.
- The 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.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Not intended for children under 13.
- Personal information from children under 13 years of age is not collected.
- 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 provide a section, heading, or separate policy for children in their policies.
- Parental consent is required before personal information is collected or disclosed.
- Parental consent is not limited with respect to third parties.
- Parents can 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 not provided.
Is the product intended for school?
- Not intended for students.
- Personal information or education records are not 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.
- Company is not designated as a school official.
- Parental consent obligations are not transferred to the school or district.
Can I control the use of my data?
- Users can control the use of their information through privacy settings.
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- Company will not combine data with additional data from third-party sources.
- Combined information is treated as personally identifiable information (PII).
- 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.
- Users can request to know what personal information has been shared with third parties.
- 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.