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.
- Behavioral data are collected.
- Sensitive data are not collected.
- Non-personally identifiable information is collected.
- Combined information is treated as personally identifiable information (PII).
- Personal information from children under 13 years of age is not collected online.
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.
- Use of information is limited to the purpose for which it was collected.
- Data are shared for analytics.
- 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.
- Social or federated 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.
- Parental controls or managed accounts are not available.
- Two-factor account protection is not available.
- Third-party contractual security protections are required.
- Industry best practices are used to protect data.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- Unclear whether this product encrypts all data at rest.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Opt-in consent is not requested from users at the time personal information is collected.
- Users can control their information through privacy settings.
- Users can create or upload content.
- Users do not retain ownership of their data.
- Processes to access and review user data are available.
- Processes to modify inaccurate data are available.
- A data-retention policy is available.
- Unclear whether the school, parents, or students can delete data.
- Processes to delete user data are available.
- Processes to download user data are not available.
Is the data sold?
- Data are 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.
- 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 is shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification process of user information.
- Data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
How safe is this product?
- Unclear whether this product supports interactions between trusted users and/or students.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
- Personal information is displayed publicly.
- Users can control how their data are displayed.
- User-created content is not reviewed, screened, or monitored by the vendor.
- 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?
- Data are not shared for third-party advertising and/or marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Behavioral or targeted advertising is not displayed.
- Data are not collected by third-party advertising or tracking services.
- Data are not used 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.
- The vendor can send marketing messages.
- Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Not intended for children under 13.
- 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 not applicable.
- COPPA parental consent exceptions are not indicated.
- Parental consent is required.
- 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.
- Product does create education records.
- Unclear whether this product provides notification of a contract or additional rights.
- Vendor is not designated as a school official.
- Parental consent obligations are not transferred to the school or district.
- FERPA parental consent exceptions are not indicated.
- Directory information is not disclosed.