Common Sense Privacy Program

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Privacy Evaluation for Elevate - Brain Training

Last updated
Applications and services with a Warning rating do not meet our recommendations for privacy and security practices. Applications and services with a Warning rating have issues narrowly focused around data use related to creating profiles that are not associated with any educational purpose, selling data, and/or using data to target advertisements.

37%

Warning

Learn how we rate

Overview

Elevate - Brain Training is an app developed by Elevate, Inc. that uses games and activities with the goal of helping users exercise and improve their minds and bodies. Users can also measure their performance against other users of the app.

Elevate - Brain Training 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 Service used for this evaluation can be found on Elevate’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.

Safety

According to the Privacy Policy, users can both upload content and engage in social interactions, but they are solely responsible for their content and their interactions with any other user. The company does not pre-screen content, according to the Terms of Service, but the Company does maintain the right, in its sole discretion, to refuse or remove it. Furthermore, the terms specify that Elevate maintains the right but not the obligation to monitor disputes between users. The terms are clear in stating that users are responsible for the content and other materials they post on or through the service, but they do not specify whether or not there are opportunities for users to provide personal information via their content or whether such information could become publicly visible.

Privacy

Elevate's Privacy Policy states that they collect personal data from users who voluntarily provide information, such as an email address, first name, or last name. The policy also refers to the collection of usage data about the services and the computers or other devices, such as mobile phones or tablets, that users employ to access them. The policy is clear that Elevate is not in the business of selling user information but specifies that under certain circumstances, they may share personal data with certain third parties and related companies without any additional notice to the user. Such parties, according to the policies, may engage in mailing information, maintaining databases and processing payments in addition to other services. It's not entirely clear from the Privacy Policy or Terms of Service whether or not the company engages in advertising beyond marketing communications. While the terms do not explicitly state whether or not the Company displays contextual or behavioral advertisements, they do state that their paid subscriptions feature an ad-free browsing experience. Lastly, aside from the EU Users section, there is no mention regarding the creation of user profiles or tracking technologies used for advertising.

Security

The Terms of Service state that users may be required to register with Elevate, including a username and password, in order to use the services. The Privacy Policy specifies that the Company employs reasonable security measures to protect users’ personal information, but it does not mention transit or storage encryption, nor does it address what, if any, steps Elevate will take to notify users in the event of a data breach.

Compliance

Regarding compliance, it is clear from both the Privacy Policy and Terms of Service that the product is not intended for use by children under the age of 18; rather, it is intended for use by adults. Elevate does not knowingly collect information from any user under the age of 13, per the policies, and will delete such information if it is reported. The terms do state that parents or guardians may create accounts for children under the age of 18 to use the product, should they choose to do so; however, it is not clear whether or not there is a process to verify a user's age or a user's identity. Finally, the terms state that users are responsible for providing and maintaining accurate personal data on the platform. Users can contact Elevate to have personal information deleted, but the policies do not clearly state whether or not users have the ability to access, modify, or delete their own data once they have submitted it.

Rating

This product received a Warning rating based on the following details:
  • Personal information is not sold or rented to third parties.
  • Personal information is 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: 30%

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 not limited to product requirements.
  • Unclear whether this product collects geolocation data.
  • Unclear whether this product collects biometric or health data.
  • Interactions, behaviors, or usage analytics data are collected.
  • 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.
  • Unclear whether personal information of users is collected by a third party.
Data Sharing
SCORE: 70%

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.
  • 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 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.
  • Reasonable security 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 all data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 45%

What rights do I have to the data?

  • 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.
  • Processes to modify data are available for authorized users.
  • A data-retention policy is available.
  • Processes for authorized users to delete data are available.
  • 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: 40%

Is the data sold?

  • Personal information is not 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 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.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • User information that is shared is not shared in an anonymous or de-identified format.
  • 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.
Data Safety
SCORE: 20%

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.
  • 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.
  • 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
SCORE: 25%

Are there advertisements or tracking?

  • Personal information is shared for third-party marketing.
  • Traditional or contextual advertisements are displayed.
  • 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.
  • 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.
Parental Consent
SCORE: 50%

Can I provide parental consent?

  • Not 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 provide a section, heading, or separate policy for children in their policies.
  • Unclear whether 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: 25%

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 not limited to the purpose for which it was collected.
  • The context 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.
  • 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.

Learn more about the SPR Read the report

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.