Common Sense Privacy Program

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Privacy Evaluation for Explore Learning Reflex

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.

40%

Warning

Learn how we rate

Overview

Explore Learning Reflex is a web based application that helps students learn basic math facts through interactive games and rewards systems. The terms indicate that users require an account to use the service and that users can interact with other untrusted users on the platform and that these interactions are not moderated. The policies state that the company collects personal information such as name, email, phone number and student information. It is unclear whether the company uses this information for marketing purposes, but the terms state that personal information is shared with third parties for research and analytics purposes. However, the terms state the company does not sell personal information to third parties. The terms state that the service does not use personal information for first party marketing on the platform, but the terms do not clearly indicate whether third parties may use cookies on the platform for their own purposes, including for their own advertising. The policies state the company uses measures to protect the security and confidentiality of user data, including restrictions on employee access to data and other administrative controls on file access. The terms state the company will notify users if their information is compromised in a data breach. The terms do not clearly state if users may access and delete their data, but the terms do specify that the company will delete personal data in select instances such as after continued nonuse of the platform.

Explore Learning Reflex can be accessed at the following locations: website. The following 2 policies were used to evaluate Explore Learning Reflex: 1 and 2. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

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.
  • Personalised advertising is not displayed.
  • 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: 35%

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.
  • Unclear whether this product collects geolocation data.
  • Unclear whether this product collects biometric or health data.
  • Unclear whether this product collects interactions, behaviors, or usage analytics data.
  • 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.
  • Personal information of users is collected by a third party.
Data Sharing
SCORE: 50%

What data does it share?

  • Unclear whether collected information is shared with third parties.
  • 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 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.
  • Unclear whether this product supports third-party login.
  • Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 55%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is required.
  • 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.
  • Employee or physical access to user information is limited.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether all data are stored in an encrypted format.
  • Notice is provided 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.
  • 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.
  • Unclear whether authorzied users 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 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: 30%

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 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.
Data Safety
SCORE: 10%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • 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.
  • Unclear whether user-created content is reviewed, screened, or monitored by the company.
  • Unclear whether user-created content is 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: 15%

Are there advertisements or tracking?

  • Personal information is shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Personalised advertising is not displayed.
  • 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.
  • Unclear whether this 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.
  • Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 25%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Unclear whether intended for parents or guardians.
  • Unclear whether company has actual knowledge that personal information from users under 13 years of age is collected.
  • The company does not 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.
  • Parental consent is limited with respect to third parties.
  • Unclear whether this product allows parents to withdraw consent for the further collection of their child's information.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 69%

Is the product intended for school?

  • Intended for students.
  • 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.
  • Processes to enter education records into the product are described.
  • 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: 10%

Can I control the use of my data?

  • Unclear whether users can control the use of their information through privacy settings.
  • Unclear whether use of information is 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.
  • Unclear whether 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.