Privacy Evaluation for FaceApp: AI Face Editor
57%
Overview
FaceApp is an application that allows users to upload photos of themselves and use filters to transform their photos or videos with different styles or expressions, or swap the gender or age, or even change the background or foreground. The terms of FaceApp do not disclose whether any social interactions are available between users, or whether personal information or user content may be made publicly visible to others. FaceApp's terms say they collect user generated content that is uploaded through the app and other usage information that is collected automatically. FaceApp's terms also say they will not rent or sell users' information to third parties. However, the terms of FaceApp also say they may provide personalized content and information to users, which could include targeted ads or other forms of third-party marketing. In addition, FaceApp's terms say they take reasonable steps to protect the confidentiality and security of personal information collected from users of the app. Lastly, the terms of FaceApp say the app and its content are not intended or directed at children under the age of 13.
FaceApp 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 FaceApp’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
The terms of FaceApp do not disclose whether any social interactions are available between users, or whether personal information or user content may be made publicly visible to others. In addition, the terms state users can share their photos through social media sites, and they provide controls for users to make photos private or public. However, the terms state FaceApp may screen, edit, or monitor user content at their discretion, and may delete or remove user content at any time and for any reason.
Privacy
FaceApp's terms say they collect user generated content that is uploaded through the app and other usage information that is collected automatically. In addition, FaceApp may also collect metadata, which is technical data that is associated with user content. For example, metadata can describe how, when and by whom a piece of user content was created, which can include geolocation data that describes where the photo was taken. FaceApp's terms say they will not rent or sell users' information to third parties. However, the terms of FaceApp also say they may provide personalized content and information to users, which could include targeted ads or other forms of third-party marketing. In addition, because FaceApp is supported by advertising revenue, the terms say they may display advertisements and promotions to others based on a user's uploaded user content.
FaceApp's terms also say third-party partners may track users to serve behavioral ads to their devices, which may use cookies, device identifiers, or similar technologies placed by FaceApp or the third party. Lastly, the terms say FaceApp may also share cookie data with third-party advertising partners that allow third-party ad networks to track and deliver targeted advertisements to users across the internet.
Security
FaceApp's terms say they take reasonable steps to protect the confidentiality and security of personal information collected from users of the app. The terms say FaceApp protects personal information with encryption, but the terms do not provide any additional information about whether notification is provided to users in the event of a data breach.
Compliance
The terms of FaceApp say the app and its content are not intended or directed at children under the age of 13. If a user is under 18 years of age, they may only access or use the app under the supervision of a parent or legal guardian who provides consent. However, the terms do not disclose the method in which a parent or guardian can actually provide consent. In addition, the terms disclose users have data rights to access, modify, delete, or export their user content but limited only for users in the European Union. The terms say in the event that FaceApp learns that they have collected personal information from a child under age 13 without parental consent, they will delete that information as quickly as possible. Lastly, users must grant FaceApp a license to use their user content without limitation, but FaceApp's terms say users retain all rights to their user content and FaceApp does not claim ownership of any user content posted through the services.
Rating
- Data are not sold or rented to third parties.
- Unclear whether data are shared for third-party advertising and/or marketing.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for data enhancement, and/or targeted advertisements.
Data Collection
SCORE: 50%
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.
- Biometric or health data are collected.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is collected.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Personal information from children under 13 years of age is collected online.
Data Sharing
SCORE: 85%
What data does it share?
- 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.
- Use of information is limited to the purpose for which it was collected.
- Data are shared for analytics.
- Unclear whether 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.
Data Security
SCORE: 40%
How does it secure data?
- A user's identity is verified with additional personal information.
- Account creation is required.
- Unclear whether parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
- Unclear whether third-party contractual security protections are required.
- Industry best practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
- All data in transit are not encrypted.
- All data at rest are encrypted.
- Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 95%
What rights do I have to the data?
- Opt-in consent is 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 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.
- Processes for the school, parents, or students to delete data are available.
- Processes to delete user data are available.
- Processes to download user data are available.
Data Sold
SCORE: 35%
Is the data sold?
- Data are not sold or rented to third parties.
- 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.
- 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 is shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification process of user information.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 5%
How safe is this product?
- Unclear whether this product supports interactions between trusted users and/or students.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information is shared for social interactions.
- Unclear whether this product displays personal information publicly.
- Unclear whether this product allows users to control how their data are displayed.
- User-created content is not reviewed, screened, or monitored by the vendor.
- Unclear whether user-created content is filtered for personal information before being made publicly visible.
- Unclear whether social interactions between users are moderated.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 55%
Are there advertisements or tracking?
- Unclear whether data are shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are displayed.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for data enhancement, and/or targeted advertisements.
- The vendor can send marketing messages.
- The vendor does provide promotional sweepstakes, contests, or surveys.
- Users can opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 50%
Can I provide parental consent?
- Intended for children under 13.
- Unclear whether 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 applicable.
- Unclear whether this product indicates COPPA parental consent exceptions.
- Parental consent is required.
- 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.
- Unclear whether the product creates education records.
- Unclear whether this product provides notification of a contract or additional rights.
- Unclear whether this product designates the vendor as a school official.
- Unclear whether this product transfers parental consent obligations to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear 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.