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Privacy Evaluation for Fitbit

Last updated April 13, 2020

Overview

Fitbit encourages everyone to live a healthier, more active life by tracking all-day activity, workouts, sleep and more. Fitbit's terms say they may use the information they collect to help children connect with other guardian-approved Fitbit users which are displayed within the family account. Fitbit's terms also say personal information is required to create an account, such as a user's name, email address, password, date of birth, gender, height, weight, and mobile telephone number. The terms say Fitbit does not sell data to any third parties, but may display interest-based targeted advertisements to users. Fitbit's terms say they use the information they collect to promote the safety and security of the services and work hard to keep users' data safe. Lastly, Fitbit allows parents to set up accounts for their children to use with select Fitbit devices.

Fitbit 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 Fitbit’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Fitbit Privacy Policy for Children’s Accounts, and Cookies and Similar Technologies. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Fitbit's terms say they may use the information they collect to help children connect with other guardian-approved Fitbit users which are displayed within the family account. Users may also connect with friends on the services or invite friends who have not yet joined by providing their email addresses, accessing social networking accounts, or using the contact list on their mobile device. Fitbit's terms remind users that if they choose to participate in a challenge, information like their profile photo, posted messages, total steps in the challenge, personal statistics, and achievements, are not governed by their privacy preferences and will be visible to all other challenge participants. Lastly, Fitbit's terms say they provide live coaching services for users to communicate with a live health, fitness, or wellness coach. Coaches may be provided by third parties, such as an individual's employer or insurance company, or by third-party coaching service providers.

Privacy

Fitbit's terms say personal information is required to create an account, such as a user's name, email address, password, date of birth, gender, height, weight, and mobile telephone number. Also, Fitbit's fitness tracking services include features that use precise geolocation data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. In addition, the services also collect biometric information, such as a user's exercise, activity, sleep, or health data, including the number of steps they take, distance traveled, calories burned, weight, heart rate, sleep stages, active minutes, female health data, and Live Coaching data. When parents create an account for their child, Fitbit will ask for personal information about them, like their name, date of birth, gender, height, and weight.

The terms say Fitbit does not sell data to any third parties, but may display interest-based targeted advertisements to users. The terms also say Fitbit allows third parties to display advertisements on their behalf to users across the internet, but they do not track child users over time and across third-party websites to provide targeted advertising.

Security

Fitbit's terms say they use the information they collect to promote the safety and security of the services and work hard to keep users' data safe. The terms also say Fitbit uses reasonable security practices with a combination of technical, administrative, and physical controls to maintain the security of a user's data. In addition, the terms say they encrypt user data when in transit, but do not disclose if they provide notice to users in the event of a data breach.

Compliance

Fitbit's terms say if they collect health data they will ask users for their explicit consent to process the data. Fitbit says they obtain this consent separately when a user takes actions for Fitbit to obtain the data, for example, when a user pairs their device to their account, grants Fitbit or a third-party access to exercise or activity data from another service, or uses the female health tracking feature. Fitbit's terms say they allow users to access, modify, delete, and export personal data through the services at any time.

In addition, Fitbit allows parents to set up accounts for their children to use with select Fitbit devices. A parent has control of any child’s account within their family account. Once a parent has signed in to their Fitbit account, verified their email address, and created a family account they can create an account for their child. Lastly, if Fitbit learns that they have collected the personal information of a child under 13 years of age without parental consent, they will take steps to delete the information as soon as possible.

Data Collection
SCORE: 45%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Unclear whether the collection or use of data is limited to product requirements.
  • Geolocation data are collected.
  • 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: 65%

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.
  • Unclear whether 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.
  • Unclear whether this product supports social or federated login.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 50%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Account creation is required.
  • Parental controls or managed accounts are available.
  • Unclear whether two-factor account protection is available.
  • 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 encrypted.
  • Unclear whether this product encrypts all data at rest.
  • 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: 55%

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.
  • 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.
  • Third-party transfer is 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: 55%

How safe is this product?

  • Users can interact with 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 reviewed, screened, or monitored by the vendor.
  • 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?

  • 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.
  • Unclear whether this product creates and uses data profiles 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: 80%

Can I provide parental consent?

  • Intended for children under 13.
  • Intended for parents or guardians.
  • Vendor does 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.
  • 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 provided.
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.