Privacy Evaluation for Flipgrid
Flipgrid describes itself as a video discussion platform for millions of PreK to PhD educators, students, and families. Flipgrid's policy indicates that it doesn't control content, but enables "Discussion Owners," a category of users, to do so. Flipgrid's terms indicate that it does not sell users’ personal information to third parties or use personal information to market or advertise to users. Several categories of accounts are available, including Discussion Owner and student. A teacher or school Discussion Owner may act as the agent of the parent or legal guardian of a student and provide consent on behalf of the parent, and Flipgrid's policy includes a link to facilitate this process.
Flipgrid's policy indicates that it doesn't control content, but enables "Discussion Owners," a category of users, to do so. Also, they note that Discussion Owners have certain options with respect to the privacy settings of their Discussions. The policy explains that parents and students should send all requests regarding these privacy settings directly to the Discussion Owner. In their policy, the Discussion Owner controls what is public and can moderate content and interactions. Depending on the Discussion's privacy settings, as set by the DiscussionOwner, users may be able to post videos.
Flipgrid's policy explains that when a Discussion Owner creates an account on the Service, Flipgrid collects the Discussion Owner’s first name, last name, email address, password, instruction type, and country. Users may also be students and schools, although implicitly the Discussion Owners are teachers. In addition to the cookies Flipgrid sets, the policy also notes that third parties can also set cookies when you visit their sites. For example, companies they hire to provide services on Flipgrid's behalf, such as site analytics, may place cookies when users visit their sites. Flipgrid's terms indicate that it does not sell users’ personal information to third parties or use personal information to market or advertise to users. Lastly, Flipgrid's terms explain that the service does not use personal information to track and target advertisements to users' on third party websites or services.
Flipgrid's policy allows Discussion Owners (presumably teachers) to monitor content for other users like schools and students. By enrolling a student under 13 to use the Service, Flipgrid's policy indicates that the school provides such consent to Flipgrid and agrees that the students’ activities while on the service are subject to their terms and conditions online agreement. Flipgrid's policy for children gives parents of students under 13 certain rights with respect to its collection, use, retention, and disclosure of their student’s information. This includes the right to review, update, or delete student information. Flipgrid notes that they are required under the Children Online Privacy Protection Act ("COPPA") to obtain verifiable parental consent in order to collect, use or disclose personal information from children, but requires Discussion Owners to obtain such consent. Flipgrid's policy includes a link to a parent consent form to facilitate this process.
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.
- Personal information of users is collected by a third party.
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 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.
- Contractual limits are not placed on third-party data use.
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.
- 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.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Users can create or upload content.
- Users retain ownership of their data.
- Processes to access or review user data are available.
- 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.
- Data are deleted when no longer necessary.
- Methods are available to restrict who has access to data.
- Unclear whether this product provides users the ability to download their data.
Is the data sold?
- Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
- 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.
- Unclear whether 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.
- Contractual limits do not prohibit third parties from reidentifying or de-identified information.
How safe is this product?
- Users can interact with trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Users can 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.
- Users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Personal information is not shared for third-party marketing.
- Traditional or contextual advertisements are not displayed.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- Users's information is not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for personalised advertisements.
- The company can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
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.
- Company does 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.
- Parental consent is required before personal information is collected or disclosed.
- Parental consent is limited with respect to third parties.
- Parents can 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.
- Parental consent notice and method for submission are provided.
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.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Company is not designated as a school official.
- Parental consent obligations are transferred to the school or district.
Can I control the use of my data?
- 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.
- 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.
- Notice is provided in the event the company receives a government or legal request for a user's information.