Privacy Evaluation for Flipgrid
Flipgrid describes itself as a video discussion platform for millions of PreK to PhD educators, students, and families in 180+ countries. Flipgrid's policy indicates that it doesn't control content, but enables "Grid 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 Grid Owner, student, and school accounts. A teacher or school Grid 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 a parent consent form to facilitate this process.
Flipgrid's policy indicates that it doesn't control content, but enables "Grid Owners," a category of users, to do so. Also, they note that Grid Owners have certain options with respect to the privacy settings of their Grids. Flipgrid gives the example that teacher or School Grid Owners must password-protect the Grid and can also moderate their Grid. The policy explains that parents and students should send all requests regarding these privacy settings directly to the Grid Owner. In their policy, the Grid Owner controls what is public and can moderate content and interactions. Depending on the Grid's privacy settings, as set by the Grid Owner, users may be able to post Videos to SNSs (e.g., Facebook or Twitter). If a user chooses to do this, Flipgrid indicates that it will provide information to such SNSs in accordance with such user's elections.
Flipgrid's policy explains that when a Grid Owner creates an account on the Service, Flipgrid collects the Grid Owner’s first name, last name, email address, password, instruction type, and country. Users may also be students and schools, although implicitly the Grid 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 Grid 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 us 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 notes that a teacher or school Grid Owner may act as the agent of the parent or legal guardian of a student and provide consent on behalf of the parent. 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.
- Unclear whether the collection or use of data is limited to product requirements.
- Geolocation data are collected.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- Unclear whether this product collects sensitive data.
- 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.
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.
- Unclear whether use of information is limited to the purpose for which it was collected.
- Data are shared for analytics.
- 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.
- Unclear whether contractual limits are 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.
- 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.
- Unclear whether this product encrypts all data in transit.
- Unclear whether this product encrypts all data at rest.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Unclear whether 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.
- Unclear whether 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 not available.
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.
- Unclear whether user information is shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification process of user information.
- Data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
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 not shared for social interactions.
- Personal information is displayed publicly.
- Users can control how their data are displayed.
- Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
- 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
Are there advertisements or tracking?
- Data are not shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are not displayed.
- Behavioral or targeted advertising is not displayed.
- Data are not collected by third-party advertising or tracking services.
- Data are not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for data enhancement, and/or targeted advertisements.
- The vendor can send marketing messages.
- Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- Unclear whether 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.
- 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.
- Product does create 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.
- Parental consent obligations are transferred to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.