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Privacy Evaluation for Freckle

Last updated

Overview

Freckle can be accessed at the following locations: website. The following 3 policies were used to evaluate Freckle: 1, 2, and 3. 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:
  • Data are not sold or rented to third parties.
  • Data are not shared for third-party advertising and/or marketing.
  • Unclear whether this product displays behavioral or targeted advertising.
  • Data are collected by third-party advertising or tracking services.
  • Unclear whether this product uses data 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.
Data Collection
SCORE: 75%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • Collection or use of data is limited to product requirements.
Not yet answered
  • Did not evaluate whether the categories of collected personally identifiable information are indicated.
  • Did not evaluate whether this product collects geolocation data.
  • Did not evaluate whether this product collects biometric or health data.
  • Did not evaluate whether this product collects behavioral data.
  • Did not evaluate whether this product collects sensitive data.
  • Did not evaluate whether this product collects non-personally identifiable information.
  • Did not evaluate whether this product treats combined information as personally identifiable information (PII).
  • Did not evaluate whether this product collects personal information online from children under 13 years of age.
Data Sharing
SCORE: 75%

What data does it share?

  • Collected information is shared with third parties.
  • The categories of information shared with third parties are indicated.
  • Unclear whether this product supports social or federated login.
  • Contractual limits are placed on third-party data use.
Not yet answered
  • Did not evaluate whether the purpose for sharing a user's personal information with third parties is indicated.
  • Did not evaluate whether use of information is limited to the purpose for which it was collected.
  • Did not evaluate whether data are shared for analytics.
  • Did not evaluate whether data are shared for research and/or product improvement.
  • Did not evaluate whether data are shared with third-party service providers.
  • Did not evaluate whether the roles of third-party service providers are indicated.
Data Security
SCORE: 83%

How does it secure data?

  • Account creation is required.
  • Parental controls or managed accounts are available.
  • Industry best practices are used to protect data.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Unclear whether this product provides notice in the event of a data breach.
Not yet answered
  • Did not evaluate whether a user's identity is verified with additional personal information.
  • Did not evaluate whether two-factor account protection is available.
  • Did not evaluate whether third-party contractual security protections are required.
  • Did not evaluate whether this product limits employee or physical access to user information.
Data Rights
SCORE: 88%

What rights do I have to the data?

  • Users can create or upload content.
  • Processes to access and review user data are available.
  • Processes to modify inaccurate data are available.
  • Processes for the school, parents, or students to delete data are available.
Not yet answered
  • Did not evaluate whether opt-in consent is requested from users at the time personal information is collected.
  • Did not evaluate whether users can control their information through privacy settings.
  • Did not evaluate whether users retain ownership of their data.
  • Did not evaluate whether the product provides a data-retention policy.
  • Did not evaluate whether a user can delete all their data.
  • Did not evaluate whether this product provides users the ability to download their data.
Data Sold
SCORE: 75%

Is the data sold?

  • Data are not sold or rented to third parties.
  • User information can be transferred to a third party.
Not yet answered
  • Did not evaluate whether users can opt out from the disclosure or sale of their data to a third party.
  • Did not evaluate whether users are notified if their information is transferred to a third party.
  • Did not evaluate whether user information can be deleted prior to its transfer to a third party.
  • Did not evaluate whether third-party transfers are contractually required to use the same privacy practices.
  • Did not evaluate whether user information is shared in an anonymous or deidentified format.
  • Did not evaluate whether the vendor describes their deidentification process of user information.
  • Did not evaluate whether data are shared for research and/or product improvement.
  • Did not evaluate whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 63%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Personal information is displayed publicly.
  • User-created content is not filtered for personal information before being made publicly visible.
  • Social interactions between users are not moderated.
Not yet answered
  • Did not evaluate whether users can interact with untrusted users, including strangers and/or adults.
  • Did not evaluate whether profile information is shared for social interactions.
  • Did not evaluate whether this product allows users to control how their data are displayed.
  • Did not evaluate whether user-created content is reviewed, screened, or monitored by the vendor.
  • Did not evaluate whether social interactions of users are logged.
  • Did not evaluate whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 42%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Unclear whether this product displays behavioral or targeted advertising.
  • Data are collected by third-party advertising or tracking services.
  • Unclear whether this product uses data 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.
Not yet answered
  • Did not evaluate whether this vendor can send marketing messages.
  • Did not evaluate whether this vendor provides promotional sweepstakes, contests, or surveys.
  • Did not evaluate whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
  • Did not evaluate whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 33%

Can I provide parental consent?

  • Unclear whether intended for children under 13.
  • Parental consent is required.
  • Unclear whether this product provides parental consent notice and method for submission.
Not yet answered
  • Did not evaluate whether intended for parents or guardians.
  • Did not evaluate whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
  • Did not evaluate whether children's privacy is applicable.
  • Did not evaluate whether this product discloses COPPA parental consent exceptions.
  • Did not evaluate whether this product limits parental consent with respect to third parties.
  • Did not evaluate whether this product allows parents to withdraw consent for the further collection of their child's information.
  • Did not evaluate whether this product deletes children's personal information if collected without parental consent.
School Purpose
SCORE: 100%

Is the product intended for school?

  • Intended for students.
  • Product is primarily used by, designed for, and marketed toward students in grades preK–12.
Not yet answered
  • Did not evaluate whether personal information or education records are collected from preK-12 students.
  • Did not evaluate whether intended for teachers.
  • Did not evaluate whether the product creates education records.
  • Did not evaluate whether this product provides notification of a contract or additional rights.
  • Did not evaluate whether this product designates the vendor as a school official.
  • Did not evaluate whether this product transfers parental consent obligations to the school or district.
  • Did not evaluate whether the vendor indicates FERPA parental consent exceptions.
  • Did not evaluate 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.