Privacy Evaluation for Garmin Vivofit Jr.
Garmin vívofit jr. 2 is an interactive fitness mobile app experience where fitness activity unlocks games and adventures. The terms say parents will be asked to provide a display name for each of their children whose vívofit jr. device they add to their parent profile. The terms also say when a parent syncs the vívofit jr. device with the vívofit jr. app, they upload to Garmin information about their child’s activities such as chores, rewards, steps, distance, activity time and sleep information. However, the terms do not say whether Garmin's vívofit jr. app sells personal information to third parties or whether it displays targeted ads, sends third-party marketing emails, or tracks users across the internet or on other services. Lastly, the terms say a parent or legal guardian has the right under the Children’s Online Privacy Protection (COPPA) to access, modify, delete, and export any personal information Garmin collects from their child.
The terms say parents will be asked to provide a display name for each of their children whose vívofit jr. device they add to their parent profile. The display name they choose will be shown on their child’s vívofit jr. device and may be displayed to others when the child engages in Toe-to-Toe challenges. The display name a parent chooses to provide in the vívofit jr. app, together with the total number of steps taken by their child during the duration of the challenge, will be shown on the devices of their child’s friends or family members if their child engages in a Toe-to-Toe step challenge with them. Also, a child's display name will be shown in the vívofit jr. apps of the parents of friends and family members and in the Garmin Connect account of friends or family members who use other Garmin devices to engage in a Toe-to-Toe step challenge with a child.
Parents should keep in mind other vívofit jr. app users will be able to see a chid's profile. Users who are not in a child's connections will be able to see the Family name parents choose in their profile, their admin name, the name of any additional parent or guardian they have added to their profile and the number of children parents have added to their profile.
The terms say when a parent syncs the vívofit jr. device with the vívofit jr. app, they upload to Garmin information about their child’s device settings and their child’s activities such as chores, rewards, steps, distance, activity time and sleep information. However, the terms do not say whether Garmin's vívofit jr. app sells personal information to third parties or whether it displays targeted ads, sends third-party marketing emails, or tracks users across the internet and on other services.
The terms say data security is a priority at Garmin. If a security researcher or Garmin customer thinks they have found a security issue or vulnerability, the terms say Garmin would appreciate their help in disclosing it to them in a responsible manner. In addition, the terms say Garmin has dedicated security personnel who are armed with an array of security tools that protect and continuously monitor for threats. Garmin's terms say security personnel work closely with teams throughout the company in an effort to keep products, apps and websites safe. Garmin team members are also continually keeping servers up-to-date with security patches and operating system updates. Lastly, the terms say Garmin uses a variety of safeguards, personnel, and processes to protect users' data, but the terms do not disclose any additional details about whether Garmin uses reasonable security procedures such as encryption to protect personal data in transit or whether they provide notice to users in the event of a data breach.
The terms say that when a parent creates a Garmin account, the service asks them to provide their email address, name and password. Parents can also choose to remain anonymous and provide only their first name or a nickname instead of their full name. The terms also say parents can withdraw their consent to upload their child’s activity data and information about their child’s device and device settings to Garmin at any time by not syncing the vívofit jr. device with the vívofit jr. app. In addition, the terms say a parent or legal guardian has the right under the Children’s Online Privacy Protection (COPPA) to access, modify, delete, and export any personal information Garmin collects from their child.
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.
- Interactions, behaviors, or usage analytics data are collected.
- Unclear whether this product collects sensitive data.
- Data is automatically collected.
- 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.
- The categories of third parties that receive data are indicated.
- Data are shared for analytics.
- Unclear whether 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.
- Unclear whether this product supports third-party login.
- Unclear whether contractual limits are placed on third-party data use.
How does it secure data?
- Unclear whether 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.
- Employee or physical access to user information is limited.
- Unclear whether this product encrypts all data in transit.
- Unclear whether all data are stored in an encrypted format.
- Unclear whether this product provides notice 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.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Unclear whether this product deletes data when no longer necessary.
- Methods are available to restrict who has access to data.
- Processes to download user data are available.
Is the data sold?
- Unclear whether personal information is 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.
- 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.
- 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.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether contractual limits 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 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?
- Unclear whether personal information are shared for third-party marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Unclear whether this product displays personalised advertising.
- Unclear whether data are collected by third-parties for their own purposes.
- Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
- The company can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to 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.
- 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.
- 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.
- Unclear whether this product deletes children's personal information if collected without parental consent.
- Unclear whether this product provides parental consent notice and method for submission.
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.
- Processes to enter education records into the product are not described.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Unclear whether the company is designated as a school official.
- Unclear whether this product transfers parental consent obligations to the school or district.
Can I control the use of my data?
- Users can control the use of their information through privacy settings.
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- Unclear whether company may combine data with additional data from third-party sources.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Notice is provided if the context in which data are collected changes.
- Consent is obtained if the practices in which data are collected change.
- A grievance or remedy mechanism is available for users to file a complaint.
- Users can request to know what personal information has been shared with third parties.
- Unclear whether notice is provided in the event the company receives a government or legal request for a user's information.