Privacy Evaluation for Garmin Vivofit Jr.
46%
Overview
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.
Garmin's Vívofit jr. 2 can be accessed through its website, and is available for download at the iOS App Store, the Google Play Store, and the Amazon App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Vívofit jr. 2’s website, iOS App Store, the Google Play Store, and the Amazon App Store. Additionally, other policies used for this evaluation include: Garmin Privacy Policy, Security Policy, and California Privacy Rights. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
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.
Privacy
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.
Security
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.
Compliance
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.
Rating
- Unclear whether data are sold or rented to third parties.
- Unclear whether data are shared for third-party advertising and/or marketing.
- Unclear whether this product displays behavioral or targeted advertising.
- Unclear whether this product allows data collection 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.
- Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
Data Collection
SCORE: 50%
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.
- Unclear whether this product collects sensitive data.
- Non-personally identifiable information is 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.
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.
- The categories of third parties that receive personal information are indicated.
- 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.
- Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 40%
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.
- Unclear whether third-party contractual security protections are required.
- Industry best 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 this product encrypts all data at rest.
- Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 75%
What rights do I have to the data?
- 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.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Unclear whether this product deletes data when no longer necessary.
- Permissions, roles, or access controls are available to restrict who has access to data.
- Processes to download user data are available.
Data Sold
SCORE: 45%
Is the data sold?
- Unclear whether data are 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.
- 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 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 not reviewed, screened, or monitored by the vendor.
- 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
SCORE: 15%
Are there advertisements or tracking?
- Unclear whether data are 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.
- Unclear whether this product allows data collection 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.
- Unclear whether this product creates and uses data profiles 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.
Parental Consent
SCORE: 65%
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected online.
- 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.
- 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.
- 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.
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.