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Privacy Evaluation for GizmoHub

Last updated April 3, 2020

Overview

The Verizon GizmoHub app allows parents to locate and monitor usage of their child's Gizmo smart watch device. The terms say Gizmo products and services do not allow children to make their personal information publicly available. However, the terms also say messages can be still be exchanged between Gizmo users through the wearable device and GizmoHub app. The Gizmo watch is primarily used for location tracking and the device collects geolocation information including the location of a child’s wireless devices. The terms say Verizon uses technical, administrative, and physical safeguards to help protect against unauthorized access or disclosure of personal information they collect or store. Lastly, the terms say Verizon collects personal information from children when a parent or guardian sets up Gizmo services through the GizmoHub app, including their name, mobile telephone number, email address, and child’s name, age and gender.

Verizon's Gizmo Watch can be accessed through its website, and its companion mobile application is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Verizon's website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Verizon Privacy Policy Summary, and Gizmo Privacy Policy. In the event of a conflict between the Verizon privacy policy, the practices described in the Gizmo policy govern when using Gizmo products and services. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms say some of Verizon’s websites, apps, and services let users participate in discussions, message boards and chat rooms, or leave reviews. The terms warn users that these are public spaces so a user’s comments can be read, collected and shared by anyone. However, the terms also say Gizmo products and services do not allow children to make their personal information publicly available. Lastly, the terms say messages can be still be exchanged between Gizmo users through the wearable device and GizmoHub app.

Privacy

The terms say the service collects personal information when a parent sets up Gizmo services through the GizmoHub app, and the service collects non-personal usage information automatically through use of the app and cellular mobile service. The GizmoHub app collects a child’s name, mobile telephone number, email address, and child’s name, age and gender. The terms say they do not collect more information from Gizmo devices than is reasonably necessary.

In addition, the Gizmo watch is primarily used for location tracking and the device collects geolocation information including the location of a child’s wireless devices. The terms say the service collects cell tower location information and may also collect Wi-Fi, Global Positioning Satellite (GPS), and other location information. The terms say Verizon does not sell or share information that individually identifies a particular user outside of Verizon and its affiliate companies. However, the terms also say Verizon may display targeted “interest-based” advertising to users on their apps and sites. Lastly, the terms say Verizon may use information about a user’s visits over time to different non-Verizon websites in order to better customize targeted ads.

Security

The terms say Verizon uses technical, administrative, and physical safeguards to help protect against unauthorized access or disclosure of personal information they collect or store. In addition, the terms say Verizon trains their employees on the importance of privacy, security, and the proper ways to access, use and disclose customer information. Verizon's terms say their practices and policies prohibit employees with access to personal information from using sensitive information unless they are authorized to do so and have a legitimate business need. Lastly, the terms say in the event of a data breach Verizon may use its security and incident response plans to handle such incidents and provide notice to impacted users.

Compliance

The terms say Verizon collects personal information from children when a parent or guardian sets up Gizmo services through the GizmoHub app, including their name, mobile telephone number, email address, and child’s name, age and gender. Verizon's terms also say the allow GizmoHub users to access, modify, delete, and export their personal information. The terms say parents are asked to provide consent when they set up Gizmo services through the GizmoHub app. Specifically, parents are asked to provide consent for all Gizmo watch devices that are paired with the app when they register an account. In addition, the terms say parents may revoke their consent at any time, however, certain Gizmo services will not be available without parental consent.

Data Collection
SCORE: 55%

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 limited to product requirements.
  • Geolocation data are collected.
  • Biometric or health data are collected.
  • Behavioral data are collected.
  • Sensitive data are collected.
  • 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.
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.
  • 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.
  • 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.
  • Social or federated login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 55%

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.
  • 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.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 90%

What rights do I have to the data?

  • Opt-in consent is requested from users at the time personal information is collected.
  • Users can control their information through privacy settings.
  • Unclear whether 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.
  • Processes to delete user data are available.
  • Processes to download user data are available.
Data Sold
SCORE: 35%

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.
  • 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: 75%

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 not displayed publicly.
  • Users can control how their data are displayed.
  • User-created content is reviewed, screened, or monitored by the vendor.
  • Unclear whether user-created content is filtered for personal information before being made publicly visible.
  • Unclear whether social interactions between users are moderated.
  • Social interactions of users are logged.
  • Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 55%

Are there advertisements or tracking?

  • Unclear whether data are shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • Behavioral or targeted advertising is displayed.
  • Data are collected by third-party advertising or tracking services.
  • Data are used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for data enhancement, and/or targeted advertisements.
  • The vendor can send marketing messages.
  • The vendor does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 60%

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.
  • 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.
  • Parental consent notice and method for submission are provided.
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.