Privacy Evaluation for GizmoHub
The Verizon GizmoHub app allows parents to locate and monitor usage of their child's Gizmo smart watch device. The terms say that 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 that 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.
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.
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 sells information to third-party advertising networks. The terms say Verizon may display targeted “interest-based” advertising to users on their apps and sites. However, the terms also say the personal information collected through the Gizmo services are not used for behavioral advertising, to compile profiles, or any other purpose. 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.
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.
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 that they allow GizmoHub users to access, modify, delete, and export their personal information. The terms say that 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 that parents may revoke their consent at any time, however, certain Gizmo services will not be available without parental consent.
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.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are collected.
- Data is automatically collected.
- Opt-in consent is requested from users at the time personal information is collected.
- Unclear whether 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.
- Third-party login is supported.
- 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.
- 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.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Unclear whether 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.
- A user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Unclear whether methods are available to restrict who has access to data.
- Processes to download user data are available.
Is the data sold?
- 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.
- 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 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 not shared for social interactions.
- Personal information can be not displayed publicly.
- Users can control how their data are displayed to others.
- User-created content is reviewed, screened, or monitored by the company.
- 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
Are there advertisements or tracking?
- Unclear whether personal information are shared for third-party marketing.
- Traditional or contextual advertisements are displayed.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- Users's information is not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for personalised advertisements.
- The company can send marketing messages.
- The company does provide promotional sweepstakes, contests, or surveys.
- Users can 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.
- Unclear whether 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.
- Parental consent notice and method for submission are provided.
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.
- Unclear whether use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- 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.
- Notice is provided in the event the company receives a government or legal request for a user's 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.