Privacy Evaluation for HMH Close Reads: Grades 9–10
HMH Close Reads: Grades 9-10 guides students through the close reading of a variety of complex texts—argument, poetry, informational texts, fiction, drama, and even media messages in image and video. The terms specify that the Service may allow users to create their own profile, which may be displayed publicly or semi-publicly. The terms state that the service may collect Personal Information and Demographic Information from users. In addition, the terms state that all data sent to and from their platform are protected via Transport Layer Security, or TLS. Teachers are strongly encouraged to review the parental consent procedures within their school or district before sharing student information.
HMH Close Reads: Grades 9-10 terms specify that the service may allow users to create their own profile, which may be displayed publicly or semi-publicly. The terms state that a user's profile page may be set up to display information such as the user's display name, images, location, groups that the user has joined, and optional information added by the user including -- for example -- the user's tagline, photographs and educational materials.
The terms state that the user can post to chat rooms, message boards, other user's profiles, bulletin boards, or similar forums. The terms describe that these interactions may be public or semi-public, and could potentially be accessible via search. The terms state that the Service may also publish a user's name, voice, likeness and other Personal Information that is part of their User Content, and they may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.
Lastly, the terms state that a user may send messages or invitations from the Service, and that people sending messages from the service should be aware that their e-mail address, mobile number, name and/or user name may be included along with any message.
The terms state that the service may share a user’s non-Personal Information, such as aggregated user statistics or data related to a user and their activities, with third parties. However, the terms state that Personal Information will not be shared with third parties for direct marketing purposes unless the user provides consent. Users should be aware that the terms state that a person's name, voice, likeness and other Personal Information that is part of their User Content could be used for advertising, marketing, publicity and promotional activities.
Additionally, the Service may supplement the information they collect directly from users on the Service with external information from third parties. The terms state that third parties, including advertisers and advertising service providers, may collect information about users. These third parties may use their own tracking technologies on a user’s Device, or collect a user’s personal Information. While the terms state that the Service will not use Personally identifiable information to target ads, they also state that a user may be served with targeted and contextual advertising, including location-based advertising.
The terms state that all data sent to and from their platform are protected via Transport Layer Security, or TLS. The terms also specify that data that are covered under COPPA or FERPA are encrypted at rest whenever possible. The terms state that if the Service is not able to encrypt data, the Service will use other means to protect that data. The terms do not provide clear information on whether or not sensitive information that is not covered under COPPA or FERPA is encrypted at rest.
In the terms, the Company describes that privacy and information security training is provided to employees. They also describe how access to personal information is limited to specific employees. The Company uses third-party cloud service providers in the delivery and operation of their learning platform, and data is stored on the servers of their cloud service providers. The terms describe contractual requirements in place with these cloud service providers that are designed to protect user data.
The terms specify that the tools and services covered under their policies are designed for teachers and schools working with K12 students. The terms highlight that, under COPPA, schools can provide consent for parents for online tools used for an educational purpose. The terms also state that the Company meets the criteria for a "school official" under FERPA.
The terms specify that the service does not knowingly collect Personal Information from children under the age of 13 without verified parental consent - and for applications used within schools, the terms state that this consent can be provided by the school. However, if personal information is collected, the service allows users to access, update, or correct their Personal Information.
The service states they meet FERPA's requirements for qualifying as a school official because they give the school direct control over the use and maintenance of the education records. The terms also state that the Service does not re-disclose or use this personal information except for the purposes of providing the learning platform to the school.
Teachers are strongly encouraged to review the parental consent procedures within their school or district before sharing student information.
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.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- Sensitive data are not collected.
- Non-personally identifiable information is collected.
- Combined information is treated as personally identifiable information (PII).
- Personal information from children under 13 years of age is collected online.
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.
- Use of information is limited to the purpose for which it was collected.
- Data are shared for analytics.
- 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.
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Unclear whether this product requires account creation.
- Parental controls or managed accounts are available.
- Two-factor account protection is available.
- Third-party contractual security protections are required.
- Industry best practices are used to protect data.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- All data at rest are encrypted.
- Notice is provided in the event of a data breach.
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.
- Users can create or upload content.
- Unclear whether 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 not available.
- Unclear whether this product provides users the ability to download their data.
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.
- Third-party transfer is contractually required to use the same privacy practices.
- User information is shared in an anonymous or deidentified format.
- The vendor describes their deidentification process of user information.
- Data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
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.
- Unclear whether 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.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Data are shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are not 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 not 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 cannot opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
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.
- Children's personal information is deleted if collected without parental consent.
- Unclear whether this product provides parental consent notice and method for submission.
Is the product intended for school?
- Intended for students.
- Personal information or education records are collected from preK-12 students.
- Intended for teachers.
- Product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Product does create education records.
- Unclear whether this product provides notification of a contract or additional rights.
- Vendor is designated as a school official.
- Parental consent obligations are transferred to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.