Common Sense Privacy Program

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Privacy Evaluation for HTC Vive

Last updated
Applications and services with a Warning rating do not meet our recommendations for privacy and security practices. Applications and services with a Warning rating have issues narrowly focused around data use related to creating profiles that are not associated with any educational purpose, selling data, and/or using data to target advertisements.

57%

Warning

Learn how we rate

Overview

The HTC Vive is a virtual reality headset developed by HTC and Valve. The headset uses "room scale" tracking technology, allowing the user to move in 3D space and use motion-tracked handheld controllers to interact with the virtual environment. The terms say the services may provide communication features (such as blogs, support forums, chat, etc.) designed to enable users to communicate with others and share information publicly. However, the terms say HTC may sell a user's data to third parties, and may display targeted advertisements to users using data automatically collected about a user and their device when they use the services. In addition, HTC's terms say they use third-party tracking technologies to track users with personally identifiable information about their online activities over time and across third party websites and applications for marketing and advertising purposes.

The terms say HTC strives to protect personal information by taking appropriate physical, technical and organizational measures to help guard against unauthorized or unlawful access, use, processing or alteration of the personal information that HTC obtains from users through the services and against any breaches or loss of personal information. Lastly, the terms say users under the age of 13 should not use the services and they should not provide any information about themselves to HTC, including their name, address, telephone number, or email address (directly, or on site bulletin boards, blogs, etc.).

HTC Vive can be accessed through its website, and 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 HTC’s website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Additionally, other policies used for this evaluation include:

Safety

The terms say the services may provide communication features (such as blogs, support forums, chat, etc.) designed to enable users to communicate with others and share information publicly. The terms also say the services allow users to share information and content that they choose to upload via social media, but must agree to use the services only to post, send and receive messages and material that are appropriate. Lastly, the terms say the services may allow users to connect and share their actions, comments, content and information publicly or with people they specify, but privacy controls allow users to decide what information they make publicly available.

Privacy

The terms say the services may collect behavioral usage reporting data when using the device that can include, for example: details about how a user interacts and uses their device and the apps, categories, features, programs and services on the device, including how and when a user access these items, the number of times they access these items, actions they take when accessing and using these items, the length of time of the access, and the number of times a user adjusts the settings of the device. In addition, the service collects information about the applications a user's downloads, including what they downloaded, when they download applications, and whether a user shares these downloads, or whether a user uninstalls or delete the downloads. The terms say HTC may sell a user's data to third parties, and may display targeted advertisements to users using data automatically collected about a user and their device when they use the services. In addition, HTC's terms say they use third-party tracking technologies to track users with personally identifiable information about their online activities over time and across third party website and applications for advertising purposes.

When users use VIVE Pro Eye or other devices with VIVE eye tracking technology incorporated, their eye tracking data may be collected. VIVE eye tracking enables users to use their eyes to control or interact with applications on the device. The term say a series of photographic images are taken and each eye image is instantly used to create data that can include gaze data (e.g., direction you are looking at), pupil size, eye openness (whether your eyes are open or closed). This eye tracking data (but not eye image itself) may be used by other applications or services to interact with a user. The actual image of a user's eyes is not permanently stored or sent off the device, including to any third parties. The terms say HTC does not allow use of an eye image to personally identify a user.

Security

The terms say HTC strives to protect personal information by taking appropriate physical, technical and organizational measures to help guard against unauthorized or unlawful access, use, processing or alteration of the personal information that HTC obtains from users through the services and against any breaches or loss of personal information, such as anonymization, pseudonymization, encryption (such as encrypted by Transport Layer Security (HTTPS) during transmission), and restricted access. In addition, the terms say a user's usage reporting data is recorded, secured and stored locally on a user's device. A user's device transmits collected data with encryption to HTC where the data is stored and linked to a user's device serial number in hashed form. Lastly, the terms also say that although HTC takes steps to use and improve various safeguards, no system or technology is completely secure and they will provide responsible disclosure notification to users in the event of a data breach.

Compliance

The terms say users under the age of 13 should not use the services and they should not provide any information about themselves to HTC, including their name, address, telephone number, or email address (directly, or on site bulletin boards, blogs, etc.). However, the terms say that users who are 13 years of age or older but under 18 years old, should review the terms with their parent or guardian to make sure that the teen and their parent or guardian understand it. Parents or guardians are advised to supervise their children while using the Internet and mobile and other devices. Additionally, the terms specify that users can access, modify, delete, and export their personal information from the service at any time. However, the terms do not discuss use by students in an educational institution or any additional student data privacy protections.

Rating

This product received a Warning rating based on the following details:
  • Data are sold or rented to third parties.
  • Data are shared for third-party advertising and/or marketing.
  • 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.
Data Collection
SCORE: 60%

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.
  • Sensitive data are 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 not collected online.
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.
  • 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.
  • Unclear whether this product supports social or federated login.
  • 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.
  • Unclear whether 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.
  • Unclear whether this product limits employee or physical access to user information.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 85%

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.
  • 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.
  • Unclear whether the school, parents, or students can delete data.
  • Processes to delete user data are available.
  • Processes to download user data are available.
Data Sold
SCORE: 35%

Is the data sold?

  • 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.
  • 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.
  • Contractual limits do not prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 30%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users and/or students.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether 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.
  • 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
SCORE: 60%

Are there advertisements or tracking?

  • 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: 20%

Can I provide parental consent?

  • Not intended for children under 13.
  • Unclear whether intended for parents or guardians.
  • Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
  • Unclear whether 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.
  • Unclear whether this product allows parents to 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.

Learn more about the SPR Read the report

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.