Privacy Evaluation for IXL
IXL is the one of the world's most popular subscription-based learning sites for K-12. Used by over 7 million students, IXL provides unlimited practice in more than 7,000 topics, covering math, language arts, science, social studies, and Spanish. The terms of IXL say users can interact with trusted users on the service but do not disclose whether a child or student's personal information can be displayed publicly in any way. The terms say IXL will never sell student data to third parties, however the terms also say IXL may sell data from school or parent users to third parties. IXL's terms say they will maintain a comprehensive data security program and have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information they collect and to protect against unauthorized access, disclosure, and use. Furthermore, IXL's terms say their collection, use, and sharing of student data is governed by contracts with the school or district and any applicable laws and regulations including the Family Educational Rights and Privacy Act ("FERPA"), the Children's Online Privacy Protection Act ("COPPA") and applicable state laws.
The terms of IXL say users can interact with trusted users on the service but do not disclose whether a child or student's personal information can be displayed publicly in any way. The terms say a school may elect to provide user names or identifiers for student users which are not readily identifiable to anyone outside of the school community in substitution of a full student name. In addition, a school may elect to provide a profile name for a child user and selection of a profile avatar. IXL's terms say they recommend that the parent selects a profile name that does not include the real name or identifying characteristics of the child. The parent may also create a "secret word," which functions similar to a password to access the child profile, although it cannot be used to sign in to the IXL service without the parent first signing in to the parent's account using the parent's login credentials. However, parents and teachers should be aware the terms say a child may change his or her profile avatar, secret word, or profile name, but the parent will see these changes through the parent's account dashboard. IXL's terms say the account dashboard ensures that parents have access to, and control of, their child's use of the service.
IXL's terms say the type of personal information the service collects may vary depending on the account type. A family account is purchased by or for a parent. A family account typically includes child profiles that can be used by a parent's child at the parent's direction. A classroom account is purchased by or on behalf of a school, such as by a teacher and is a type of school account. A classroom account typically includes a single teacher user and a small number of student users. A site account is purchased by or on behalf of a school or school district. A site account typically includes an unlimited number of teacher users and a set maximum number of student users. In addition, the terms state IXL takes special precautions to collect only as much information as is reasonably necessary for a child to use the service.
The terms of IXL say they may share information with third parties with consent and at the direction of schools and parents. In addition, third party service providers who have access to student data, are contractually bound to uphold privacy and confidentiality terms no less protective than IXL's terms. IXL's terms also say they consider student data to be strictly confidential and in general do not use student data for any purpose other than improving and providing the services to the school or on the school's behalf. The terms say IXL will never sell student data to third parties, but the terms do say that IXL may sell data from school or parent users to third parties. In addition, the terms say that from time to time, IXL may send periodic promotional or informational e-mails to school or parent users, but IXL does not disclose whether any third-party marketing e-mails may also be sent to school or parent users. Furthermore, the terms specify IXL does not use student data to send marketing communications, and they do not send marketing communications to student or child users. IXL's terms say they do not display any targeted advertising on the service and do not use student data for any targeted or behavioral advertising purposes.
IXL's terms say they will maintain a comprehensive data security program and have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information they collect and to protect against unauthorized access, disclosure, and use. However, the terms do not disclose whether personal information is protected with encryption while in transit or while at rest. Additionally, the terms say some schools may elect to use a single-sign on (SSO) service like G Suite for Education rather than usernames and passwords to authenticate student access.
The terms state IXL and their employees, affiliates, service providers, or agents involved in the handling, transmittal, and processing of student data will be required to maintain the confidentiality of student data. In addition, the terms state IXL uses physical security measures to guard against unauthorized access to systems where they store personal data. IXL's terms specify they restrict access to personal information to IXL employees, contractors, and agents who need to know that information in order to operate, develop, or improve the services. IXL's terms state employees may be subject to disciplinary action, including termination, if they fail to meet privacy and confidentiality obligations. Lastly, the terms state that if personal information under IXL's control is compromised as a result of a breach of security, they will take reasonable steps to investigate the situation and take all steps required by applicable laws and agreements with any affected schools to provide notification.
IXL's terms say that if a user is under eighteen (18) years of age, they may use the service only with the involvement and consent of a parent, legal guardian, or at the direction of their school. The terms say IXL may collect information about a child authorized by their parent to use the service through the parent's account and if IXL is used by a school for an educational purpose, IXL may collect student data that is provided by the school or by a student. The terms of IXL state they may share information collected from users associated with a school with other users or persons designated by the school, such as teachers and school administrators of that school.
Parents or guardians of a student who uses the IXL service through a school must refer all questions and requests regarding access, modification, or deletion of a student's user account or student data to their child's school. IXL's terms state they will respond promptly to all access, modification, and deletion requests it receives from schools. However, IXL is not required to delete student data that has moved to a personal family account on the service. IXL’s terms state they do not retain student data beyond the time period required to support its educational purpose, unless authorized by a school or parent. In addition, the terms state IXL does not delete or de-identify any student data from an active student user account associated with a school except at the direction of the school. The school is responsible for maintaining current student rosters and identifying student data which the school no longer needs for an educational purpose by removing students from the school's master roster or by submitting a deletion request to IXL.
Furthermore, IXL's terms state their collection, use, and sharing of student data is governed by contracts with the school or district and any applicable laws and regulations including the Family Educational Rights and Privacy Act ("FERPA"), the Children's Online Privacy Protection Act ("COPPA") and applicable state laws. IXL's terms state its service is designed to comply with AB 1584 and pupil education records obtained by IXL from a local educational agency ("LEA") continue to be the property of and under the control of the LEA. Lastly, if a school provides the IXL service to children under 13, they must represent and warrant that they have the authority to provide consent on behalf of parents for IXL to collect information from students under 13 before allowing the students to access the service.
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 not collected.
- Unclear whether this product collects biometric or health data.
- Interactions, behaviors, or usage analytics data are collected.
- Unclear whether this product collects sensitive data.
- Data is automatically 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.
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.
- 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?
- Unclear whether 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.
- 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?
- 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.
- 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.
- 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.
- User information that is shared is shared in an anonymous or de-identified format.
- The company describes their de-identification process of user information.
- 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.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Unclear whether personal information can be displayed publicly.
- Users can control how their data are displayed to others.
- Unclear whether 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.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Traditional or contextual advertisements are displayed.
- Personalised advertising is not displayed.
- Data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for personalised advertisements.
- The company can send marketing messages.
- Unclear whether this company provides 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.
- Intended for parents or guardians.
- Company does not 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.
- Children's personal information is deleted if collected without parental consent.
- Parental consent notice and method for submission are provided.
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.
- Processes to enter education records into the product are described.
- Additional rights or protections may be provided with an additional school contract.
- Company is designated as a school official.
- Parental consent obligations are transferred to the school or district.
Can I control the use of my data?
- Users can control the use of their information through privacy settings.
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- Unclear whether 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.
- Unclear whether users can request to know what personal information has been shared with third parties.
- Unclear whether notice is provided in the event the company receives a government or legal request for a user's information.