Privacy Evaluation for Kiddom
Kiddom is described as an all-in-one school operating system that enables educators to collaborate and personalize student instruction and assessment. The terms state the service includes features that allow users to communicate in a variety of ways, and personal data may be shared by users with other users through the service. The terms state the service collects personal and non personal information from children and students and the information the service requires users to provide on the Kiddom platform is extremely limited. The terms specify they employ physical, managerial, and technical safeguards designed to maintain the integrity and security of users' personal data. Lastly, the terms state that if a child under 13 (or 16 in the EU) tries to create a Kiddom account, they require verifiable parental consent before collecting children’s personal data.
The terms state the service includes features that allow users to communicate in a variety of ways, and personal data may be shared by users with other users through the service. The terms further clarify that users can make personal information publicly available in publicly accessible areas of the service, such as by sharing user submissions with another user. However, the service does not monitor content or interactions and therefore does not take reasonable measures to delete all personal information from a user's postings before they are made publicly visible.
The terms state the service collects personal and non personal information from children and students and the information the service requires users to provide on the Kiddom platform is extremely limited. In addition, the terms state the service does not sell users’ personal information or share their information with any thine-parties for their marketing or advertising purposes. Parents and educators should be aware that the service allows users to connect with a Google account, which grants Kiddom access to certain information associated with that student’s Google account that the service may use to setup and operate their classroom.
The terms of Kiddom state they endeavor to protect user information. The terms specify they employ physical, managerial, and technical safeguards designed to maintain the integrity and security of users' personal data. To protect users' privacy and security, the service takes reasonable steps to verify a user's identity before granting them account access or making corrections to their information. In addition, the terms state when users enter information in the login portion of the service, Kiddom encrypts the transmission of that information using secure socket layer technology (SSL). The terms further clarify they do not store a user's password, but instead store a result of an irreversible operation performed on the password to verify its validity.
However, the terms state Kiddom cannot guarantee the security of user account information in the case of unauthorized entry or use, hardware or software failure, and other factors that may compromise the security of user information at any time. In the event Kiddom learns of a security systems breach, the terms state they may attempt to notify users electronically or otherwise contact users through the service so that they can take appropriate protective steps.
The terms state that if a child under 13 (or 16 in the EU) tries to create a Kiddom account, they require verifiable parental consent before collecting children’s personal data. The terms further specify that if Kiddom learns that personal data of children under the age of 13 has been collected on the service without verifiable parental consent, or if a user has provided personal data beyond what was requested, they will delete that information as quickly as possible.
Additionally, the terms state parents and teachers can request to review, access, modify, delete, and download a copy of their child or student's information. Only those students who have been invited by their teacher, school, or district to use the Service may register to use Kiddom. The terms further specify that FERPA prohibits schools from sharing educational records without the consent of the student and/or the student’s parent. Kiddom's terms state they work hard to ensure that schools using the service have met that obligation. For that reason, the terms state parents must provide consent to Kiddom for storing and accessing student education records, and teachers are required to provide consent that their school or district has obtained all necessary parental consents to share educational records of students with Kiddom.
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.
- Unclear whether this product collects geolocation data.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- Unclear whether this product collects sensitive data.
- 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.
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.
- 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?
- 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.
- 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.
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.
- Unclear whether the product provides a data-retention policy.
- 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.
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.
- 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 is shared in an anonymous or deidentified format.
- Unclear whether 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.
- Social interactions between users are not 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 not shared for third-party advertising and/or marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Behavioral or targeted advertising is not displayed.
- Data are not collected by third-party advertising or tracking services.
- Data are not 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.
- Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
- Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- 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.
- Unclear whether this product allows parents to 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.
- Notification of a contract or additional rights is provided.
- Unclear whether this product designates the vendor as a school official.
- Parental consent obligations are transferred to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Directory information is disclosed.