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Privacy Evaluation for Kids' Vocab by MindSnacks

Last updated December 17, 2019

Overview

Kids' Vocab - MindSnacks allows kids to build vocabalary skills using the service. Kids' Vocab - MindSnacks state in their terms that participating in message boards could make personal information publicly visible to others. In addition, Kids' Vocab - MindSnacks terms state they collect personal information from users when they register for the Service, such as their email address, first, and last name. The terms do not disclose additional details about data security practices, or whether personal information is encrypted while in transit or while at rest, or whether the company provides notice to users in the event of a data breach. Lastly, the terms of Kids' Vocab - MindSnacks state for applications directed to children under the age of 13, they do not require an email address. The terms also state that children under the age of 13 should not register for the company's "general audience" mobile apps.

Kids' Vocab - MindSnacks is available for download at the iOS App Store. The Privacy Policy and Terms of Use accessed for this evaluation can be found on MindSnacks’ website, iOS App Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms of Kids' Vocab - MindSnacks state that participating in message boards could make users' personal information publicly visible to others. The terms also specify that people can connect other social services with Kids' Vocab, and that usernames and passwords for connected third-party services are collected and passed by the Service. The terms also state that users are responsible for their interactions with other users, and that MindSnacks has no obligation to be involved in any disputes. In addition, the terms do not contain details about any monitoring of social interactions. In the terms, MindSnacks encourages parents and legal guardians to become involved in the online activities of their children.

Privacy

The terms of Kids' Vocab - MindSnacks state they collect personal information from users when they register for the Service, such as their email address, first, and last name. In addition when a user interacts with Kids' Vocab, the Service automatically collects usage information via cookies. The terms state they do not share or sell a user’s personal information with third parties. However, the terms also state personally identifying information can be shared with subsidiaries or affiliates. The terms also state MindSnacks may conduct research on user demographics using interests and behavior from a user's personal information and other non-identifiable information. The terms state that any research provided to third parties will be compiled and analyzed by the Service on an aggregate and de-identified basis. Lastly, the terms state that the Service does not track users across other third-party websites.

Security

The terms of Kids' Vocab - MindSnacks state they take reasonable steps to protect a user's personal data provided through the Service from loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, the terms do not disclose any additional details about data security practices, or whether personal information is encrypted while in transit or while at rest, or whether the Service provides notice to users in the event of a data breach.

Compliance

The terms of Kids' Vocab - MindSnacks state for applications directed to children under the age of 13, they do not require an email address. The terms also state that children under the age of 13 should not register for the company's "general audience" mobile apps. As a practical matter, however, the effectiveness of these terms require that a parent or a child under the age of 13 would have an understanding of COPPA, read these terms of service, and understand the difference between an app directed to someone under 13, and an app directed for someone older than 13.

The terms state that if MindSnacks obtains actual knowledge that a child under 13 has stored Personal Information with the Service, the company will seek parental consent in accordance with COPPA. In addition, if a user is under 18 years old, the terms state that they may use parts of the Service, with or without registering, only with the approval of their parent or guardian. Full use of general-audience apps requires registering and creating a user account, and submitting personally identifiable information.

Lastly, MindSnacks' general audience apps would likely appeal to children under 13 and students in K-12. The definition of what constitutes "appeal" takes several factors into account, including subject matter, visual content, age of models, and the activities provided. If Kids' Vocab is used in a school classroom, the terms do not sufficiently disclose information about potential compliance obligations under FERPA, with respect to the creation of student education records.

Data Collection
SCORE: 40%

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.
Data Sharing
SCORE: 85%

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 not 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.
Data Security
SCORE: 15%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Unclear whether this product requires account creation.
  • 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.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether this product encrypts all data at rest.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 40%

What rights do I have to the data?

  • Opt-in consent is requested from users at the time personal information is collected.
  • Unclear whether users can control their information through privacy settings.
  • Users can create or upload content.
  • Unclear whether users retain ownership of their data.
  • Unclear whether this product provides processes to access and review user data.
  • Unclear whether this product provides processes to modify inaccurate data.
  • 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.
Data Sold
SCORE: 30%

Is the data sold?

  • Data are not sold or rented to third parties.
  • Unclear whether 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.
  • Data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 15%

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.
  • Unclear whether this product allows users to 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
SCORE: 25%

Are there advertisements or tracking?

  • Unclear whether data are shared for third-party advertising and/or marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Unclear whether this product displays behavioral or targeted advertising.
  • Unclear whether this product allows data collection by third-party advertising or tracking services.
  • Data are not used to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles 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.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 80%

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.
  • COPPA parental consent exceptions are indicated.
  • 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.
  • Parental consent notice and method for submission are provided.
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.

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.