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Privacy Evaluation for Learn French by MindSnacks

Last updated December 21, 2020

Overview

Learn French by MindSnacks allows users to learn French and play games simultaneously. With 9 games designed for essential vocab & conversation skills, MindSnacks’ French app is perfect for adults, kids, students and travelers who wants to read, write and speak one of the world’s most beautiful languages. Learn French by MindSnacks state in their terms that participating in message boards could make personal information publicly visible to others. In addition, Learn French by 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 Learn French by 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.

Learn French by 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 Learn French by 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 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 Learn French by 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, 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 Learn French by 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 Learn French by 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 the Service 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: 45%

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.
  • 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.
  • Unclear whether personal information of users is collected by a third party.
Data Sharing
SCORE: 90%

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.
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 managed accounts are available.
  • Unclear whether multi-factor account protection is available.
  • Unclear whether 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.
  • Unclear whether this product limits employee or physical access to user information.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether all data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 30%

What rights do I have to the data?

  • 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 data for authorized users.
  • A data-retention policy is available.
  • Processes for authorized users to delete data are available.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Data are not deleted when no longer necessary.
  • Unclear whether methods are available to restrict who has access to data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 30%

Is the data sold?

  • Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
  • 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 that is shared is shared in an anonymous or de-identified format.
  • Unclear whether 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.
Data Safety
SCORE: 15%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information must be shared for social interactions.
  • Personal information can be displayed publicly.
  • Unclear whether this product allows users to 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.
  • 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 personal information are shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Unclear whether this product displays personalised advertising.
  • Unclear whether data are collected by third-parties for their own purposes.
  • Users's information is not used to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
  • The company can send marketing messages.
  • Unclear whether this company provides promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 75%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Unclear whether intended for parents or guardians.
  • Company does 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.
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.
  • Processes to enter education records into the product are not described.
  • Unclear whether additional rights or protections may be provided with an additional school contract.
  • Unclear whether the company is designated as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: 45%

Can I control the use of my data?

  • Unclear whether users can control the use of their information through privacy settings.
  • Use of information is not 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.

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.