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Privacy Evaluation for Lucid Chart

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Overview

Lucid Chart is a productivity platform that provides collaboration for enterprises, schools, and hybrid teams. The privacy policy clearly indicates that users can interact with both trusted and untrusted users by creating, uploading, and copying content into Lucid. The privacy policy also states that Lucid collects users’ names, email addresses, telephone numbers, postal addresses, credit card information, and other contact or identifying information the user chooses to provide. The privacy policy provides a non-exhaustive list of the categories of user information Lucid shares with third parties and discloses that Lucid and third parties may use collected information to serve users targeted advertising. The security program policy states Lucid encrypts users’ personal information both at rest and at transit. The privacy policy provides that users have the right to access, edit, and delete their personal information.

Lucid Chart 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 Lucid Chart’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Sub-Processor List, Cookie Policy, GDPR Compliance, Security Program, Code of Ethics and Conduct, Data Processing Addendum, Education Privacy Policy, Global Anti-Bribery & Anti-Corruption Policy, and Developer Terms of Service. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The Privacy Policy clearly indicates that users can interact with both trusted and untrusted users by creating, uploading, and copying content into Lucid and sharing it with both people the user knows and people the user does not know, including sharing information in with users participating in a chat function. The Privacy Policy fully discloses that Lucid retains the right to publicize its customers’ identities on its website or in its customer list, blogs, and other marketing materials or public communications. The terms fail to state whether Lucid takes reasonable measures to delete personal information from a user’s posting before it is made publicly available, whether interactions between users are moderated, or whether users have the option of reporting inappropriate content.

Privacy

The Privacy Policy clearly states that in the preceding 12 months, Lucid has collected identifies, financial information, internet or electronic network activity information, professional and employment-related information, and inferences. The terms do not clearly state whether Lucid’s collection of information is limited to only data that are specifically required for the product, or whether Lucid collects geolocation data, health or biometric data, behavioral data, or sensitive data. The Privacy Policy provides that Lucid’s servers automatically collect information about a user’s use of Lucid’s Services, and that third party providers collect user data through cookies, web beacons, device identifiers, and other tracking technologies. The Privacy Policy clearly states that Lucid may share your personal information with third parties and that the categories of information shared with third parties includes identifiers, financial information, internet or electronic network activity information, professional employment-related information, education information, inferences, and other information provided by the user.

The Privacy Policy also indicates that Lucid sells personal information to advertisers so third parties can serve targeted advertisements promoting Lucid to on other properties. However, the Data Processing Addendum, which applies exclusively to enterprise-designated accounts, states that Lucid does not sell the personal information of these types of account holders. The terms provide an extensive list of third party processing providers as well as the roles of the third-party service providers. The Privacy Policy discloses that Lucid shares personal information for analytical and marketing purposes. However, the terms do not clearly disclose whether Lucid shares personal information for product improvement or research purposes. The Privacy Policy provides users a method of opting out of certain targeted advertising vendors and for opting out of the sale and sharing of the user’s personal information.

Security

The Security Program policy clearly dictates that Lucid implements reasonable security standards and encrypts user information both at rest and in transit. Furthermore, the Security Program policy states that Lucid imposes physical security measures to protect the confidentiality of user personal information. The Privacy Policy indicates that Lucid verifies the identity of users requesting to access, edit, or delete their information by requiring the user to receive a verification email with the email associated with the Lucid account. The terms do not dictate whether site visitors must create a Lucid account before using Lucid’s services. The Terms of Service indicate that schools, school districts, and related persons control students’ personal information. The terms state that Lucid obligates third parties with access to users’ information to provide an equivalent level of data protection as Lucid. The terms fail to state whether Lucid will notify users in the event of a data security breach.

Compliance

The Education Privacy Policy states that schools “are responsible for ensuring that they have any parental consent necessary to share personal information with us and to allow us to collect personal information from Students.” The terms are unclear on whether parents can consent to the collection and use of their child’s personal information without also consenting to the disclosure of the information to third parties. However, the Education Privacy Policy clearly provides that parents may withdraw consent for Lucid to collect their child’s personal information.

The terms clearly state that users can create and upload content to Lucid’s services and that the user retains ownership over their content uploaded to Lucid, but grants Lucid a limited license over the content. The Privacy Policy indicates that users can designate an authorized agent to request privacy rights on the users’ behalf, including accessing, editing, deleting, and downloading user personal information. However, the Privacy Policy discloses that even if a user deletes personal information from an account, or deactivates an account, that Lucid “may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your information for a certain period of time.” The terms fail to disclose how long it may take to process a privacy rights requests.

Rating

This product received a Warning rating based on the following details:
  • Personal information is sold or rented to third parties.
  • Personal information is shared for third-party marketing.
  • Personalised advertising is 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.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
Data Collection
SCORE: 25%

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.
  • Unclear whether this product collects geolocation data.
  • Unclear whether this product collects biometric or health data.
  • Unclear whether this product collects interactions, behaviors, or usage analytics data.
  • Unclear whether this product collects sensitive data.
  • Data is automatically collected.
  • Unclear whether opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is collected by a third party.
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.
  • The categories of third parties that receive data are indicated.
  • Data are shared for analytics.
  • Unclear whether 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: 95%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is not required.
  • Managed accounts are available.
  • 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.
  • All data in transit are encrypted.
  • All data are stored in an encrypted format.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 65%

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.
  • Unclear whether authorzied users can delete data.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Unclear whether this product deletes data when no longer necessary.
  • Methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 20%

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.
  • 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.
  • Unclear whether 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.
  • Unclear whether 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: 40%

How safe is this product?

  • Users can interact with 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.
  • Users can control how their data are displayed to others.
  • 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
SCORE: 50%

Are there advertisements or tracking?

  • Personal information is shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Personalised advertising is 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.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
  • The company can send marketing messages.
  • The company does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 45%

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.
  • Unclear whether company has 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.
  • 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: 88%

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.
Individual Control
SCORE: 60%

Can I control the use of my data?

  • Users can control the use of their information through privacy settings.
  • Unclear whether use of information is limited to the purpose for which it was collected.
  • The context or purpose for which data are collected is indicated.
  • 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 not 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.
  • 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.