Privacy Evaluation for MobyMax
MobyMax helps struggling learners quickly catch up to grade level and closes learning gaps for students. The policies for MobyMax are clear that the service will store personal information, but also clearly state that the service will not collect any sensitive information. The policies are also clear that the service may allow users to create content and communicate with each other, and that those postings will not be monitored by the service. Further, the policies are clear that the service has security measures in place to protect data, but do not provide any detail about those measures. Finally, the policies state that the service will help schools and districts comply with privacy laws, but do not indicate how the service complies with COPPA or FERPA regulations.
The policies for MobyMax indicate that users of the service are able to post content and communicate through the service. Further, the policies are clear that the content and communications posted to the service are not moderated or filtered. While the policies do indicate that the service may remove any content that is posted in violation of the terms, they do not offer any guarantees that such content will be removed in a timely manner. The policies are also clear that by posting content to the service, users are granting the service the right to publish that content and the user's name publicly.
MobyMax's policies provide a statement that the service will use security measures to protect user data. However, they do not indicate the types of security measures that may be in place, such as physical access controls or data encryption. The policies clearly state that the service will notify users in the event of a data breach and will work with schools and districts to notify parents. The policies also indicate that the service will verify a user with a phone call prior to that user being given access to the system. Finally, the policies indicate that users may use some portions of the service without providing any personal information.
The policies for MobyMax provide a broad statement that the service will work with schools and districts to comply with laws such as COPPA and FERPA, but they do not provide details about how the service aids in compliance. The policies do, however, indicate that the school or district will retain control of student data that is collected by the service. They also indicate that teachers may provide parents with accounts to the service to monitor children. Finally, the policies provide a method to delete information stored by the service, but do not indicate a timeline for when the deletion will be complete.
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.
- Sensitive data are not collected.
- Data is automatically collected.
- Unclear whether 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.
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.
- Unclear what the roles of third-party service providers are.
- Third-party login is supported.
- Unclear whether 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 not required.
- 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.
- 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.
- Unclear whether the product provides a data-retention policy.
- Processes for authorized users to delete data are available.
- A user's data are not deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Unclear whether methods are available to restrict who has access to data.
- Processes to download user data are available.
Is the data sold?
- Personal information is 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 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.
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 cannot control how their data are displayed to others.
- User-created content is not reviewed, screened, or monitored by the company.
- User-created content is not 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?
- 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.
- Unclear whether this product uses a user's information 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.
Can I provide parental consent?
- Unclear whether intended for children under 13.
- Unclear whether this product collects personal information from children under 13 years of age.
- 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 not provide a section, heading, or separate policy for children in their policies.
- Unclear whether parental consent is required before personal information is collected or disclosed.
- 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.
- 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.
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 not described.
- 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.
Can I control the use of my data?
- Unclear whether 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.
- 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 not 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.