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Privacy Evaluation for MobyMax

Last updated January 17, 2020

Overview

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.

MobyMax can be accessed through its website. The Privacy Policy and Terms of Use used for this evaluation can be found on MobyMax’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

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.

Privacy

The privacy policy for MobyMax is clear about the personal information that is collected by the service and indicates that schools may elect to use aliases instead of student names. Also, the policy clearly states that the service will not collect any sensitive information from users. Further, the policies clearly state that if there are material changes to the policies, users will be given 30 days to decide whether to continue using the service. The policies also indicate that the service employs tracking technology, but are not clear how the information collected may be used in conjunction with third-party advertising. Finally, the policies clearly state that the service will not sell or rent user data to third parties.

Security

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.

Compliance

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.

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.
  • Behavioral data are collected.
  • Sensitive data are not collected.
  • Non-personally identifiable information is 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.
Data Sharing
SCORE: 70%

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 personal information are indicated.
  • Data are shared for analytics.
  • Data are shared for research and/or product improvement.
  • Data are shared with third-party service providers.
  • Unclear whether the roles of third-party service providers are indicated.
  • Social or federated login is supported.
  • Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 45%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is not required.
  • 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.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 70%

What rights do I have to the data?

  • 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.
  • A user's data are not deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 40%

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.
  • 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: 40%

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.
  • Unclear whether profile information is shared for social interactions.
  • Personal information is displayed publicly.
  • Users cannot control how their data are displayed.
  • User-created content is not reviewed, screened, or monitored by the vendor.
  • 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
SCORE: 15%

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.
  • Unclear whether this product uses data 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: 10%

Can I provide parental consent?

  • Unclear whether intended for children under 13.
  • Unclear whether this product collects personal information online from children under 13 years of age.
  • Intended for parents or guardians.
  • Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
  • Unclear whether children's privacy is applicable.
  • Unclear whether this product requires parental consent.
  • 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.
School Purpose
SCORE: 45%

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.
  • Unclear whether the product creates education records.
  • Notification of a contract or additional rights is provided.
  • 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.