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Privacy Evaluation for Neo

Last updated January 17, 2020

Overview

NEO is a learning management system (LMS) for managing classroom activities. The service description on their site states that NEO focuses on delivering a great learning experience, while incorporating all the essential tools schools need to support efficient teaching and learning. NEO does not disclose in its policies whether a user can interact with other trusted users or whether a user's personal information can be displayed publicly in any way. However, NEO's terms do state that they may review, screen, or monitor user-created content and can delete it if the content violates its policies. NEO does not display a version or effective date of the polices. A version or effective date provides notice to consumers of exactly what terms they actually provide their consent to and, more importantly, gives notice in the event any changes are made to the policies, requiring a new effective date.

In addition, NEO's terms state they use industry best practices to protect the privacy and security of users' data. Lastly, NEO's terms state that because they provide a LMS platform, schools and districts are fully responsible for the data hosted on the platform and how they use it. The terms of NEO state that schools and districts are the "data collector" and NEO is the "data processor".

NEO can be accessed through its website, and is available for download at the iOS App Store, the Google Play Store, and Microsoft Appstore. The Privacy Policy and Terms of Use used for this evaluation can be found on NEO’s website, iOS App Store, the Google Play Store, and Microsoft Appstore. Additionally, other policies used for this evaluation include: EU General Data Protection Regulation. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

NEO does not disclose in its policies whether a user can interact with other trusted users or whether a user's personal information can be displayed publicly in any way. However, NEO's terms do state they may review, screen, or monitor user-created content and can delete it if the content violates its policies.

Privacy

NEO does not display a version or effective date of the polices. A version or effective date provides notice to consumers of exactly what terms they actually provide their consent to and, more importantly, give notice in the event any changes are made to the policies, requiring a new effective date. The terms state that any personal information shard with third-parties would also subject those third parties to the same privacy protections of user data as NEO. The terms state NEO may engage in first-party marketing campaigns that might be suited for users such as invitations to webinars and events, content marketing campaigns, campaigns related to NEO's platforms and blogs, research campaigns related to its platforms, blogs, and industry. However, overall the terms are not transparent about several important privacy practices. For example, the terms do not disclose information about whether user data is sold, or whether personal information is used for behavioral advertising or tracking purposes.

Security

NEO's terms state they use industry best practices to protect the privacy and security of users' data. In addition, the terms specify they use a rate limiter to prevent script kiddies or malicious attackers from overwhelming their system, and their Amazon servers are hosted in their own VPC (virtual private cloud), and all remote ssh logins are protected using public/private keys. The terms further disclose that all communications are encrypted over HTTPS, and they use secure storage with all personal passwords encrypted with individual SALT values on secure servers. Lastly, the terms of NEO state they follow industry best practices to ensure the security of our system and prevent breaches. If NEO detects a security breach, the terms state they will immediately work to fix the issue as well as alert our users if there is a threat to their content or passwords so that they can take appropriate action such as resetting their passwords.

Compliance

NEO's terms state that because they provide a LMS platform, schools and districts are fully responsible for the data hosted on the platform and how they use it. The terms of NEO state that schools and districts are the "data collector" and NEO is the "data processor". NEO's terms further specify that they only collect the data that schools or districts use when registering for its platforms, which is usually the administrator account of the platform. The terms further specify that NEO's LMS platform can only be used by schools for children and accredited universities/colleges that award degrees. The terms also state users can access, review and delete their information and all related data. In addition, the terms state NEO is FERPA compliant, but the terms do not provide any additional detail about FERPA compliance, and do not discuss whether parental consent should be obtained, or whether NEO will delete information from children under the age of 13 if collected without parental consent. Lastly, NEO's terms state that they comply with the EU-US Privacy Shield.

Data Collection
SCORE: 15%

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 behavioral data.
  • Unclear whether this product collects sensitive data.
  • Unclear whether this product collects non-personally identifiable information.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Unclear whether this product collects personal information online from children under 13 years of age.
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.
  • Unclear whether use of information is limited to the purpose for which it was collected.
  • Unclear whether data are shared for analytics.
  • Unclear whether 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: 60%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Account creation is 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.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 75%

What rights do I have to the data?

  • Opt-in consent is requested from users at the time personal information is collected.
  • Users can control their information through privacy settings.
  • Users can create or upload content.
  • Users retain ownership of their data.
  • Processes to access and review user data are available.
  • Unclear whether this product provides processes to modify inaccurate data.
  • A data-retention policy is available.
  • Unclear whether the school, parents, or students can delete data.
  • Processes to delete user data are available.
  • Processes to download user data are available.
Data Sold
SCORE: 0%

Is the data sold?

  • Unclear whether data are sold or rented to third parties.
  • Unclear whether users can opt out from the disclosure or sale of their data to a third party.
  • Unclear whether 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.
  • Unclear whether user information is shared in an anonymous or deidentified format.
  • Unclear whether the vendor describes their deidentification process of user information.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 20%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users and/or students.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information is shared for social interactions.
  • Unclear whether this product displays personal information publicly.
  • Unclear whether this product allows users to control how their data are displayed.
  • 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 moderated.
  • Unclear whether social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 20%

Are there advertisements or tracking?

  • Unclear whether data are shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • 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: 20%

Can I provide parental consent?

  • Intended for children under 13.
  • Unclear whether 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 indicates COPPA parental consent exceptions.
  • Unclear whether this product requires parental consent.
  • 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: 45%

Is the product intended for school?

  • Intended for students.
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • Product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Product does create education records.
  • Notification of a contract or additional rights is provided.
  • Unclear whether this product designates the vendor as a school official.
  • Parental consent obligations are transferred 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.