Privacy Evaluation for Neo
36%
Overview
Neo is a product of Cypher Learning, which specializes in providing online learning platforms for schools and universities to aid students, teachers, and administration. The policy does not indicate if Neo moderates social interactions between users. The policy specifies Neo collects personal data such as name, gender, email address, phone number, and other contact information. The policies confirm Neo uses third party cookies from Google Ads, Facebook Business, Twitter Ads, Instagram Ads, LinkedIn Ads and more to gather information and serve interest based ads. Furthermore, the policy states users are able to share content to Facebook, Twitter, LinkedIn and other social media services. The policy confirms only authorized users are entitled to access the platform with their unique username and password. The policy states Neo employs reasonable security measures such as password controls, monitoring and maintenance, network security controls, and vulnerability and threat assessments to protect user data, but does not indicate if data encryption is used for data in transit. The policy states Neo is a "School Official" with "Legitimate Educational Interests in regards to education records and student information according to FERPA requirements, but it does not clearly indicate the age of its intended users. Furthermore, the responsibility to collect verifiable parental consent is passed onto the “customer” (school).
Neo 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 Neo’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Cookie Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The policy states Neo may use Customer name and Customer Marks on its website, social media, and marketing materials. Furthermore the policy states customer content will be made available to end users through the platform. Furthermore, the policy states Neo doesn't filter user submissions for personal data, but asks customers not to post anything that contains personal information.
Privacy
The policy states the services use usage and analytics data to improve the services, platform, and other related products. Furthermore, Neo has enabled IP anonymization for Google Analytics. The policy states Neo may share data with third parties with customer consent. The policy also specifies Neo shares information with third parties such as Amazon Web Services and Google Workspace to support the infrastructure of the services and for email and file sharing, with Vanta for audit logs and evidencing, and with NetSuite for ERP system of record. The policy states Neo may transfer data in the event of a company merger, reorganization, or sale but does not indicate if user consent will be collected or if users will be notified. In addition, the policy states Neo may not process data other than on customer's instructions or as required, but it doesn't say that the collection of data is limited.
Security
The policy states customers may select authorized users such as employees, agents, or independent contractors to access the platform in accordance with the policy requirements. In addition, the policy states Neo implements physical access controls and restricts employee access to data based on authority levels and job functions.The policy does not indicate if multi-factor authentication is used to protect user accounts. The policies confirm Neo will enter into a binding contract with service providers that imposes data protection obligations which meet or exceed the relevant standards required in the policy. The policy states Neo will notify users in the event of a personal data security breach.
Compliance
The policies do not indicate if users can access, modify, or delete personal data held by Neo. However, the policy states Neo will return all data to the customer and then delete the data after the account or services have been terminated.
Rating
- Personal information is not 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.
- Data profiles are created and used for personalised advertisements.
Data Collection
SCORE: 45%
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.
- Geolocation data are not collected.
- Biometric or health data are not collected.
- 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: 50%
What data does it share?
- Collected information is shared with third parties.
- Unclear whether 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 the categories of third parties that receive data are indicated.
- Unclear whether 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.
- Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 70%
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Unclear whether 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.
- Unclear whether this product encrypts all data in transit.
- All data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
Data Rights
SCORE: 45%
What rights do I have to the data?
- Users can create or upload content.
- 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.
- Unclear whether authorzied users can delete data.
- A user's data are 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.
- Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 25%
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.
- Third-party transfer is 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: 5%
How safe is this product?
- Unclear whether this product supports interactions between trusted users.
- Unclear whether 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.
- 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: 40%
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Traditional or contextual advertisements are displayed.
- 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.
- Data profiles are created and used for personalised advertisements.
- Unclear whether this company can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 15%
Can I provide parental consent?
- Unclear whether 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.
- 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.
School Purpose
SCORE: 38%
Is the product intended for school?
- Unclear whether intended for students.
- 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.
- 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.
- Company is designated as a school official.
- Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 35%
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 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).
- Unclear whether notice is provided if the context in which data are collected changes.
- Unclear whether consent is obtained if the practices in which data are collected change.
- Unclear whether 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.