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Privacy Evaluation for Osmo Numbers

Last updated July 1, 2020

Overview

Osmo Numbers allows kids to arrange physical tiles, including dots and digits, to make numbers and complete levels. Osmo's terms state that they filter all user submissions to ensure no obvious Personal Information is included before any such content is made available publicly. However, Osmo's terms state they may use collected information to assist their marketing efforts, including, for example, by tailoring and serving advertisements. Osmo's terms state they take commercially reasonable physical, electronic, and procedural safeguards to protect Personal Information. Lastly, if a school and/or teacher uses the service with students that are under 18 years of age and provides personally identifiable information about students they must first obtain written consent from each student’s parent and/or legal guardian.

Osmo Numbers can be accessed through its website, and is available for download at the iOS App Store, and the Amazon App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Osmo Number’s website, iOS App Store, Google Play Store, and the Amazon App Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Osmo's terms state that they filter all user submissions to ensure no obvious Personal Information is included before any such content is made available publicly. The terms of Osmo state that users can interact with other users through comments, reviews, and other content. Osmo's terms do not explicitly state whether or not social interactions are regularly moderated or monitored. In addition, the terms of Osmo do not explicitly state whether or not the vendor provides tools and processes that support safe and appropriate social interactions on the product.

Privacy

Osmo's terms state that they collect physical addresses. The terms of Osmo state that Personal Information and non-Personal Information may be combined. However, Osmo's terms state they may use collected information to assist their marketing efforts, including, for example, by tailoring and serving advertisements. Osmo's terms state that they limit the information provided to third-party service providers to only what is reasonably necessary for them to perform the functions of the service, and third-party providers are legally bound to maintain the confidentiality of personal information.

Security

Osmo's terms state they take commercially reasonable physical, electronic, and procedural safeguards to protect Personal Information. However, the terms of Osmo do not state whether encryption is used to protect personal information. In addition, Osmo's terms state that in the event of a breach affected users will be promptly notified. The terms of Osmo state that a user must create an account with a username and password to access the service. Lastly, Osmo's terms state that they may verify a user's identity with Personal Information before allowing a user to request deletion of or access to personal information.

Compliance

The terms of Osmo state that the website is not intended for children, they do not market the service to children, and they do not knowingly collect personal information from children. However, Osmo's terms also state that its play experience is directed at users of all ages, including children. The terms state that users may update, correct, or delete their personal information and preferences at any time by accessing their account preferences page on the website or contacting Osmo. Lastly, if a school and/or teacher uses the service with students that are under 18 years of age and provides personally identifiable information about students they must first obtain written consent from each student’s parent and/or legal guardian.

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 not limited to product requirements.
  • Geolocation data are collected.
  • Unclear whether this product collects biometric or health data.
  • Interactions, behaviors, or usage analytics data are collected.
  • Unclear whether this product collects sensitive data.
  • Data is automatically collected.
  • 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: 80%

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.
  • The roles of third-party service providers are indicated.
  • Unclear whether this product supports third-party login.
  • 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 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.
Data Rights
SCORE: 65%

What rights do I have to the data?

  • Users can create or upload content.
  • Users do not 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.
Data Sold
SCORE: 50%

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.
  • Third-party transfer is contractually required to use the same privacy practices.
  • User information that is shared is not 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.
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.
  • Unclear whether this product allows users to control how their data are displayed to others.
  • User-created content is reviewed, screened, or monitored by the company.
  • 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: 45%

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.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Data profiles are not created and used for personalised advertisements.
  • The company can send marketing messages.
  • The company does provide 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.
Parental Consent
SCORE: 70%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is not collected.
  • Intended for parents or guardians.
  • Company does have 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.
  • 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.
  • Parental consent notice and method for submission are provided.
School Purpose
SCORE: 44%

Is the product intended for school?

  • Intended for students.
  • Unclear whether 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.
  • Unclear whether additional rights or protections may be provided with an additional school contract.
  • Unclear whether the company is designated as a school official.
  • Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 85%

Can I control the use of my data?

  • 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.
  • Combined information is treated 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.
  • Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
  • 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.