Privacy Evaluation for Osmo Tangram
Osmo Tangram allows kids to arrange puzzle pieces to match on-screen shapes and play with a friend or challenge others to increasingly difficult levels as their handiwork lights up with each victory. 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'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.
Osmo's terms state that they do not collect information about a user's location from their mobile device, but the vendor does log a user's IP address, which can be used to approximate location. The terms of Osmo state that Personal Information and non-Personal Information may be combined and that this combination is treated as Personal Information. 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.
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.
The terms of Osmo state that the service 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. There is no mention in the terms of an age-gate (or similar) process to verify that children are not using the service. 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.
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.
- Behavioral data are collected.
- Unclear whether this product collects sensitive data.
- Non-personally identifiable information is 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.
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.
- The roles of third-party service providers are indicated.
- Unclear whether this product supports social or federated login.
- 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 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.
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 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.
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.
- Third-party transfer is contractually required to use the same privacy practices.
- User information is not 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.
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.
- Unclear whether this product allows users to control how their data are displayed.
- User-created content is reviewed, screened, or monitored by the vendor.
- 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
Are there advertisements or tracking?
- Data are shared for third-party advertising and/or marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Behavioral or targeted advertising is displayed.
- Data are collected 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.
- Data profiles are not created and used for data enhancement, and/or targeted advertisements.
- The vendor can send marketing messages.
- The vendor does provide 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.
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is not collected online.
- Intended for parents or guardians.
- Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- Parental consent is required.
- 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.
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.
- Unclear whether the product creates education records.
- Unclear whether this product provides notification of a contract or additional rights.
- Unclear whether this product designates the vendor as a school official.
- Parental consent obligations are transferred to the school or district.
- FERPA parental consent exceptions are not indicated.
- Unclear whether this product discloses directory information.