Common Sense Privacy Program

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Privacy Evaluation for Parlay

Last updated
Applications and services with a Pass rating have met our minimum requirements for privacy and security practices. Before using an application or service with this rating, parents, teachers, schools, and districts are strongly advised to read the full privacy evaluation as a starting point for the process of vetting the application or service. In addition, a more detailed review should happen before any child or student data is shared with a product.

75%

Pass

Learn how we rate

Overview

Parlay is a service that assists teachers with the facilitation and assessment of in person and online discussions. The terms of Parlay clearly state that the service does not display any personal information about students and that student interactions only take place in a teacher moderated environment. The terms are also clear that while personal information is collected from students, the information is only used to facilitate the service and will not be used for any marketing purpose. Additionally, the terms indicate that Parlay takes reasonable measures to protect student data and outline a clear process of how any data breach would be handled. Finally, Parlay's terms state that the teacher or school must obtain parental consent before any personal information for children under 13 is provided to the service.

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

Safety

Parlay's terms are are clear that the service provides students the opportunity to upload content and communicate with one another. However, the terms state that the communications and uploads are moderated by the students' teacher and that participation is limited to only those students that have been invited by the teacher. Additionally, Parlay's terms indicate that the service takes measure to remove any personal information from content before that content may be made publicly visible. Additionally, the terms provide clear expectations for the behaviors allowed on the platform by users and provide a reporting mechanism should those expectations be violated.

Privacy

The terms for Parlay make clear that the service may collect personal information from users as part of the account creation process. Accounts in the Parlay system may be generated by the user creating them or by using a Single Sign-On service such as those provided by Google or Microsoft. However, the terms plainly state that the personal information collected by the service will not be used to display any advertisements to students or teachers. They are also clear that the service will not use third party advertising services or use tracking technology to display ads on other websites. Further, the terms indicate that the service may use third party analytics services, they are clear that those services will only be used for the purposes of operating or improving Parlay.

Security

Parlay's terms are also clear that the service participates in the iKeepSafe FERPA program to ensure up to date security measures are in place to protect data. The terms provide an explanation of the security audit process from iKeepSafe and state that Parlay will use the findings from those audits to improve upon the security measure in place. Additionally, the terms state that Parlay will use protection measures such as encryption and physical access controls to protect student data. Further, a data breach notification process is outlined where Parlay will notify schools in the event of a data breach then the schools are responsible for notifying students and parents as appropriate.

Compliance

The terms are clear that the Parlay service is intended to be used by students in grades 3-12 which includes children under 13. They clearly state that when a school is using the service with children, it is the responsibility of the school to obtain the necessary consent from parents before providing personal information from children. Further, the terms are clear that if Parlay is notified that they have collected the personal information of a child with the proper consent, they will delete that child's information from the system as soon as possible. Additionally, the terms clearly indicate that if a parent wishes to access or update a child's information in the Parlay system, they will require an authorized user at the school to provide a written request to the service. Finally, Parlay's terms state that account information will be deleted for any account that has been dormant in their system for more than one year. Also, all data related to a school's use of the service will be deleted at the conclusion of the contract unless Parlay is required to keep the data for reasons such as legal requests.

Rating

This product received a Pass rating based on the following details:
  • Intended for children under 13.
  • Unclear whether the collection or use of data is limited to product requirements.
  • Personal information can be not displayed publicly.
  • Users can interact with trusted users.
  • Notice is provided in the event of a data breach.
  • Parental consent is required before personal information is collected or disclosed.
Data Collection
SCORE: 35%

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.
  • Interactions, behaviors, or usage analytics data are collected.
  • 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 not collected by a third party.
Data Sharing
SCORE: 60%

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.
  • 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.
  • All data in transit are encrypted.
  • 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 retain ownership of their data.
  • Processes to access or review user data are available.
  • 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.
  • 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: 55%

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.
  • Users are notified if their information is transferred to a third party.
  • 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 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.
  • Contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 70%

How safe is this product?

  • Users can interact with trusted users.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information must be shared for social interactions.
  • Personal information can be not 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.
  • Social interactions between users are moderated.
  • Unclear whether social interactions of users are logged.
  • Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 85%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Traditional or contextual advertisements are not displayed.
  • Personalised advertising is not displayed.
  • Data are not collected by third-parties for their own purposes.
  • Users's information is not used 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.
  • Unclear whether this company provides promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 75%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Not 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.
  • Children's personal information is deleted if collected without parental consent.
  • Parental consent notice and method for submission are provided.
School Purpose
SCORE: 63%

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.
  • Processes to enter education records into the product are 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: 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.
  • Unclear whether company may combine data with additional data from third-party sources.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Notice is provided if the context in which data are collected changes.
  • Consent is not 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.
  • Unclear whether 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.

Learn more about the SPR Read the report

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.