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Privacy Evaluation for Pattern Shapes, by the Math Learning Center

Last updated June 12, 2019

Overview

Students use Pattern Shapes, by the Math Learning Center (MLC) to explore geometry and fractions, create their own designs, or filling in outlines. The terms state the service may contain one or more areas where users can post content that can be publicly viewed by others. The terms state MLC may collect personally identifiable information and non-personal usage information automatically for data analytics. In addition, the terms state MLC uses commercially reasonable physical, electronic, and managerial security measures to assist in protecting against the loss, misuse, and unauthorized alteration of personally identifiable information that is under their control. Lastly, The terms do not disclose whether personal information is collected from students in K-12 or children under 13 years of age, how that information is used, or MLC's disclosure practices of that information without parental consent.

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

Safety

The terms state the service may contain one or more areas where users can post content that can be publicly viewed by others. When a user voluntarily discloses Personally Identifiable Information on these areas of the service for public viewing, their information may be collected, stored, used, and disclosed by other users. In addition, the service may also provide blogs or web forums which may or may not be pre-screened or monitored by MLC for user-generated content. Therefore, users should use caution when posting information, because it may be publicly visible to others.

Privacy

The terms state MLC may collect personally identifiable information and non-personal usage information automatically for data analytics. A visitor to the service does not need to provide personal information in order to browse or use some of features of the service. In addition, MLC will not sell or otherwise transfer or disclose a user's personally identifiable information to any third party. However, MLC may share a user's de-identified aggregated automatically collected information with third parties without restriction.

Users should be aware that any automatically collected information may be combined with personally identifiable information that a user may have provided. If a user chooses to provide the service with their contact information, they may contact users with offers for products and services that may be of interest to them. Lastly, the terms state MLC does not display any advertising to users on its service or engage in ad tracking.

Security

The terms state MLC uses commercially reasonable physical, electronic, and managerial security measures to assist in protecting against the loss, misuse, and unauthorized alteration of personally identifiable information that is under their control. This includes the use of firewalls, encryption during transmission and at rest, vulnerability scans, and other security measures. However, MLC cannot guarantee the security of their servers, or the means by which personally identifiable information is transmitted between a user's computer and their servers, and does not disclose whether they provide notice to users in the event of a data breach.

Compliance

The terms do not disclose whether personal information is collected from students in K-12 or children under 13 years of age, how that information is used, or MLC's disclosure practices of that information without parental consent. MLC's apps would likely appeal to children under 13 years of age, which takes several factors into consideration such as: the subject matter, visual content, the use of animated characters or child-oriented activities and incentives, music or other audio content, age of models, presence of child celebrities or celebrities who appeal to children, language or other characteristics of the product.

Data Collection
SCORE: 35%

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 limited to product requirements.
  • Unclear whether this product collects geolocation data.
  • 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.
  • 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: 75%

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.
  • Use of information is limited to the purpose for which it was collected.
  • 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.
  • Unclear whether this product supports social or federated login.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 65%

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.
  • Employee or physical access to user information is limited.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Notice is not provided in the event of a data breach.
Data Rights
SCORE: 95%

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.
  • Processes to modify inaccurate data are available.
  • A data-retention policy is available.
  • Processes for the school, parents, or students to delete data are available.
  • Processes to delete user data are available.
  • Processes to download user data are available.
Data Sold
SCORE: 60%

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 cannot be transferred to a third party.
  • 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 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: 65%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information is not shared for social interactions.
  • Personal information is displayed publicly.
  • Users can 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
SCORE: 75%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are not displayed.
  • Behavioral or targeted advertising is not displayed.
  • Data are not collected by third-party advertising or tracking services.
  • Data are not used 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.
  • 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: 0%

Can I provide parental consent?

  • Unclear whether 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.
  • 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: 30%

Is the product intended for school?

  • Unclear whether 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.
  • Product does create 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.
  • Unclear whether this product transfers parental consent obligations 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.