Privacy Evaluation for Pattern Shapes, by the Math Learning Center
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.
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.
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.
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.
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.
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.
- 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.
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.
- Unclear whether the categories of third parties that receive data are indicated.
- 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.
- Unclear whether this product supports third-party login.
- Contractual limits are placed on third-party data use.
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.
- 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.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- All data are stored in an encrypted format.
- Notice is not provided in the event of a data breach.
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.
- Processes to modify data are available for authorized users.
- A data-retention policy is available.
- Processes for authorized users to delete data are available.
- 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.
- Processes to download user data are available.
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 cannot 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.
- 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 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.
How safe is this product?
- Users can interact with trusted users.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information must be not shared for social interactions.
- Personal information can be displayed publicly.
- Users can 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
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Traditional or contextual advertisements are not displayed.
- Personalised advertising is not 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.
- The company can send marketing messages.
- Unclear whether this company provides 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.
Can I provide parental consent?
- Unclear whether intended for children under 13.
- Unclear whether this product collects personal information from children under 13 years of age.
- 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 not 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.
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.
- 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.
- Unclear whether this product transfers parental consent obligations to the school or district.
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 will not 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 obtained if the practices in which data are collected change.
- A grievance or remedy mechanism is not available for users to file a complaint.
- 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.