Common Sense has recently updated its privacy notice. We also provide an overview of the entire policy here.

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Privacy Evaluation for Proloquo2Go

Last updated December 19, 2022

Overview

Proloquo2Go is a symbol-based Augmentative and Alternative Communication (AAC) app for iOS devices that provides a communications environment for non-speaking people. Its terms state that children, students, and adults may be users of their service. Proloquo2Go's terms state that they do collect information from those who register for accounts or contact their support team, but that they don't collect student data, and any student data shared with them is treated as confidential. Additionally, the terms state that most personal information will not be shared with third parties, but that information shared with the support team may be shared with product development partners for limited purposes. Additionally, the terms state that third-party tracking technologies who collect information from users are not allowed to use the information for their own purposes. The terms make no mention of sharing information with third parties for marketing purposes, nor of any advertising, tracking on other sites, or profiling in the service. The terms do state that users may subscribe to a newsletter. The terms don't mention any use of encryption for security, nor what action they may take in the event of a data breach. The terms explain that many of their products facilitate communication for their user, but there is no mention of users communicating with other users through the app or that any user information may be made publicly visible. According to Proloquo2Go's terms, user content/vocabulary is stored on the local device, but the company has no access to that content. Finally, the terms make no mention of users being able to access or modify any personal information held by the company, but that users may request deletion of any student data or personal information previously shared with the company.

Proloquo2Go can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms & Conditions used for this evaluation can be found on Proloquo2Go’s website and iOS App Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Data Collection
SCORE: 33%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • Unclear if the categories of personally identifiable information collected are indicated.
  • Collection or use of data is not limited to product requirements.
Not yet answered
  • This evaluation did not assess whether this product collects geolocation data.
  • This evaluation did not assess whether this product collects biometric or health data.
  • This evaluation did not assess whether this product collects behavioral data.
  • This evaluation did not assess whether this product collects sensitive data.
  • This evaluation did not assess whether this product automatically collects any data.
  • This evaluation did not assess whether opt-in consent is requested from users at the time personal information is collected.
  • This evaluation did not assess whether personal information of users is collected by a third party.
Data Sharing
SCORE: 100%

What data does it share?

  • Collected information is shared with third parties.
  • Contractual limits are placed on third-party data use.
Not yet answered
  • This evaluation did not assess whether the categories of information are shared with third parties are indicated.
  • This evaluation did not assess whether the purpose for sharing a user's personal information with third parties is indicated.
  • This evaluation did not assess whether the categories of third parties that receive data are indicated.
  • This evaluation did not assess whether data are shared for analytics.
  • This evaluation did not assess whether data are shared for research and/or product improvement.
  • This evaluation did not assess whether third-party services are used to support the product.
  • This evaluation did not assess whether the roles of third-party service providers are indicated.
  • This evaluation did not assess whether this product supports third-party login.
Data Security
SCORE: 0%

How does it secure data?

  • Unclear whether this product encrypts all data in transit.
  • Unclear whether all data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Not yet answered
  • This evaluation did not assess whether a user's identity is verified with additional personal information.
  • This evaluation did not assess whether this product requires account creation.
  • This evaluation did not assess whether managed accounts are available.
  • This evaluation did not assess whether multi-factor account protection is available.
  • This evaluation did not assess whether Third-parties with access to information are required to provide the same security protections as the company.
  • This evaluation did not assess whether this product uses reasonable security practices to protect data.
  • This evaluation did not assess whether this product limits employee or physical access to user information.
Data Rights
SCORE: 38%

What rights do I have to the data?

  • Users can create or upload content.
  • Unclear whether this product provides processes to access and review user data.
  • Unclear whether this product provides processes to modify data for authorized users.
  • Processes for authorized users to delete data are available.
Not yet answered
  • This evaluation did not assess whether users retain ownership of their data.
  • This evaluation did not assess whether the product provides a data-retention policy.
  • This evaluation did not assess whether a user's data are deleted upon account cancellation or termination.
  • This evaluation did not assess whether this product deletes data when no longer necessary.
  • This evaluation did not assess whether methods are available to restrict who has access to data.
  • This evaluation did not assess whether this product provides users the ability to download their data.
Data Sold
SCORE: 0%

Is the data sold?

  • Unclear whether personal information is sold or rented to third parties.
  • Unclear whether user information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
Not yet answered
  • This evaluation did not assess whether users can opt out from the disclosure or sale of their data to a third party.
  • This evaluation did not assess whether users are notified if their information is transferred to a third party.
  • This evaluation did not assess whether user information can be deleted prior to its transfer to a third party.
  • This evaluation did not assess whether third-party transfers are contractually required to use the same privacy practices.
  • This evaluation did not assess whether user information is shared in an anonymous or de-identified format.
  • This evaluation did not assess whether the company describes their de-identification process of user information.
  • This evaluation did not assess whether data are shared for research and/or product improvement.
  • This evaluation did not assess whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 0%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether personal information can be displayed publicly.
Not yet answered
  • This evaluation did not assess whether profile information must be shared for social interactions.
  • This evaluation did not assess whether this product allows users to control how their data are displayed to others.
  • This evaluation did not assess whether user-created content is reviewed, screened, or monitored by the company.
  • This evaluation did not assess whether user-created content is filtered for personal information before being made publicly visible.
  • This evaluation did not assess whether social interactions between users are moderated.
  • This evaluation did not assess whether social interactions of users are logged.
  • This evaluation did not assess whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 36%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Unclear whether this product displays personalised advertising.
  • Data are not 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.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
  • The company can send marketing messages.
Not yet answered
  • This evaluation did not assess whether this company provides promotional sweepstakes, contests, or surveys.
  • This evaluation did not assess whether this product provides users the ability to opt-out of contextual, or personalised advertising.
  • This evaluation did not assess whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 50%

Can I provide parental consent?

  • Intended for children under 13.
  • Unclear whether parental consent is required before personal information is collected or disclosed.
Not yet answered
  • This evaluation did not assess whether this product collects personal information from children under 13 years of age.
  • This evaluation did not assess whether intended for parents or guardians.
  • This evaluation did not assess whether company has actual knowledge that personal information from users under 13 years of age is collected.
  • This evaluation did not assess if the company provides a section, heading, or separate policy for children in their policies.
  • This evaluation did not assess whether this product limits parental consent with respect to third parties.
  • This evaluation did not assess whether this product allows parents to withdraw consent for the further collection of their child's information.
  • This evaluation did not assess whether this product deletes children's personal information if collected without parental consent.
  • This evaluation did not assess whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 100%

Is the product intended for school?

  • Intended for students.
Not yet answered
  • This evaluation did not assess whether personal information or education records are collected from preK-12 students.
  • This evaluation did not assess whether intended for teachers.
  • This evaluation did not assess whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • This evaluation did not assess whether the processes to enter education records into the product are clear.
  • This evaluation did not assess whether additional rights or protections may be provided with an additional school contract.
  • This evaluation did not assess whether the company is designated as a school official.
  • This evaluation did not assess whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: NA%

Can I control the use of my data?

    Not yet answered
    • This evaluation did not assess whether users can control the use of their information through privacy settings.
    • This evaluation did not assess whether use of information is limited to the purpose for which it was collected.
    • This evaluation did not assess whether the conext or purpose for which data are collected is indicated.
    • This evaluation did not assess whether company may combine data with additional data from third-party sources.
    • This evaluation did not assess whether this product treats combined information as personally identifiable information (PII).
    • This evaluation did not assess whether notice is provided if the context in which data are collected change.
    • This evaluation did not assess whether consent is obtained if the practices in which data are collected change.
    • This evaluation did not assess whether a grievance or remedy mechanism is available for users to file a complaint.
    • This evaluation did not assess whether users can request to know what personal information has been shared with third parties.
    • This evaluation did not assess 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.

    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.