Privacy Evaluation for Rhithm
63%
Overview
Rhithm develops social-emotional learning and wellness products designed for use in classrooms, healthcare settings, and at home. The policy indicates users are able to interact and share information while using Rhithm's services; additionally, the policy states Rhithm does not monitor user interactions or disputes. The policies specify Rhithm may collect personal data including student data, metadata, user content, name, email address, student ID, assessment data, IP address, and usage data. The policies do not indicate if any personal information is sold or exchanged for anything of value to third parties. The policy confirms Rhithm does not share personal information with third parties for marketing purposes; however, the policy also states personal information may be used to tailor content on the services and on other sites. Furthermore, the policy indicates both Rhithm and third parties may use tracking technologies to collect personal information. The policy states Rhithm employs reasonable technical, physical, and administrative security measures to protect user data, including encryption of data in transit. Finally, the policies confirm Rhithm obtains consent from parents or through school consent for users under the age of 13; furthermore, Rhithm will delete any information if they learn of its collection without parental consent.
Rhithm can be accessed through its website. The Privacy Policy and Terms of Use used for this evaluation can be found on Rhithm’s website. Additionally, other policies used for this evaluation include: Rhithm FERPA Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
SAFETY The policy confirms user information may be visible to the public when users share information with each other or share user content. Additionally, the policy indicates Rhithm does not filter personal data from content before allowing a user to post.
PRIVACY The policy states Rhithm may employ third party service providers to assist in running the business, email services, and customer services. The policy confirms users may access the Rhithm services through a third party platform and that the third party may collect user information as well. The policy states Rhithm may send marketing communications and that users may unsubscribe at any time.
SECURITY The policy indicates student users do not create accounts, but teacher and administrator users are required to register an account. The policy does not indicate if a user's account is protected by multi-factor authentication. The policy does not indicate if all stored data is stored using encryption.
COMPLIANCE The policy confirms users are able to upload content to the service and that users waive any claims of moral rights in respect to user content. The policy states users are able to access or modify data by contacting the school or teacher, or by logging into their account settings. Rhithm’s retention and deletion policies are not clearly explained; the policy indicates users may request deletion of data but also states Rhithm retains archived copies of data.
Rating
- Unclear whether personal information is sold or rented to third parties.
- Personal information is not shared for third-party marketing.
- Personalised advertising is displayed.
- Unclear whether 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.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
Data Collection
SCORE: 30%
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.
- Geolocation data are collected.
- Unclear whether this product collects biometric or health data.
- Unclear whether this product collects interactions, behaviors, or usage analytics data.
- 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 collected by a third party.
Data Sharing
SCORE: 70%
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.
- 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: 40%
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Unclear whether this product requires account creation.
- Unclear whether 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.
- Unclear whether all data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
Data Rights
SCORE: 50%
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 or review user data are available.
- Processes to modify data are available for authorized users.
- Unclear whether the product provides a data-retention policy.
- Processes for authorized users to delete data are available.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Unclear whether 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: 25%
Is the data sold?
- Unclear whether personal information is sold or rented to third parties.
- Unclear whether 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.
- 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.
- 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.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 30%
How safe is this product?
- Users can interact with trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Unclear whether this product allows users to control how their data are displayed to others.
- Unclear whether user-created content is reviewed, screened, or monitored by the company.
- User-created content is not filtered for personal information before being made publicly visible.
- Social interactions between users are not moderated.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 35%
Are there advertisements or tracking?
- Personal information is not shared for third-party marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Personalised advertising is displayed.
- Unclear whether 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.
- Unclear whether this product creates and uses data profiles 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.
Parental Consent
SCORE: 65%
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected.
- 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.
- Unclear whether this product provides parental consent notice and method for submission.
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 not described.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Company is designated as a school official.
- Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 20%
Can I control the use of my data?
- Unclear whether users can control the use of their information through privacy settings.
- Unclear whether 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.
- Combined information is treated as personally identifiable information (PII).
- Unclear whether notice is provided if the context in which data are collected changes.
- Unclear whether consent is 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.
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.