Privacy Evaluation for Samsung Bixby
Samsung Bixby is an intelligent personal assistant for Samsung devices that learns what users like and works with their favorite apps. The terms state Samsung Social (formerly named Enhanced Features) is a bundled set of services designed to simplify and improve the ways in which users can share and connect with their friends. To provide the Bixby voice services, some voice commands may be transmitted (along with information about a use's device and its usage, including device identifiers) to a third-party service provider that converts their voice commands to text. In addition, the terms state Samsung maintains administrative, technical and physical safeguards designed to protect the personal information they obtain through the services and the customization service against unlawful or unauthorized destruction, interference, loss, alteration, access, disclosure or use. Lastly, Samsung's terms state children under 13 years of age should not attempt to register for its services or send any personal information about themself to Samsung.
The terms state Samsung Social (formerly named Enhanced Features) is a bundled set of services designed to simplify and improve the ways in which users can share and connect with their friends. With the currently available features for example, users can share their profile and view images from their friends, and easily share files and content with their friends. Some of Samsung's services enable users to communicate with other people and those other users may be able to see information stored or displayed in connection with a user's account on the social networking service with which they connect.
In addition, the terms state any content a user uploads to their public user profile, along with any information or content that they voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by others. The terms state that a user's name may also be displayed to other users if they send messages or comments or upload content, because other users can contact a user through their messages and comments. However, a user's account privacy settings allow them to limit the other users who can see the information in their user profile and/or what information in their user profile is visible to others.
Samsung's terms state users can control their mobile device, and use many of its features, with voice commands with Bixby. For example, Samsung's customization service can improve a user's experience by offering hints and information customized for that user when they use Samsung’s voice recognition service Bixby. To provide the Bixby voice services, some voice commands may be transmitted (along with information about a use's device and its usage, including device identifiers) to a third-party service provider that converts their voice commands to text. In addition, Samsung's terms state they may collect information a user exchanges with Bixby through their interactions with the services, including recordings of their voice commands (such as their questions, requests and instructions), their pictures, and other inputs, and the information they receive from the services (such as responses, answers and content).
The terms state Samsung may combine information from or about a user, including across different services or devices. For example, the terms state that Samsung may use a user’s account details across all of the services that require a Samsung account. In addition, the terms state the service may use a user's personal information to display customized advertisements about products and services that may be of interest to them. Users may opt-out of targeted advertisements, but will continue to receive traditional advertisements which will be based on other information such as generalized location, and other estimated or inferred information. However, the terms do not disclose whether a user’s personal information may be sold to third parties.
The terms state Samsung may use third-party tracking technologies for a variety of purposes, including to analyze the use of their services and (in conjunction with cookies) to provide content and ads that are more relevant to users. Certain third parties may serve advertising or keep track of which advertisements users see, how often they see those advertisements, and what users do in response to them. Lastly, Samsung’s customization service may collect, analyze and share information about a user’s use of the services and online activities, over time and across third-party websites and apps, as well as across devices, to provide them with advertising and direct marketing communications about products and services offered by Samsung and third parties.
Samsung's terms state a number of their services enable users to create accounts or profiles. To use the customization service, a user must first have a Samsung account which requires users to provide certain information about themself to set up the account or profile. In addition, the terms state Samsung maintains administrative, technical and physical safeguards designed to protect the personal information they obtain through the services and the customization service against unlawful or unauthorized destruction, interference, loss, alteration, access, disclosure or use.
The terms state only limited members of the Bixby voice service team in Samsung may access and otherwise process personal data in connection with their job responsibilities or contractual obligations. However, the terms do not disclose whether standard industry security protections like encryption are used to protect personal information in transit or while at rest. Lastly, the terms do not disclose whether notification is provided to users in the event of a data breach.
Samsung's terms state children under 13 years of age should not attempt to register for its services or send any personal information about themself to Samsung. In addition, the terms state Samsung does not knowingly collect or solicit personally identifiable information from children under 13 without parental consent. If Samsung learns that a child under the age of 13 has provided Samsung with personal information they will delete it immediately. The terms also state users can access, rectify, or delete their personal information through the service at any time. Lastly, Samsung's terms state they take reasonable steps to ensure that information about users is available only for so long as is necessary for the purpose for which it is processed.
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.
- Geolocation data are collected.
- Biometric or health data are collected.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is collected.
- Combined information is not treated as personally identifiable information (PII).
- Personal information from children under 13 years of age is not collected online.
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.
- Social or federated login is supported.
- 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.
- Unclear whether parental controls or managed accounts are available.
- 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.
- Unclear whether this product encrypts all data in transit.
- Unclear whether this product encrypts all data at rest.
- Unclear whether this product provides notice in the event of a data breach.
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.
- Unclear whether the school, parents, or students can delete data.
- Processes to delete user data are available.
- Unclear whether this product provides users the ability to download their data.
Is the data sold?
- Unclear whether data are 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.
- Unclear whether 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.
- Unclear whether third-party transfers are 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.
- Contractual limits do not prohibit third parties from reidentifying deidentified information.
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 shared for social interactions.
- Personal information is displayed publicly.
- Users can control how their data are displayed.
- Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
- Unclear whether 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?
- Data are shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are displayed.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for data enhancement, and/or targeted advertisements.
- The vendor can send marketing messages.
- The vendor does provide promotional sweepstakes, contests, or surveys.
- Users can opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Not intended for children under 13.
- Unclear whether intended for parents or guardians.
- Vendor does not have 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.
- Parental consent is required.
- Unclear whether this product limits parental consent with respect to third parties.
- Parents can 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.
Is the product intended for school?
- Unclear whether intended for students.
- Unclear whether personal information or education records are collected from preK-12 students.
- Unclear whether intended for teachers.
- Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Unclear whether the product creates 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.