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Privacy Evaluation for Samsung Bixby

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Overview

Samsung Bixby is the automated voice assistant incorporated in many Samsung electronics. Samsung Bixby does not have its own privacy policy, but instead is referenced in Samsung’s general privacy policy and terms of use. These terms do not clearly state whether users can control how their personal information is shared with other users; whether user generated content is filtered before personal information becomes publicly visible; or whether social interactions of users are logged.The privacy policy indicates that Samsung collects the following types of personal information: (1) contact information such as postal address, email address, payment card information; (2) voice recordings; and (3) location data and precise geolocation. The policy indicates that personal information from these categories and other categories of personal information listed in the terms are shared with third parties. The terms state that information is shared with third party ad networks to deliver customized advertisements on Samsung platforms. The terms do not indicate whether third parties that have access to users’ personal information are required to provide the same security protections as Samsung; whether Samsung limits employee access to user information; whether personal information is encrypted in transit or when stored; or whether Samsung gives notice to the user in the event of data breach. The policies do not clearly state whether Samasung deletes user data when it is no longer necessary; whether user data are deleted upon account termination; or whether there are methods available for users to restrict who has access to their data.

Information about Samsung Bixby can be accessed through its website. The Privacy Policy and Terms of Use. Additionally, other policies used for this evaluation include: Samsung Ads. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms provide that 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. However, a user's account privacy settings may 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.

Privacy

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 may continue to receive traditional advertisements which will be based on other information such as generalized location, and other estimated or inferred information.

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.

Security

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 themselves 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.

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.

Compliance

Samsung's terms state children under 13 years of age should not attempt to register for its services or send any personal information about themselves 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. The terms 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.

Rating

This product received a Warning rating based on the following details:
  • Personal information is sold or rented to third parties.
  • Personal information is shared for third-party marketing.
  • Personalised advertising is displayed.
  • Data are 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.
  • Data profiles are created and used for personalised advertisements.
Data Collection
SCORE: 45%

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.
  • Biometric or health data are collected.
  • Interactions, behaviors, or usage analytics data are collected.
  • Sensitive data are collected.
  • 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: 35%

What data does it share?

  • Collected information is shared with third parties.
  • The categories of information shared with third parties are indicated.
  • Unclear whether 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.
  • Unclear what the roles of third-party service providers are.
  • Unclear whether this product supports third-party login.
  • Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 15%

How does it secure data?

  • 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.
  • Unclear whether this product limits employee or physical access to user information.
  • 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.
Data Rights
SCORE: 30%

What rights do I have to the data?

  • Unclear whether users can create or upload content.
  • Users retain ownership of their data.
  • Processes to access or review user data are available.
  • Unclear whether this product provides processes to modify data 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.
  • Unclear whether this product deletes data 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: 20%

Is the data sold?

  • Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
  • 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.
  • 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: 20%

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.
  • 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
SCORE: 40%

Are there advertisements or tracking?

  • Personal information is shared for third-party marketing.
  • Traditional or contextual advertisements are displayed.
  • Personalised advertising is displayed.
  • Data are 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.
  • 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.
  • Users can opt out of contextual, or personalised advertising.
  • Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 45%

Can I provide parental consent?

  • Not intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • 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 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.
  • 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.
School Purpose
SCORE: 19%

Is the product intended for school?

  • Unclear whether intended for students.
  • Personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • Product is not 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.
  • Unclear whether the company is designated as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: 35%

Can I control the use of my data?

  • 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.
  • Company may combine data with additional data from third-party sources.
  • Unclear whether this product treats combined information 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.
  • 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.