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Privacy Evaluation for Samsung Galaxy Watch

Last updated March 23, 2020

Overview

Samsung Galaxy Watch Active 2 is a smartwatch that incorporates fitness tracking and health-oriented capabilities and integrates with a companion mobile app called "Samsung Galaxy Watch" and "Samsung Health." Samsung's terms state that its services may 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 any social networking service they connect. Also, the terms state Samsung may display targeted ads and sell a user’s personal information to third parties and users can click the Do Not Sell link to request Samsung to stop selling their data. In addition, the terms state Samsung maintains administrative, technical and physical safeguards designed to protect the personal information they obtain through the services 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.

Samsung Galaxy Watch 2 can be accessed through its website, and the companion app is available on the iOS App Store and the Google Play Store. In addition, Samsung Health is available on the iOS App Store and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Samsung's website. 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

Samsung's terms state that its services may 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 any social networking service 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.

Privacy

Samsung's terms say they may collect personal information such as name, email address, postal address and phone number as well as persistent identifiers and location information automatically. Also the terms state Samsung may sell a user’s personal information to third parties and users can click the Do Not Sell link to request Samsung to stop selling their data. 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.

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 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 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 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.

Data Collection
SCORE: 50%

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.
  • Behavioral data are collected.
  • Sensitive data are collected.
  • Non-personally identifiable information is collected.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Personal information from children under 13 years of age is not collected online.
Data Sharing
SCORE: 65%

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 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.
  • Unclear whether this product supports social or federated login.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 25%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is required.
  • Unclear whether parental controls or managed accounts are available.
  • Unclear whether two-factor account protection is available.
  • Unclear whether third-party contractual security protections are required.
  • Industry best 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 this product encrypts all data at rest.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 75%

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.
  • Unclear whether this product provides processes to modify inaccurate data.
  • A data-retention policy is available.
  • Processes for the school, parents, or students to delete data are available.
  • Processes to delete user data are available.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 30%

Is the data sold?

  • 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.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 35%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information is shared for social interactions.
  • Unclear whether this product displays personal information publicly.
  • Unclear whether this product allows users to control how their data are displayed.
  • User-created content is reviewed, screened, or monitored by the vendor.
  • 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: 45%

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.
  • Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 50%

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.
  • 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.
  • 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: 0%

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.

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.