Privacy Evaluation for Samsung Galaxy Watch
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'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 with which they connect. In addition, the terms state that 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.
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 that 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 that 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.
Samsung's terms state that 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 that 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.
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 immediately. The terms also state users can access, rectify, or delete their personal information through the service at any time. Lastly, Samsung's terms note that 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.
- 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.
- Opt-in consent is requested from users at the time personal information is collected.
- Personal information of users is collected by a third party.
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.
- 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.
- The roles of third-party service providers are indicated.
- Unclear whether this product supports third-party login.
- Contractual limits are placed on third-party data use.
How does it secure data?
- A user's identity is verified with additional personal information.
- Account creation is required.
- 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.
What rights do I have to the data?
- 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.
- A data-retention policy is available.
- Processes for authorized users to delete data are available.
- 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.
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.
- 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.
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.
- Unclear whether personal information can be displayed publicly.
- Unclear whether this product allows users to control how their data are displayed to others.
- User-created content is reviewed, screened, or monitored by the company.
- 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?
- 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.
- User's information is used 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.
Can I provide parental consent?
- Not intended for children under 13.
- Personal information from children under 13 years of age is not collected.
- Unclear whether intended for parents or guardians.
- Company does not 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.
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.
- 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.
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).
- Notice is provided if the context in which data are collected changes.
- Consent is obtained if the practices in which data are collected change.
- A grievance or remedy mechanism is not 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.