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Privacy Evaluation for Samsung Galaxy Watch

Last updated September 7, 2022

Overview

Samsung Galaxy Watch is wearable tech that can connect with other smart devices and read physical activity by and biometrics from the wearer. Its terms state that it is not specifically intended for children under 13, but that teens may use it if they themselves obtain parental consent. The terms state that they do collect personal information—including geolocation, behavioral, and biometric information—and they do list the categories of personal information collected; other data is also collected automatically. The terms explicitly state that if they learn they've collected personal information from a child under 13 without parental consent, they'll either seek the consent or promptly delete the information.

The terms state that they use third parties to perform services for them. According to the terms, user information may also be collected by third parties, as well as shared with third parties by the service, including for analytics and marketing purposes. The terms also state that service providers are not authorized to use or disclose user information except as necessary to perform services or comply with legal requirements. According to the terms, they may sell personal information by the CCPA definition.

Samsung Galaxy Watch's terms state that personalized ads are shown, and users who opt out will receive generic ads. The terms further state that third-party tracking technologies collect information from users, including tracking across time and across the internet, and profiles of online browsing and app usage by the user are also built. The terms state that they send marketing communications to users, and may also share communications with users about their own or third-parties' promotions. The terms state that users can upload content to the service, and retain intellectual property ownership of that content, but must license it in an unlimited way to the service. The terms also state that users can interact with other users and that the service may screen, filter, or block content from users.

According to the terms, they seek to verify a user's identity with additional personal information, and use two-step authentication, but it is not clear for which services an account is required. It is not clear from the terms what kind of security they use to protect user information, and encryption is also not mentioned. Finally, according to the terms, users in California can request access to or deletion of their personal information, or opt-out of its sale to a third party. The terms also state that users in general can modify their information or delete their accounts, but it is not clear whether deleting an account also completely deletes personal information from the service.

Samsung Galaxy Watch can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms and Conditions used for this evaluation can be found on Samsung Galaxy Watch’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Samsung Ads Privacy Notice. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Samsung Galaxy Watch's terms state that users can interact with and share content with other users, and that the service may screen, filter, or block content from users. It is not clear whether users can interact with trusted users. The terms do not clearly state whether a user's information might be visibly publicly, nor whether social interactions are moderated or logged.

Privacy

The terms state that they do collect personal information—including geolocation, behavioral, and biometric information—and they do list the categories of personal information collected; other data is also collected automatically. According to the terms, they do not limit information collection to what is specifically required for the product. The terms also state that they may collect login information for third-party devices, apps, features, or services. It is not clear from the terms whether they obtain opt-in consent from users any time information is collected.

The terms state that they use third parties to perform services for them. The terms explain that user information may also be collected by third parties, as well as shared with third parties by the service, including for analytics and marketing purposes; the terms also state which categories of information are shared and with which categories of companies. The terms also state that service providers are not authorized to use or disclose user information except as necessary to perform services or comply with legal requirements. According to the terms, they may sell personal information by the CCPA definition. The terms explicitly state that California residents can opt-out from the sale of their personal information, but other users are not addressed.

Samsung Galaxy Watch's terms state that personalized ads are shown, and users who opt out will receive generic ads. The terms further state that third-party tracking technologies collect information from users, including tracking across time and across the internet, and profiles of online browsing and app usage by the user are also built. The terms state that they send marketing communications to users, and may also share communications with users about their own or third-parties' promotions.

Security

According to the terms, they seek to verify a user's identity with additional personal information, and use two-step authentication, but it is not clear for which services an account is required. It is not clear from the terms what kind of security they use to protect user information, and encryption is also not mentioned.

Compliance

Samsung Galaxy Watch's terms state that the service is not specifically intended for children under 13, but that teens may use it if they themselves obtain parental consent. The terms explicitly state that if they learn they've collected personal information from a child under 13 without parental consent, they'll either seek the consent or promptly delete the information. It is not clear from the terms whether the service is meant to be used by students or in educational settings. The terms state that users can upload content to the service, and retain intellectual property ownership of that content, but must license it in an unlimited way to the service. Finally, according to the terms, users in California can request access to or deletion of their personal information, or opt-out of its sale to a third party. The terms also state that users in general can modify their information or delete their accounts, but it is not clear whether deleting an account also completely deletes personal information from the service.

Data Collection
SCORE: 45%

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 not limited to product requirements.
  • Geolocation data are collected.
  • Biometric or health data are collected.
  • Interactions, behaviors, or usage analytics data are collected.
  • 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: 65%

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.
  • 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.
  • Third-party login is supported.
  • 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.
  • 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.
  • Unclear whether this product uses reasonable security practices 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: 25%

What rights do I have to the data?

  • Users can create or upload content.
  • Users retain ownership of their data.
  • Unclear whether this product provides processes to access and review user data.
  • Processes to modify data are available for authorized users.
  • Unclear whether the product provides a data-retention policy.
  • Unclear whether authorzied users can delete data.
  • 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: 10%

Is the data sold?

  • 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.
  • 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: 15%

How safe is this product?

  • Unclear whether this product supports interactions between 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.
  • 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.
  • 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.
  • The company does provide promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
  • Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 60%

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.
  • 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: 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.
  • 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: 50%

Can I control the use of my data?

  • Users can control the use of their information through privacy settings.
  • Use of information is not 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.
  • 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.