Privacy Evaluation for Snapchat
Snapchat lets you easily talk with friends, view live stories from around the world, and explore news. The terms of Snapchat disclose that social interactions are available between users and any personal information or content may be made publicly visible to others. The terms say that Snapchat does not sell personal information to third parties, but the terms do state that Snapchat and third-party partners may place advertising on the services. Snapchat's terms state they take reasonable steps to protect the confidentiality and security of personal information collected from users of the service, but do not provide any additional information about how they secure personal information. Lastly, Snapchat's terms say they allow users to access, modify, delete, and download their data at any time through the service
The terms of Snapchat disclose that social interactions are available between users and any personal information or content may be made publicly visible to others. Snapchat says users should keep in mind that other users can view their Snaps, Chats, and any other content and can always save that content or copy it outside the app. The terms state that in order to participate in social interactions a user must share information about themselves, such as their username, name, profile picture, and Bitmoji avatar. Users should also be aware Story submissions are set to be viewable by everyone and any content that they submit may be publicly visible to others. A user's content may be viewed and shared by the public at large both on and off Snapchat's services, including through search results, on websites, in apps, and in online and offline broadcasts. Lastly, the terms state that social interactions are logged which include how users communicate with other Snapchatters, such as their names, the time and date of their communications, the number of messages they exchange with their friends, which friends they exchange messages with the most, and their interactions with messages (such as when they open a message or capture a screenshot).
Snapchat's terms say they may use tracking technologies to collect information when a user interacts with offers through one of their partners, such as advertising and marketing features. For example, Snapchat may use information collected on other websites to show a user more targeted ads on Snapchat. Lastly, Snapchat's terms state third-party advertising partners may use tracking cookies to build a profile of a user's interests and deliver relevant advertising on other third-party sites across the internet.
Snapchat's terms state they take reasonable steps to protect the confidentiality and security of personal information collected from users of the service, but do not provide any additional information about how they secure personal information. In addition, Snapchat's terms do not disclose whether they use encryption to protect personal information collected by the service and do not disclose whether they provide notification to users in the event of a data breach.
Snapchat's terms say they allow users to access, modify, delete, and download their data at any time through the service. Snapchat's terms also state no one under 13 is allowed to create an account and the services are not intended for—and Snapchat does not direct them to—anyone under 13. However, a general audience product like Snapchat may be considered directed to children if the product would appeal to children under 13 years of age, which takes several factors into consideration such as: the subject matter, visual content, the use of animated characters or child-oriented activities and incentives, music or other audio content, the age of models, the presence of child celebrities or celebrities who appeal to children, language or other characteristics of the product, or whether advertising promoting or appearing on the product is directed at children. Therefore, a general audience application or service that collects personal information from users to chat with friends with animated cartoon characters and images would likely be a child-directed product.
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.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is 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 personal information are indicated.
- Unclear whether 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.
- Unclear whether 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 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.
What rights do I have to the data?
- 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.
- Processes for the school, parents, or students to delete data are available.
- A user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Permissions, roles, or access controls are available to restrict who has access to data.
- Processes to download user data are available.
Is the data sold?
- Data are not 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.
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.
- Profile information is shared for social interactions.
- Personal information is displayed publicly.
- Users can 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.
- 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.
- Unclear whether this product provides users the ability to 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 online.
- 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.
- 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.
- Unclear whether this product deletes children's personal information 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.