Privacy Evaluation for Spotlight by Samba TV
43%
Overview
Samba TV is a movie and tv show recommendation service as well as a streaming platform. The terms do state that Samba TV reserves the right to remove or edit user submissions, but further states that Samba TV does not regularly review user content. The Privacy Policy clearly provides that Samba TV collects demographic information such as household income, age bracket, and homeownership, email addresses, IP addresses, device ids, cookies, and advertising IDs. Furthermore, the Privacy Policy discloses that the categories of information shared with third parties include device IDs, advertising IDs, IP addresses, hashed/encrypted versions of email addresses, and other identifiers. The Privacy Policy states Samba TV does subject its users to personalized advertisements both on Samba TV’s services and on other third-party services. The Privacy Policy does not clearly disclose whether Samba TV verifies a user’s identity with additional personal information before a user makes a privacy request. The Privacy Policy provides that Samba TV uses reasonable security measures to protect users’ confidentiality and personal information. The Terms of Service state that individuals under the age of 18 are prohibited from using Samba TV’s services and the Privacy Policy provides that Samba TV does not knowingly collect information from individuals under the age of 16.
Samba TV can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Samba TV’s website, and iOS App Store. Additionally, other policies used for this evaluation include: Cookie Policy and Notice of Right to Opt out of “Sale”. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The Terms of Service state that Samba TV reserves the right to remove or edit user submissions, but further states that Samba TV does not regularly review user content. The terms do not clearly state whether users can report inappropriate content, harassment, or cyberbullying, nor whether users’ personal information may be publicly displayed. The terms do not disclose whether users may interact with trusted or untrusted users.
Privacy
The Privacy Policy discloses that Samba TV collects users’ personal information, geolocation data, behavioral data, and usage data. The Privacy Policy states that Samba TV records the length of time users view content, the use of other websites and apps, and information that apps and websites enable Samba TV to collect, including the content the user views on other applications. The Privacy Policy provides that Samba TV collects information about the Services the user or their household use and how they are used, such as when the user watches a video on a Samba mobile application, visits a third-party website or app that uses Samba TV’s integrated Services, or interacts with Samba TV’s ads and content. The Privacy Policy further states that Samba TV uses Web beacons in their Services or emails to help deliver cookies, count website visits, and determine the effectiveness of email marketing campaigns. The Privacy Policy indicates that Samba TV may share the information it collects from the user with third parties, and that third parties may collect personal information from the user as well. The Privacy Policy discloses that user information is shared with third parties for analytics, to perform services on behalf of Samba TV, for marketing, and for research or product improvement. Although, the terms ensure that “the personal information that we may share will not directly identify you, but may indirectly identify you through, for example, your device or other means.” The Privacy Policy states that Samba TV has, in the past 12 months “disclosed or sold IP addresses, device IDs, advertising IDs, and content and ad exposure data.” The Privacy Policy clearly provides that Samba TV provides “personalized ads both on and off the Services.”
Security
The Privacy Policy provides very little information on Samba TV’s security practices and merely states that “Samba TV takes reasonable and appropriate security measures to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.” The terms do not disclose whether any user information is encrypted, either in transit or in storage. The terms provide nothing on whether user accounts may require two-factor authentication before access, nor whether third parties with access to a user’s information are contractually required to provide the same level of security protections as Samba TV.
Compliance
The terms indicate that users may upload submissions and content through Samba TV services, including text messages, postings to chat rooms, boards, or contests, drawings and concepts. However, The Terms of Service state that Samba TV obtains exclusive ownership to all user submissions “of every kind and nature throughout the universe and shall be entitled to unrestricted use of the submissions for any purpose whatsoever, commercial or otherwise, without compensation to the provider of the submissions.” The Privacy Policy provides that users have the right to access, correct, and delete their personal information, but does not disclose whether an authorized third party may enact the same rights.
The Privacy Policy provides a separate section for Children’s Privacy, and the Terms of Service state that individuals under the age of 18 are prohibited from using Samba TV’s services. The Privacy Policy further states that Samba TV does not collect information from individuals under the age of 16 without parental consent, but fails to address how parents can provide parental consent, whether parents may limit their consent or whether parents may withdraw their consent. The Privacy Policy likewise does not state whether Samba TV deletes personal information of children under the age of 13 if Samba TV learns it collected the information without parental consent.
Rating
- Personal information is sold or rented to third parties.
- Personal information is shared for third-party marketing.
- Personalised advertising is displayed.
- Unclear whether 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.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
Data Collection
SCORE: 30%
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.
- Unclear whether this product collects biometric or health data.
- 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.
- Unclear whether personal information of users is collected by a third party.
Data Sharing
SCORE: 80%
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.
- 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.
- Third-party login is supported.
- Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 10%
How does it secure data?
- Unclear whether 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: 50%
What rights do I have to the data?
- Users can create or upload content.
- Users do not retain ownership of their data.
- Processes to access or review user data are available.
- Processes to modify data are available for authorized users.
- A data-retention policy is available.
- Unclear whether authorzied users can delete data.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Data are deleted 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: 35%
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.
- 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: 10%
How safe is this product?
- Unclear whether this product supports interactions between trusted users.
- Unclear whether 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: 45%
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Personalised advertising is displayed.
- Unclear whether 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.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
- The company can send marketing messages.
- The company does provide promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 40%
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.
- 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.
- 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.
- 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.
School Purpose
SCORE: 13%
Is the product intended for school?
- Not 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: 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.