Privacy Evaluation for Thrively
Thrively is a personalized learning platform that uncovers student's strengths and interests and then helps students find their purpose, build skills, and create personal impact to unleash their full potential. The terms state Thrively may filter information to ensure age appropriateness and may also offer users the ability to post user generated content that is visible publicly to other users. Thrively's terms say they do not sell, rent, trade or share any personal information with third parties for their marketing purposes and they do not send marketing communications to children or students. In addition, the terms state any information collected by Thrively is stored using standard security and encryption procedures and practices that they believe are appropriate to the nature of the information. Lastly, the terms state that when a parent or teacher registers with Thrively they are required to provide their name, email, and provide their child or student’s name, age, and gender.
The terms state Thrively may filter information to ensure age appropriateness and may also offer users the ability to post user generated content that is visible publicly to other users. Public content could include any information a user submits to any area of the service open to other users or the general public. In addition, if a user posts user ratings or reviews, comments related to activities, respond to public surveys, or participate in other social media they should be aware that any personally identifiable information they submit there can be read, collected, or used by other users to send them unsolicited messages.
The terms state the service collects personal information and automatically generated usage information. In addition, Thrively's terms state if it is informed that an account holder is under thirteen (13) years of age, they will only request a user’s first name and last initial, and not other personally identifying information such as email address or mailing address. The terms say Thrively will retain information collected from a child only so long as reasonably necessary to fulfill an activity request or allow the child to continue to participate in the activity.
Thrively's terms say they do not sell, rent, trade or share any personal information with third parties for their marketing purposes and they do not send marketing communications to children or students. Moreover, the terms state Thrively does not advertise or send promotional messages to students and ads are not be displayed on Thrively for any user. However, Thrively's terms do state they collect personal information for third-party tracking purposes and share student data with third parties in a de-identified format to allow Thrively to market products or services to parents through the service.
The terms state any information collected by Thrively is stored using standard security and encryption procedures and practices that they believe are appropriate to the nature of the information. However, the terms do not provide any additional information about how data is protected and do not disclose whether notice is provided in the event of a data breach.
The terms state that when a parent or teacher registers with Thrively they are required to provide their name, email, and provide their child or student’s name, age, and gender. If a user is under 13 years of age, the terms state Thrively will obtain verifiable parental consent in order to collect, use or disclose their personal information. In addition, only a child's teacher or parent may instruct Thrively to activate their account because student accounts must be connected to a teacher or parent account.
Thrively's terms state that at any time, schools and parents can request that to access, modify, and delete any personal information they have collected about a child or student. In addition, the terms state a school or other institution must obtain any necessary permission from each student’s parents. The terms say it is typical for schools to obtain this permission at the beginning of the academic year for all educational software they plan to use.
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.
- Biometric or health data are collected.
- Unclear whether this product collects behavioral data.
- Unclear whether this product collects sensitive data.
- 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 collected online.
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.
- 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.
- 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.
- 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.
- All data at rest are encrypted.
- Unclear whether this product provides notice in the event of a data breach.
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.
- 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.
- Processes to delete user data are available.
- Unclear whether this product provides users the ability to download their data.
Is the data sold?
- Data are not 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.
- 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.
- 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 not 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
Are there advertisements or tracking?
- Data are not shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are not displayed.
- Behavioral or targeted advertising is not 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.
- Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- Unclear whether intended for parents or guardians.
- Vendor does 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.
- Parental consent notice and method for submission are provided.
Is the product intended for school?
- Intended for students.
- Personal information or education records are collected from preK-12 students.
- Intended for teachers.
- Product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Product does create education records.
- Notification of a contract or additional rights is provided.
- Unclear whether this product designates the vendor as a school official.
- Parental consent obligations are transferred to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.