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Privacy Evaluation for Vector

Last updated January 17, 2020

Overview

Anki's Vector product is described on their site as a home robot with interactive AI technology. Anki's policy claims that it is not responsible for third-party services or individuals that users may interact with through its services. Anki's policy notes that ads may be displayed to a user based on the user's behavior on the internet (on Anki's websites or other websites), search activity, response to advertisements or emails, pages visited, general location, or other information. Customer data is encrypted between the robot and the cloud, and payment transactions are encrypted in transit, but discussion of what happens in the event of a data breach is missing. There's a COPPA safe harbor certification for other products, but Vector is not listed. When Vector will connect with Amazon Alexa (scheduled for December 2018), it's worth reviewing Amazon's privacy policy as well.

Also, a hands-on basic security assessment of Vector is available here. Vector can be accessed through its website, and is available for download at the iOS App Store, the Google Play Store, and/or Amazon Appstore. The Privacy Policy and Terms of Use used for this evaluation can be found on Vector’s website, iOS App Store, the Google Play Store, and/or Amazon Appstore. Additionally, other policies used for this evaluation include: Cookie Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Anki's policy claims that it is not responsible for third-party services or individuals that users may interact with through its services. They do not regularly review user submissions of content, but reserve the right to remove or edit content a user may submit, including to enforce their terms of use.

Privacy

Anki's policy defines personal information as information about a user that can be used by itself, or combined with other information, to personally identify a user ("Personal Information"). They describe how they collect this information, directly from users when the users provide it to them, and by other means. Their policy also indicates that they use analytics data, either alone or combined with other data, to create aggregated data which does not identify a user personally ("Aggregate Data"). They indicate that they may freely use and share Aggregate Data with their partners, for example, who perform functions on their behalf or help them improve the Services. Also, Anki's policy notes that ads may be displayed to a user based on the user's behavior on the Internet (on Anki's websites or other websites), search activity, response to advertisements or emails, the pages visited, general location, or other information. The policy explains that if a user has, or, for a child under the age of 13 (or up to 16, depending on the country), his or her parent/legal guardian has, given Anki consent by providing us contact information, they may, subject to the users' marketing preferences, send education, marketing, product support, and research emails.

Security

Anki explains in its policy that with third parties that support their business, such as to process payments, provide accounting, or store and/or process information, they are bound to keep personal information confidential and adequately protected and use it only for the purposes for which it was disclosed it to them. Customer data is encrypted between the robot and cloud, and payment transactions are encrypted in transit. Discussion of data breach is missing.

Compliance

Unless they note otherwise (for example, on product packaging), Anki states that its services are intended for audiences of all ages. The policy explains that users can contact Anki to modify, request a copy of, or request deletion of personal information or the entire account. There's a COPPA safe harbor certification for other products, but vector is not listed. FERPA and schools are not covered in the policies. When a child signs up for an Account, the policy explains that Anki will send a notice via email to the child's parent or guardian, or obtain verifiable consent via other acceptable methods. When applicable, the policy notes that parents/legal guardians have the right to consent to Anki's collection and use of personal information from the child without also consenting to its disclosure to independent third parties. The policy allows parents to revoke their consent anytime by contacting the company by email, and they can request modification or deletion of children’s accounts.

Data Collection
SCORE: 60%

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.
  • Behavioral data are collected.
  • Unclear whether this product collects sensitive data.
  • Non-personally identifiable information is collected.
  • Combined information is treated as personally identifiable information (PII).
  • Personal information from children under 13 years of age is collected online.
Data Sharing
SCORE: 70%

What data does it share?

  • Collected information is shared with third parties.
  • Unclear whether 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.
  • 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.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 45%

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.
  • 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.
  • All data in transit are encrypted.
  • Unclear whether this product encrypts all data at rest.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 80%

What rights do I have to the data?

  • Opt-in consent is not 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.
Data Sold
SCORE: 35%

Is the data sold?

  • Unclear whether data are 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.
  • Users are not 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 not shared in an anonymous or deidentified format.
  • Unclear whether the vendor describes their deidentification process of user information.
  • Data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 30%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users and/or students.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information is shared for social interactions.
  • Unclear whether this product displays personal information publicly.
  • Users can control how their data are displayed.
  • User-created content is not reviewed, screened, or monitored by the vendor.
  • Unclear whether user-created content is filtered for personal information before being made publicly visible.
  • Social interactions between users are not moderated.
  • Unclear whether social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 60%

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.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 100%

Can I provide parental consent?

  • Intended for children under 13.
  • 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.
  • COPPA parental consent exceptions are indicated.
  • Parental consent is required.
  • Parental consent is limited 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.
  • Parental consent notice and method for submission are provided.
School Purpose
SCORE: 10%

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.
  • Product is not 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.

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.