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Privacy Evaluation for Zogo: Finance Simplified

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Overview

Zogo helps users improve their financial literacy and partners with financial institutions that reward users for learning about finance. The terms do not say whether Zogo provides social interactions between users, and Zogo does not say whether personal information may be made publicly visible to others. The terms say that Zogo collects personal information such first name, email address, school, and geolocation information as well as information users submit through responses to survey questions, such as responses to questions about their financial literacy and product and service interests.

The terms do not say whether a user's data can be sold to third parties, and Zogo does not say whether it displays targeted advertisements to users. However, the terms do say Zogo may allow third parties to collect personal information about a user's online activities over time and across different websites, applications, and other online products or services. The terms say Zogo has adopted reasonable safeguards to help protect users' information from loss, misuse, and alteration, but do not specify what safeguards they use. Lastly, the terms say the service is intended for users over the age of 13, and users can delete their account, but the terms do not say how they protect student data privacy when used by students in K-12 schools and districts.

Zogo 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 of Use used for this evaluation can be found on Zogo’s website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Rating

This product received a Warning rating based on the following details:
  • Unclear whether data are sold or rented to third parties.
  • Data are shared for third-party advertising and/or marketing.
  • Unclear whether this product displays behavioral or targeted advertising.
  • 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.
  • Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
Data Collection
SCORE: 45%

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 not collected.
  • Unclear whether this product collects biometric or health data.
  • Behavioral data are collected.
  • 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 not collected online.
Data Sharing
SCORE: 45%

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.
  • Unclear whether 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.
  • Unclear whether 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.
Data Security
SCORE: 20%

How does it secure data?

  • Unclear whether 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.
Data Rights
SCORE: 35%

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.
  • Unclear whether users retain ownership of their data.
  • Unclear whether this product provides processes to access and review user data.
  • Unclear whether this product provides processes to modify inaccurate data.
  • Unclear whether the product provides a data-retention policy.
  • Processes for the school, parents, or students to delete data are available.
  • Unclear whether a user can delete all their data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 15%

Is the data sold?

  • Unclear whether data are 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.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 0%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users and/or students.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information is shared for social interactions.
  • Unclear whether this product displays personal information publicly.
  • Unclear whether this product allows users to control how their data are displayed.
  • Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
  • 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: 20%

Are there advertisements or tracking?

  • Data are shared for third-party advertising and/or marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Unclear whether this product displays behavioral or targeted advertising.
  • 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.
  • Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
  • The vendor can send marketing messages.
  • Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
  • Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 20%

Can I provide parental consent?

  • Not intended for children under 13.
  • Unclear whether intended for parents or guardians.
  • Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
  • Unclear whether children's privacy is applicable.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • Unclear whether this product requires parental consent.
  • 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.
  • 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.
  • 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.