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Privacy Evaluation for Actively Learn

Last updated March 8, 2019

Overview

Actively Learn allows teachers to create instructional content and students to create base content that includes rich media in their reading experiences. The terms state they collect only the information required to provide the service. The terms also state they will protect a user's data with administrative, technical, and physical safeguards designed to protect against unauthorized use and disclosure of personal information. Lastly, the terms state that they are in compliance with COPPA and FERPA, and they require verifiable parental consent before a child under 13 can register for the service.

Actively Learn can be accessed through its website. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Actively Learn’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Actively Learn allows teachers to create instructional content and students to create base content that includes rich media in their reading experiences. The terms state this content is available for the student, class, and associated educator. However, a user can choose to share their discussions, notes, questions, feedback or ideas with other individuals.

Privacy

The terms of Actively Learn states that it will not sell, lease, or share PII of students under 18 or children under 13 to third parties for any purpose, except (1) To comply with laws or a legal process such as responding to a subpoena or court order; (2) To exercise legal rights or defend against legal claims. The policy notes that it may share personal information with a teacher’s or student’s current or prior educational institution for authorized educational/school purposes. Actively Learn's policy notes that when an educator or student creates an account on Actively Learn, they collect their name, email address, school, and, depending on the method of signup, a password for accessing their Actively Learn account, and that users also have the option of uploading a profile picture. In addition, the terms state they do not sell or lease student or teacher personal information to third parties for their advertising, marketing, or other non-educational purposes.

Security

The terms of Actively Learn state they will protect a user's data with administrative, technical, and physical safeguards designed to protect against unauthorized use and disclosure of personal information. The terms also state they use 2-factor authentication whenever possible and encrypt all data at rest and in transit between the Actively Learn web application and Actively Learn's servers using TLS/SSL. When their third party subprocessors transfer personal data of EU residents, these services are processors and are bound to also comply with GDPR to protect user data privacy and security.

Compliance

Actively Learn's policy claims that it is in compliance with COPPA and FERPA. The policy notes that the company will make good faith efforts to honor reasonable requests to access or correct personal information if it is inaccurate. In particular, the policy explains that parents can request deletion of their child’s data by sending a request to privacy@activelylearn.com, and that the data will be deleted within 48 hours of confirming the request.

Data Collection
SCORE: 40%

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.
  • Unclear whether this product collects geolocation data.
  • 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 collected online.
Data Sharing
SCORE: 80%

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.
  • Social or federated login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 80%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Account creation is required.
  • Parental controls or managed accounts are available.
  • Two-factor account protection is available.
  • Third-party contractual security protections are required.
  • Industry best practices are used to protect data.
  • Employee or physical access to user information is limited.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 75%

What rights do I have to the data?

  • Opt-in consent is requested from users at the time personal information is collected.
  • Unclear whether 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: 15%

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.
  • Unclear whether 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.
  • Unclear whether user information is 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: 35%

How safe is this product?

  • Users can interact with 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.
  • 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 not 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: 25%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • Behavioral or targeted advertising is not displayed.
  • Unclear whether this product allows data collection by third-party advertising or tracking services.
  • Unclear whether this product uses data 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.
  • Unclear whether this 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: 80%

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.
  • Unclear whether children's privacy is applicable.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • 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: 60%

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.

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.