Privacy Evaluation for Actively Learn
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 take reasonable measures to protect a user's data and personally identifiable information (PII). 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 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.
The terms of Actively Learn states that the company will not sell any PII, nor share PII with third parties except (1) To provide the Actively Learn services, (2) To comply with laws or a legal process such as responding to a subpoena or court order; (3) To exercise legal rights or defend against legal claims. In addition, the company requires all third-party service providers to comply with Actively Learn’s policies and only use PII to provide services. The terms specifically state they do not display advertisements on the product and do not sell any personal information to third parties for advertising, marketing, or other non-educational purposes. Actively Learn's policy notes that when an educator creates an account on Actively Learn, they may collect their name, email address, school and/or district, classes taught, and the names, grade, email and identifiers of students in their class. When creating a student account, no PII is required.
The terms of Actively Learn state they will protect a user's data with technical safeguards designed to protect against unauthorized use and disclosure of personal information. Terms specify that personal data in storage and all in transit is encrypted using SSL technology, but does not indicate whether other kinds of data are encrypted while in storage. In addition, Actively Learn’s terms state that the company provides notice to users in the event of a data breach.
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, remove, or correct personal information. In particular, the policy explains that parents can request deletion of their child’s data by sending a request to firstname.lastname@example.org if their children’s PII was collected in violation of the policies or COPPA.
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.
- Unclear whether this product collects biometric or health data.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are collected.
- 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.
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.
- Unclear whether the categories of third parties that receive data are indicated.
- Data are shared for analytics.
- Unclear whether 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.
- Contractual limits are placed on third-party data use.
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Unclear whether this product requires account creation.
- 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.
- All data in transit are encrypted.
- All data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Users can create or upload content.
- Unclear whether users 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.
- Processes for authorized users to delete data are available.
- 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.
Is the data sold?
- Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
- Users are notified if their information is transferred to a third party.
- User information can be deleted prior to its transfer to a third party.
- Third-party transfer is contractually required to use the same privacy practices.
- Unclear whether 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.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
How safe is this product?
- Users can interact with 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.
- 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.
- 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?
- Personal information is not shared for third-party marketing.
- Traditional or contextual advertisements are not displayed.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- Users's information is not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for personalised advertisements.
- The company can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected.
- Intended for parents or guardians.
- Company does have 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.
- Parents can 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.
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.
- Processes to enter education records into the product are 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.
- Parental consent obligations are transferred to the school or district.
Can I control the use of my data?
- Unclear whether users can control the use of their information through privacy settings.
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- Unclear whether 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.
- Unclear whether 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.