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Privacy Evaluation for Apollo

Last updated January 9, 2020

Overview

Apollo by Atlas Learning is an interactive learning platform designed for use in the modern 1:1 classroom. Apollo's privacy policy makes it clear that it is not responsible for ensuring that information uploaded to the service will not be accessible to the public. Although the privacy policy states that Apollo does not share personal information with third parties, it is unclear whether non-personally identifiable information is shared with third parties for marketing purposes. Apollo does not guarantee that it uses reasonable security measures to ensure that data is protected because users assume the risk of a data breach when using the service. It is unclear from the terms of use and the privacy policy whether this product is intended for people under the age of eighteen; however, it is clear from the privacy policy that Apollo intends university students, teachers, and administrators to use the service.

Apollo by Atlas Learning can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Apollo’s website, and the iOS App Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Apollo's terms of use and privacy policy do not indicate whether or not users, both trusted and untrusted, are able to interact with each other through the service. Personal information may be visible on the service. Apollo's privacy policy makes it clear that it is not responsible for ensuring that information uploaded to the service cannot be accessed publicly. Likewise, Apollo has the discretion to remove content that it believes violates its terms of use, but does not guarantee that all such content is removed from the service.

Privacy

Apollo's privacy policy clearly states that the service does not share personal information with third parties. The terms indicate that third party marketing vendors do use the service. It is unclear whether non-personally identifiable information is shared with third party vendors for marketing purposes. The terms of Apollo's service state that personal information is collected to ensure that the service is operating properly, that communications between Apollo and users are properly conveyed, and to create a more tailored and efficient service for individual users. Apollo does not sell personal information that it has collected to third parties. Neither the terms of use nor the privacy policy indicate any specific actions regarding advertising and tracking.

Security

Apollo's privacy policy warns users that they assume the risk of a data breach when using the product. As such, Apollo does not guarantee that it uses reasonable security measures to ensure that data is protected. Apollo also does not indicate whether it notifies users in the event of a data breach. In addition, Apollo states that some data in transit may be unencrypted, and does not clearly indicate whether data at rest is encrypted or not. The terms indicate that an account is required for some features of the service, including features that require payment; however, an account is not required for use of the service. Moreover, the terms clearly state that multiple people cannot share access to a single account, but do not indicate whether user-managed accounts are available for parents or administrators.

Compliance

It is unclear from the terms of use and the privacy policy whether this product is intended for people under the age of eighteen. It is clear from the privacy policy that Apollo intends the product to be used by university students, teachers, and administrators. The terms do not list any method for parents and school administrators to provide consent for the collection of personally identifiable information from children under the age of thirteen. Neither the privacy policy nor the terms of use refer to any of the governing statutes that apply to children, including COPPA and FERPA. It is unclear whether users can access and modify the data they have uploaded to the service. The terms, however, do indicate that user information will be deleted when the user is no longer using the service and wishes to cancel their account.

Data Collection
SCORE: 45%

What data does it collect?

  • Personally identifiable information (PII) is not 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 collected.
  • Biometric or health data are collected.
  • Behavioral data are collected.
  • Sensitive data are collected.
  • Unclear whether this product collects non-personally identifiable information.
  • Unclear whether opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is collected by a third party.
Data Sharing
SCORE: 30%

What data does it share?

  • Collected information is shared with third parties.
  • Unclear whether the categories of information shared with third parties are indicated.
  • Unclear whether the purpose for sharing a user's personal information with third parties is indicated.
  • Unclear whether the categories of third parties that receive personal information are indicated.
  • Unclear whether data are shared for analytics.
  • Unclear whether data are shared for research and/or product improvement.
  • Data are not 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.
Data Security
SCORE: 15%

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.
  • Unclear whether this product uses industry best practices to protect data.
  • Unclear whether this product limits employee or physical access to user information.
  • All data in transit are not 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: 40%

What rights do I have to the data?

  • Users can create or upload content.
  • 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.
  • A data-retention policy is available.
  • Unclear whether the school, parents, or students can delete data.
  • A user's data are deleted upon account cancellation or termination.
  • Unclear whether this product deletes data when no longer necessary.
  • Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
  • Processes to download user data are not available.
Data Sold
SCORE: 5%

Is the data sold?

  • 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.
  • 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.
  • 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: 5%

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.
  • 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.
  • 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: 0%

Are there advertisements or tracking?

  • Unclear whether 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.
  • 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: 30%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is not collected online.
  • 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 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.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 40%

Is the product intended for school?

  • Intended for students.
  • Personal information or education records are not collected from preK-12 students.
  • Intended for teachers.
  • 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.