Privacy Evaluation for Apollo
28%
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.
Rating
- Personal information is sold or rented to third parties.
- Unclear whether personal information are shared for third-party marketing.
- Unclear whether this product displays personalised advertising.
- Unclear whether data are collected by third-parties for their own purposes.
- Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
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.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are collected.
- Unclear whether this product collects any data automatically.
- 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 data are indicated.
- Unclear whether data are shared for analytics.
- Unclear whether data are shared for research and/or product improvement.
- Third-party services are not used to support the product.
- The roles of third-party service providers are indicated.
- Unclear whether this product supports third-party 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 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.
- Unclear whether this product uses reasonable security 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 all data are stored in an encrypted format.
- 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 data for authorized users.
- A data-retention policy is available.
- Unclear whether authorzied users 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 methods 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?
- Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
- 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 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.
Data Safety
SCORE: 5%
How safe is this product?
- Unclear whether this product supports interactions between 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.
- Unclear whether 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 not reviewed, screened, or monitored by the company.
- 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 personal information are shared for third-party marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Unclear whether this product displays personalised advertising.
- Unclear whether data are collected by third-parties for their own purposes.
- Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
- Unclear whether this company can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
- Unclear whether users can 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.
- Intended for parents or guardians.
- Unclear whether company has actual knowledge that personal information from users under 13 years of age is collected.
- The company does not provide a section, heading, or separate policy for children in their policies.
- Unclear whether parental consent is required before personal information is collected or disclosed.
- 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: 50%
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.
- Processes to enter education records into the product are not 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.
- Unclear whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: 10%
Can I control the use of my data?
- Unclear whether users can control the use of their information through privacy settings.
- Unclear whether 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.