Privacy Evaluation for Capit
Capit is a fee-based platform that supports the development of reading skills in early learners from pre-Kindergarten to Second Grade. Capit's terms specify that students cannot communicate with each other privately using the application, and that parents or teachers need to create accounts to view the information of students that are affiliated with them. The terms state that Capit collects name, username, about adult users. This information will generally be provided to Capit by the parent or teacher signing up for the service. The terms state that Capit encrypts data in transi, and that their software development process incorporates steps to prevent attacks. Capit's terms clearly state that they only collect information from children under 13 if their parent has signed them up for the service, or if a school or district has implemented the service.
Capit's terms specify that students cannot communicate with each other privately using the application, and that parents or teachers need to create accounts to view the information of students that are affiliated with them. Because this is not a free service, the barrier to entry is higher because people need to provide a credit card or other form of verifiable payment to access the site. The terms state that a parent or guardian, or, if applicable a school or district administrator, can view or remove Children's Personal Information associated with an account.
The terms of Capit state they collect name, username, phone number, and teacher information about users. This information will generally be provided to Capit by the parent or teacher signing up for the service. The policy indicates that they do not collect biometric data, health data, or sensitive personal information. The policy promises that they do not and will not share, rent or sell student information to third parties for marketing or advertising purposes.
The terms specify that users can request deletion of their account, and that they will delete data. The terms also specify that California residents can ask for information about categories of information shared with third parties, and the addresses of those third parties. The terms also specify that third parties supporting Capit can receive Personal Information or Children's Personal Information to the extent that they need this information to support Capit. According to their policy, when they do share Anonymous Information or De-Identified Information about our users with third-parties, we take reasonable measures to ensure that the data is “De-Identified.” The policy indicates that they do not allow third parties to use a child’s/student’s data to create a profile, engage in data enhancement, social advertising, or target advertising to students, parents, teachers, or the school. However, the terms do not list these third parties, their privacy policies, or any contractual limits placed on potential recombination of this information.
The policy notes that passwords are required to log into user accounts. The terms of Capit state they encrypt data in transit, and that their software development process incorporates steps to prevent attacks. However, the terms do not specify whether or not data is encrypted at rest, or any procedural or physical safeguards in place to protect against unauthorized access other than limiting personnel and third party access.
Capit is not a free service and the only way a child can access Capit is if a parent joins the service or if a school or district signs up for the service. Capit's terms clearly state that they only collect information from children under 13 if their parent has signed them up for the service, or if a school or district has implemented the service. The policy explains that they do not allow children/students to create an account or purchase any of our products or services by themselves.
Capit's terms state that information can be updated or deleted, or parental consent can be withdrawn, by contacting Capit. The terms specify how much time will be required to address requests for updates or deletions. The terms also specify that a minor's use of the service will never be conditioned on collecting more information than needed to provide the service.
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 not collected.
- Biometric or health data are not collected.
- Unclear whether this product collects behavioral data.
- Sensitive data are not collected.
- 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.
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.
- 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.
- Unclear whether this product supports social or federated login.
- 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.
- Account creation is required.
- Parental controls or managed accounts are available.
- Unclear whether 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.
- Unclear whether this product encrypts all data at rest.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Unclear whether opt-in consent is requested from users at the time personal information is collected.
- Users can control their information through privacy settings.
- Unclear whether users can create or upload content.
- Unclear whether 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.
- Processes to download user data are available.
Is the data sold?
- Data are not sold or rented to third parties.
- 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.
- 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.
- User information is shared in an anonymous or deidentified format.
- 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.
How safe is this product?
- Users cannot interact with trusted users and/or students.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information is not 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.
- Social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Data are not shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are not displayed.
- Behavioral or targeted advertising is not displayed.
- Data are not collected by third-party advertising or tracking services.
- Data are not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used 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.
- Users can opt out or unsubscribe from marketing communications.
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.
- Children's privacy is applicable.
- COPPA parental consent exceptions are indicated.
- 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.
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.
- Vendor is designated as a school official.
- Parental consent obligations are transferred to the school or district.
- FERPA parental consent exceptions are indicated.
- Unclear whether this product discloses directory information.