Privacy Evaluation for Capit
85%
Overview
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 and username from 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 transit, 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 can be accessed through its website. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Capit’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
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.
Privacy
The terms of Capit state that 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, they 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.
Security
The policy notes that passwords are required to log into user accounts. The terms of Capit state that 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.
Compliance
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 their 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.
Rating
- Personal information is not sold or rented to third parties.
- Personal information is not shared for third-party marketing.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- User'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.
Data Collection
SCORE: 60%
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 interactions, behaviors, or usage analytics data.
- Sensitive data are not 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.
Data Sharing
SCORE: 70%
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.
- Unclear whether the categories of third parties that receive data are indicated.
- Data are shared for analytics.
- 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.
- Unclear whether this product supports third-party login.
- Contractual limits are placed on third-party data use.
Data Security
SCORE: 70%
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Unclear whether multi-factor account protection is available.
- 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.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- Unclear whether all data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
Data Rights
SCORE: 80%
What rights do I have to the data?
- Unclear whether 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.
- Methods are available to restrict who has access to data.
- Processes to download user data are available.
Data Sold
SCORE: 80%
Is the data sold?
- Personal information is 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 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.
- User information that is shared is shared in an anonymous or de-identified format.
- The company describes their de-identification process of user information.
- 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: 40%
How safe is this product?
- Users cannot interact with trusted users.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information must be not 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.
- Unclear whether 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.
- Unclear whether social interactions between users are moderated.
- Social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 75%
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.
- User'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.
- Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 95%
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.
- 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: 88%
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.
- Additional rights or protections may be provided with an additional school contract.
- Company is designated as a school official.
- Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 60%
Can I control the use of my data?
- 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.
- Company will not 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.
- Users can request to know what personal information has been shared with third parties.
- 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.