Privacy Evaluation for ClassFlow
ClassFlow describes its service as providing lesson-building tools for teachers and schools that enable creating rich and interactive content for students. The terms state the Service encourages users to avoid including personal information in user submissions and teachers should talk with their students about not including personal information. In addition, the terms state the Service does not share, sell, rent, trade, or disclose personal information about students, teachers, administrators, and parents to third parties for marketing or advertising purposes. Lastly, ClassFlow's terms state they require express consent from a parent or guardian to disclose personal information to the vendor, however, an individual teacher, school, or district is solely responsible for obtaining parental consent.
The terms of ClassFlow state they encourage users to avoid including personal information in user submissions and teachers should talk with their students about not including personal information in any content. However, the terms state the Service does not monitor, review, or exercise control over a user’s submissions. In addition, the terms state a teacher has the option to participate in the ClassFlow community marketplace which gives access to lessons and materials shared by other users. Lastly, the terms specify teachers can engage in forum discussions with other teachers and upload content that is either private or public.
ClassFlow's terms specify they collect and process only a user's information that is necessary for the purposes of providing the Service, but any information collected does not contain sensitive information. In addition, the terms state the Service does not share, sell, rent, trade, or disclose personal information about students, teachers, administrators, and parents to third parties for marketing or advertising purposes. However, the terms state the Service does use third party service providers to help provide the service, enhance the service, increase the service’s functionality, and improve a user’s experience with the service.
ClassFlow's terms state they take reasonable precautions to maintain the security and integrity of a user’s personal information that it collects. Once the vendor receives a user’s information they use procedures and security features to try and prevent unauthorized access. Lastly, the terms state the Service uses industry standard SSL encryption to transfer sensitive and personal information, and stores a user’s information on a secure server behind multiple firewalls.
ClassFlow's terms state they require express consent from a parent or guardian to disclose personal information to the vendor. The terms state that if the vendor learns they have collected personal information from a student under the age of 18 without parental consent, they will take reasonable steps to destroy the information securely and as as quickly as possible.
In addition, if ClassFlow is contacted by an authorized user such as a teacher, student, or the parent or guardian of a student to request deletion of personal information, the terms state the vendor will notify the school which has 30 days to respond to the request. However, the terms specify that an individual teacher, school, or district is solely responsible for complying with obligations of COPPA, FERPA, and obtaining written permission from a parent or guardian.
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.
- Opt-in consent is requested from users at the time personal information is collected.
- Personal information of users is collected by a third party.
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.
- 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.
How does it secure data?
- A user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- 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.
- 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.
- 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.
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.
- Unclear whether 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.
How safe is this product?
- Users can interact with trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Users can 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.
- Social interactions between users are not 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.
- 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.
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.
- Unclear whether this product allows parents to 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.
- 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.
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.
- 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).
- Notice is provided if the context in which data are collected changes.
- 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.