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.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is 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 personal information are indicated.
- 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?
- A user's identity is verified with additional personal information.
- Account creation is required.
- Parental controls or managed accounts are available.
- 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.
- All data at rest are encrypted.
- 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 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.
- A user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Permissions, roles, or access controls are available to restrict who has access to data.
- 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.
- Unclear whether 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 can interact with trusted users and/or students.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
- Personal information is displayed publicly.
- Users can 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.
- 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?
- 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.
- Personal information from children under 13 years of age is collected online.
- 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.
- Parental consent is required.
- 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.
- 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.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.