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Privacy Evaluation for EDpuzzle

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Overview

Edpuzzle is a platform that helps teachers engage with their students through video learning. The Privacy Policy states that teacher profiles are publicly viewable through Edpuzzle's search engine, however, that student profiles are not visible to the general public. The Privacy Policy provides that Edpuzzle collects personal information including first and last names, email addresses, unique usernames, passwords, a unique code provided by a teacher in order to join a class, and a profile photo. While the Privacy Policy states that personal information is shared with third parties, the terms fail to state what information is shared. The Privacy Policy states that users’ information is encrypted in transit, but states that only users’ passwords are encrypted for information in storage. The terms clearly and unambiguously designate schools as the responsible party for obtaining parental consent, and/or determining whether a FERPA exception exists, before a student under the age of 13 can use Edpuzzle and have their information collected by Edpuzzle.

Edpuzzle can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Edpuzzle’s website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms do not clearly indicate if certain user information is required to be shared or revealed in order to participate in social interactions. However, the Privacy Policy states that teacher profiles may be viewed by other teachers in the same school, or when searching for the teacher’s profile through Edpuzzle’s search engine. The Terms of Service clearly indicate that users may interact with both trusted users and untrusted users because “Edpuzzle cannot guarantee the identity of any other users with whom you may interact.” The terms do not disclose whether Edpuzzle reviews, screens, or monitors user-created content, takes reasonable measures to delete personal information from a user’s posting before they are made publicly available, or whether social interactions may be moderated or logged for review. The terms do not disclose whether users can report inappropriate content, harassment, or cyberbullying.

Privacy

The Privacy Policy clearly discloses that Edpuzzle collects behavioral data in the form of the frequency and duration of site visits, teachers’ precise geolocation information, and usage data including students’ viewing history, quiz responses, browser type, IP addresses, and device information. The Privacy Policy provides that the collection and purpose of personal information is limited to only data that are specifically required for the product and providing the product’s services. The Privacy Policy indicates that third parties are unable to collect users’ personal information, unless the user directly provides a third party with their personal information.

The Privacy Policy clearly indicates that Edpuzzle shares personal information with third parties for analytics, research, marketing, and to support Edpuzzle. Also, the Privacy Policy indicates that third-party log-in is available, including through an educational institution’s learning management system, and that Edpuzzle collects information from third party log-in platforms. Furthermore, the Privacy Policy says that Edpuzzle does not sell users’ personal information. However, the Privacy Policy indicates that teachers and parents may be subject to direct marketing and advertising. The Privacy Policy does not disclose whether users are able to opt-out of any advertising or marketing communications.

Security

The Privacy Policy clearly indicates that users’ personal information is protected with reasonable security, including physical access controls to limit employee access to user information. The Privacy Policy indicates that an account is required to use Edpuzzle and that Edpuzzle provides schools and teachers with managed accounts to control students’ use of Edpuzzle and to control students’ personal information. The Privacy Policy provides that Edpuzzle verifies the user’s identity with additional personal information when the user makes a privacy request. The Privacy Policy does not clearly indicate whether the security of a user’s account is protected by multi-factor authentication. The Privacy Policy states that in the event of a data breach, affected users will be notified “no later than forty-height [sic] (48) hours of such discovery.”

Compliance

The terms clearly indicate that users can create “User Submissions” on Edpuzzle, and that users retain all ownership rights for their content, granting Edpuzzle a limited, narrow license over the content. The terms disclose that authorized individuals, including current employees of an educational institution, are granted access to review, modify, and delete users’ information. The Privacy Policy provides that Edpuzzle automatically deletes inactive accounts and the user’s information after 18 months of inactivity, and that users can receive a copy of their information in a portable format. The Privacy Policy provides that users can control with whom they share information.

The terms fail to state whether Edpuzzle knowingly collects personal information from children under the age of 13 and furthermore fails to include a section designated for children’s privacy. The terms do not clearly indicate whether a parent can consent to the collection and use of their child’s personal information without also consenting to the disclosure of the information to third parties. The Privacy Policy discloses that if Edpuzzle discovers it has “collected information form a child in a manner inconsistent with COPPA, FERPA, GDPR, or any other applicable laws or regulations,” that Edpuzzle will take appropriate steps to delete the information.

Rating

This product received a Pass rating based on the following details:
  • Intended for children under 13.
  • Collection or use of data is limited to product requirements.
  • Personal information can be displayed publicly.
  • Users can interact with trusted users.
  • Notice is provided in the event of a data breach.
  • Parental consent is required before personal information is collected or disclosed.
Data Collection
SCORE: 50%

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.
  • Unclear whether this product collects sensitive data.
  • Data is automatically collected.
  • Unclear whether opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is not collected by a third party.
Data Sharing
SCORE: 90%

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.
  • Third-party login is supported.
  • 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: 95%

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.
Data Sold
SCORE: 70%

Is the data sold?

  • Personal information is not sold or rented to third parties.
  • Unclear whether 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 not 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: 30%

How safe is this product?

  • Users can interact with trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information must be shared for social interactions.
  • Personal information can be displayed publicly.
  • Users can 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.
  • Unclear whether social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 60%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Traditional or contextual advertisements are 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.
  • Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 50%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Not 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.
  • 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 not provided.
School Purpose
SCORE: 75%

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.
  • Unclear whether the company is designated as a school official.
  • Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 55%

Can I control the use of my data?

  • Unclear whether 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.
  • Combined information is treated 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.
  • A grievance or remedy mechanism is not 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.