Common Sense Privacy Program

thumbnail

Privacy Evaluation for Watermark (formerly EvaluationKIT)

Last updated
Applications and services with a Warning rating do not meet our recommendations for privacy and security practices. Applications and services with a Warning rating have issues narrowly focused around data use related to creating profiles that are not associated with any educational purpose, selling data, and/or using data to target advertisements.

57%

Warning

Learn how we rate

Overview

EvaluationKit is an online course evaluation and survey service. EvaluationKit's terms do not disclose whether they provide any social interaction services between users or otherwise make a user's personal information visible to the public. The terms require schools to be responsible for all decisions related to the collection of personally identifiable information of students who respond to course evaluations, surveys, or other types of data collection. The terms state EvaluationKit uses physical, electronic, and procedural safeguards to protect users' personal information. Lastly, the terms state EvaluationKit is not available to individuals under the age of 18 and the service does not target children under 13, and educational institutions should not knowingly collect personally identifiable information from children under 13 years of age.

EvaluationKit 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 EvaluationKit’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

EvaluationKit's terms do not disclose whether they provide any social interaction services between users or otherwise make a user's personal information visible to the public.

Privacy

The terms specify that EvaluationKit is committed to protecting the privacy and confidential information of its users. The terms require schools to be responsible for all decisions related to the collection of personally identifiable information of students who respond to course evaluations, surveys, or other types of data collection. EvaluationKit agrees not to disclose any of a user’s confidential information collected from the school to any third parties other than to their employees and consultants. Lastly, the terms state that EvaluationKit does not sell personal information to third parties, but the terms are not clear whether use personal information for third-party marketing or behavioral advertising.

Security

The terms state EvaluationKit uses physical, electronic, and procedural safeguards to protect users' personal information. The terms also state a user account is required to access the service, and then for users to access surveys and content. In addition, in order to access the system, an educational institution must create student accounts in EvaluationKit, which contains student personal information that includes: first and last name, username, e-mail address, and which courses a user is enrolled in. The terms state they use encryption to protect user information, but do not disclose whether users are notified in the event of a data breach.

Compliance

The terms state EvaluationKit is not available to individuals under the age of 18 and the service does not target children under 13, and educational institutions should not knowingly collect personally identifiable information from children under 13 years of age. EvaluationKIT's terms state users have the right to access, modify, and delete their personal information. EvaluationKIT will not make available or distribute any student information in violation of FERPA, and student information is considered to be confidential information in the terms. The terms state EvaluationKit will only share student information with the educational institution which is linked to the student's use of the services.

In addition, the privacy policy does not govern the collection, use, or disclosure of personal information through the service by the educational institution which has given students access to the EvaluationKIT service, or which is providing a course evaluation or survey a student is taking via the services. EvaluationKit recommends students contact their educational institution to better understand its specific privacy practices.

Rating

This product received a Warning rating based on the following details:
  • Personal information is sold or rented to third parties.
  • Personal information is not shared for third-party marketing.
  • Personalised advertising is displayed.
  • Data are collected by third-parties for their own purposes.
  • User's information is used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for personalised advertisements.
Data Collection
SCORE: 30%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Unclear whether the collection or use of data is limited to product requirements.
  • Unclear whether this product collects geolocation data.
  • Unclear whether this product collects biometric or health data.
  • Unclear whether this product collects interactions, behaviors, or usage analytics data.
  • Unclear whether this product collects sensitive data.
  • Data is automatically collected.
  • 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: 50%

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.
  • Unclear whether 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.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 50%

What rights do I have to the data?

  • Unclear whether 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.
  • Unclear whether the product provides a data-retention policy.
  • Processes for authorized users to delete data are available.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Unclear whether methods are available to restrict who has access to data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 40%

Is the data sold?

  • Personal information is sold or rented to third parties.
  • Users can opt out from the disclosure or sale of their data to a third party.
  • Unclear whether user information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
  • Unclear whether users are notified if their information is transferred to a third party.
  • Unclear whether 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.
Data Safety
SCORE: 0%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information must be 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.
  • 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 displayed.
  • Data are collected by third-parties for their own purposes.
  • User's information is used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for personalised advertisements.
  • The company can send marketing messages.
  • Unclear whether this company provides promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 30%

Can I provide parental consent?

  • Not intended for children under 13.
  • Personal information from children under 13 years of age is not collected.
  • Unclear whether 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 not provide a section, heading, or separate policy for children in their policies.
  • Unclear whether 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.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 75%

Is the product intended for school?

  • Intended for students.
  • Personal information or education records are collected from preK-12 students.
  • Unclear whether 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: 40%

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).
  • 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.
  • 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.

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.

Learn more about the SPR Read the report

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.