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Common Sense Privacy Program

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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.

54%

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:
  • Data are sold or rented to third parties.
  • Data are not shared for third-party advertising and/or marketing.
  • Behavioral or targeted advertising is displayed.
  • Data are collected by third-party advertising or tracking services.
  • Data are used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for data enhancement, and/or targeted 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 behavioral data.
  • Unclear whether this product collects sensitive data.
  • Non-personally identifiable information is collected.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Personal information from children under 13 years of age is not collected online.
Data Sharing
SCORE: 80%

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.
  • Use of information is limited to the purpose for which it was collected.
  • 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.
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.
  • Parental controls or managed accounts are available.
  • Unclear whether two-factor account protection is available.
  • Unclear whether 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.
  • Unclear whether this product encrypts all data at rest.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 70%

What rights do I have to the data?

  • Opt-in consent is requested from users at the time personal information is collected.
  • Users can control their information through privacy settings.
  • Unclear whether 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.
  • Unclear whether the product provides a data-retention policy.
  • Processes for the school, parents, or students to delete data are available.
  • Processes to delete user data are available.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 40%

Is the data sold?

  • Data are 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.
  • 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 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.
Data Safety
SCORE: 0%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users and/or students.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information is shared for social interactions.
  • Unclear whether this product displays personal information publicly.
  • Unclear whether this product allows users to control how their data are displayed.
  • Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
  • 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?

  • Data are not shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • Behavioral or targeted advertising is displayed.
  • Data are collected by third-party advertising or tracking services.
  • Data are used to track and target advertisements on other third-party websites or services.
  • Data profiles are 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.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 20%

Can I provide parental consent?

  • Not intended for children under 13.
  • Unclear whether intended for parents or guardians.
  • Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
  • Unclear whether children's privacy is applicable.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • Unclear whether this product requires parental consent.
  • 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: 60%

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.
  • 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.

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.