Privacy Evaluation for Evernote
66%
Overview
Evernote is a productivity platform that providers users with note, tasks, and scheduling capabilities. The privacy policy indicates that Evernote monitors communications between Evernote users and will block delivery of messages or material if it violates Evernote’s Terms of Service or User Guidelines. The Privacy Policy clearly states that Evernote may collect the user's information, including email addresses, billing addresses and other payment information, usage data, location information, IP addresses, and device information. The Region-Specific Privacy Policy aptly discloses the categories of information disclosed to third parties, and the privacy policy does provide methods for users to opt out of certain ad targeting and retargeting services. The Security Overview Policy says that Evernote integrates current security practices and encrypts user data both in transit and in storage. Lastly, the terms disclose that Evernote is not directed to minors, however, that any use by minors should only be done with the guidance, supervision, and consent of their parents, guardians, and/or school officials.
Evernote 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 Service used for this evaluation can be found on Evernote’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Security Overview, Cookie Information, Region Specific Information, User Guidelines, Glossary, and Evernote's 3 Laws of Data Protection. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The Privacy Policy clearly states that there are features of Evernote that allow users to publish and share information publicly, and that users determine whether to post personal or otherwise sensitive information publicly. The terms do not disclose whether Evernote has any system in place for filtering or deleting all personal information from user’s postings before they are made publicly available. The Privacy Policy discloses that Evernote may monitor email communications and will block delivery of communications, or unshare problematic material that violates Evernote’s Terms of Service or User Guidelines.
Privacy
While the Privacy Policy does provide a specific reason as to "why we may collect" information from Evernote's users, the Privacy Policy does not clearly state that the collection of information is limited only to data that are specifically required for the product. The Privacy Policy clearly discloses that Evernote collects usage data, including log Internet and other electronic network information on how the user and others access and use Evernote. However, the terms fail to disclose whether Evernote obtains any method of opt-in consent from a user, before any information is collected. The Privacy Policy specifically indicates that if a user logs-in to Evernote with a third-party account-login platform, i.e., Google Connect, that the third-party account-login platform may have access to all of the user’s data, and furthermore that the third-party account-login platform may share user information with Evernote.
The Privacy Policy discloses that personal information is shared with third party service providers to process services on behalf of Evernote, and furthermore that personal information is shared to third parties for the purposes of analytics, product development, and marketing. However, the Privacy Policy states that Evernote does not share personal information to third parties for their own advertising purposes and that Evernote does not sell personal information. The Privacy Policy fails to disclose whether Evernote will notify users in the event of merger, acquisition, or bankruptcy of Evernote, and whether Evernote will provide users with the right to delete their information in consideration of such an event. While the terms do not state whether users are subject to traditional or contextual advertising, the Privacy Policy discloses that users are subject to targeted advertising.
Security
The Security Overview policy states: "The security team runs an in-house Incident Response (“IR”) program and provides guidance to Evernote employees on how to report suspicious activity. Our security team continually evaluates new tools to increase the coverage and depth of these assessments." Furthermore, the Security Overview policy provides that "We drive a security program that includes the following focus areas: product security, infrastructure controls (physical and logical)." The Privacy Policy discloses that Evernote requires its service providers to agree to strict data protection requirements, to keep up with Evernote’s privacy policy standards and Evernote’s obligations. The Privacy Policy indicates that Evernote will verify a user’s identity with additional personal information before processing a user’s privacy request.
Compliance
The Privacy Policy provides clear instructions on how users and/or an authorized agent can access, modify, or delete personal information. However, the Privacy Policy states that data is stored by Evernote until the user deletes it, and even after deletion, user data may be stored in Evernote's back-up systems for up to one year. The terms disclose that Evernote is not directed to minors, and that Evernote does not knowingly collect personal information from minors, without parental consent. Furthermore, the Privacy Policy states that any use of Evernote by minors should only be done with the guidance, supervision, and consent of their parents, guardians, and/or school personnel. The Privacy Policy does provide that if Evernote learns it has inadvertently obtained children’s personal information without parental consent, that Evernote will promptly delete it.
Rating
- Personal information is not sold or rented to third parties.
- Personal information is shared for third-party marketing.
- Unclear whether this product displays personalised advertising.
- Unclear whether 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 not 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.
- 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.
- Unclear whether personal information of users is collected by a third party.
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.
- 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.
- Third-party login is supported.
- Contractual limits are placed on third-party data use.
Data Security
SCORE: 95%
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.
Data Rights
SCORE: 70%
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.
- Unclear whether the product provides a data-retention policy.
- Processes for authorized users to delete data are available.
- A user's data are not deleted upon account cancellation or termination.
- Unclear whether this product deletes data when no longer necessary.
- Methods are available to restrict who has access to data.
- Processes to download user data are available.
Data Sold
SCORE: 40%
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.
- 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.
- Unclear whether third-party transfers are 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: 50%
How safe is this product?
- Users can interact with trusted users.
- Unclear whether 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 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 moderated.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 45%
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Unclear whether this product displays personalised advertising.
- Unclear whether 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 not 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: 50%
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 not 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.
- 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.
- Children's personal information is deleted if collected without parental consent.
- Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 13%
Is the product intended for school?
- Not intended for students.
- Unclear whether personal information or education records are collected from preK-12 students.
- Unclear whether intended for teachers.
- Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Processes to enter education records into the product are not described.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Unclear whether the company is designated as a school official.
- Unclear whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: 55%
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.
- 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.
- Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
- Users can request to know what personal information has been shared with third parties.
- 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.