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Privacy Evaluation for ExploreLearning Gizmos

Last updated May 10, 2021

Overview

ExploreLearning Gizmos is a web-based library of standards-aligned math and science simulations for grades 3-12. The terms state that message boards, lesson plans, and other posting areas are mentioned, but it is unclear in the terms how these areas are accessed or used. The terms state that ExploreLearning does not sell personal information. In addition, the terms state that banking transactions are encrypted throughout the service, but there is no mention of additional encryption for user data in transit or at rest. Lastly, the terms state that ExploreLearning operates in compliance with the Children's Online Privacy Protection Act ("COPPA") and will obtain appropriate parental consent.

ExploreLearning Gizmos can be accessed through its website. It is a predominately HTML5 (some flash) web based platform and there is no mobile app available. The Privacy Policy and Terms of Service used for this evaluation can be found on ExploreLearning Gizmo's’ website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms of ExploreLearning Gizmos do not address social interactions of any kind. The terms state that, except for vendor created content, ExploreLearning does not control and is not responsible for additional materials. Message boards, lesson plans, and other posting areas are mentioned, but it is unclear in the terms how these areas are accessed or used.

Privacy

ExploreLearning Gizmo's terms state that they collect minimal personally identifiable information such as student name full name and identification number, teacher name, class, school name, and grade level. Student demographic data, for the purposes of optional reporting, is requested separately from the initial setup data and is obtained only with written permission from your district. The terms state that ExploreLearning does not sell personal information. Lastly, the terms state that ExploreLearning may use aggregated data for research or product development.

Security

The terms state that banking transactions are encrypted throughout the service, but there is no mention of additional encryption for user data in transit or at rest. In addition, the terms state only ExploreLearning employees who are authorized to handle student data are able to access the Data Management System. According to terms, the user retains control of student data at all times. ExploreLearning’s terms reference good faith efforts to maintain security and notification protocols if a security breach occurs.

Compliance

The terms state that ExploreLearning operates in compliance with the Children's Online Privacy Protection Act ("COPPA"). However, the terms do not discuss how they will obtain parental consent. In addition, the terms implicitly state that under the terms of contracts with schools, ExploreLearning may act as a school official as defined by the Family Educational Rights and Privacy Act. Lastly, the terms state that the teacher and school retain control and ownership of student data and that the data collected will only be used for the purpose of using the site.

Data Collection
SCORE: 40%

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.
  • 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.
  • Unclear whether this product collects any data automatically.
  • Opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is collected by a third party.
Data Sharing
SCORE: 65%

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 not shared for analytics.
  • Data are not shared for research and/or product improvement.
  • Third-party services are used to support the product.
  • Unclear what the roles of third-party service providers are.
  • Unclear whether this product supports third-party login.
  • Contractual limits are not placed on third-party data use.
Data Security
SCORE: 65%

How does it secure data?

  • 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.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether all data are stored in an encrypted format.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 50%

What rights do I have to the data?

  • Users can create or upload content.
  • Users do not 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.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Unclear whether this product deletes data 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: 55%

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.
  • 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 not shared for research and/or product improvement.
  • Contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 5%

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.
  • User-created content is not 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: 30%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Traditional or contextual advertisements are not displayed.
  • Unclear whether this product displays personalised advertising.
  • Unclear whether data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
  • The company cannot 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: 35%

Can I provide parental consent?

  • Not intended for children under 13.
  • Personal information from children under 13 years of age is 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 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: 81%

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.
  • Company is designated as a school official.
  • Unclear whether this product transfers parental consent obligations 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.
  • Company will not 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.
  • 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.