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Privacy Evaluation for ExploreLearning Gizmos

Last updated June 6, 2019

Overview

ExploreLearning Gizmos is a web based library of standards aligned math and science simulations for grades 3-12. The terms state 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 and will not use any user data to display contextual or behavioral advertising, will not use the data to track and target advertisements on third party websites, and will not allow third parties to use user data to create ad profiles, perform data enhancement or target ads. 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 not knowingly collect or use personally identifiable information from anyone under 13 years of age.

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 and will not use any user data to display contextual or behavioral advertising, will not use the data to track and target advertisements on third party websites, and will not allow third parties to use user data to create ad profiles, perform data enhancement or target ads. Lastly, the terms state that ExploreLearning may use aggregated data for research, product development, or marketing but there is no marketing directly to students within the platform.

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") and will not knowingly collect or use personally identifiable information from anyone under 13 years of age. However, the terms do not discuss obtaining parental consent. In addition, the terms state that under the terms of contracts with schools, ExploreLearning agrees to 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: 35%

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 behavioral data.
  • Unclear whether this product collects sensitive data.
  • Unclear whether this product collects non-personally identifiable information.
  • 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: 75%

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 not shared for analytics.
  • Data are not shared for research and/or product improvement.
  • Data are shared with third-party service providers.
  • Unclear whether the roles of third-party service providers are indicated.
  • Unclear whether this product supports social or federated 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.
  • Parental controls or managed accounts are available.
  • Unclear whether two-factor account protection is available.
  • Third-party contractual security protections are required.
  • Industry best 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 this product encrypts all data at rest.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 80%

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.
  • Users can create or upload content.
  • Users do not retain ownership of their data.
  • Processes to access and review user data are available.
  • Processes to modify inaccurate data are available.
  • A data-retention policy is available.
  • 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: 55%

Is the data sold?

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

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.
  • User-created content is not 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: 70%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are not displayed.
  • Behavioral or targeted advertising is not displayed.
  • Data are not collected by third-party advertising or tracking services.
  • Data are not used to track and target advertisements on other third-party websites or services.
  • Data profiles are not created and used for data enhancement, and/or targeted advertisements.
  • The vendor cannot send marketing messages.
  • Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
  • Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 25%

Can I provide parental consent?

  • Not intended for children under 13.
  • Unclear whether intended for parents or guardians.
  • Vendor does not have actual knowledge that personal information from users under 13 years of age is collected.
  • Children's privacy is not 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: 65%

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.
  • Product does create education records.
  • Notification of a contract or additional rights is provided.
  • Vendor is designated as a school official.
  • Unclear whether this product transfers parental consent obligations 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.

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.