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Privacy Evaluation for Flocabulary

Last updated August 10, 2020

Overview

Flocabulary provides a library of songs, videos and activities for K-12 online learning and research-based activities to teach content knowledge and build literacy skills. The terms of Flocabulary state they do not provide any social interactions between students or make a student's information visible to the public. The terms specify that schools and districts can use Flocabulary without sharing any personal information from students, or they can choose to set up student accounts and use Flocabulary to track their students' progress. Flocabulary's terms state they utilize industry-standard application hosting providers who agree to perform frequent diagnostics, operating system updates, and network security monitoring. Flocabulary's terms state they do not knowingly collect personal information from children under the age of 16, but do collect personal information from students and teachers in K-12.

Flocabulary can be accessed through its website. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Flocabulary’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 Flocabulary state they do not provide any social interactions between students or make a student's information visible to the public. The terms specify when students have accounts, teachers will be able to assign multiple choice quizzes and other assignments to students in their classes. Students' quiz results and work product are stored so that both the student who took the quiz or completed the assignment and the teacher can review the results.

The terms state for certain types of assignments, teachers can enable multiple students to collaborate to share their work with the class. Lastly, the terms state the student’s username, first, and last name will not be shared with any Flocabulary users other than their teacher and the account manager at their school or district.

Privacy

The terms of Flocabulary state they collect personal information from students and teachers and automatically collect and analyze information from their use of the services and activity on the website. The website is provided for potential users, but only school staff and parents or guardians may become users and create accounts for students. The terms state a website visitor may not register for Flocabulary as a user for a trial, or paid plan, unless they represent a class, school, district, or are a parent or guardian of a learner.

Flocabulary's terms state schools and districts can use the service without sharing any personal information from students, or they can choose to set-up student accounts and use Flocabulary to track their students' progress. In addition, Flocabulary's terms sate they may use aggregated, anonymized and de-identified data to make improvements to Flocabulary, and they may maintain anonymized, aggregated data, including usage data, for analytics purposes. Flocabulary's terms state they do not share any personal information with third parties for advertising, marketing or other purposes, and they do not sell or rent any students' information to any third party for any purpose. Lastly, the terms state there is no third-party advertising on Flocabulary and they do not track users across third party websites, or use targeted advertising.

Security

The terms of Flocabulary state they utilize industry-standard application hosting providers who agree to perform frequent diagnostics, operating system updates, and network security monitoring. Flocabulary's terms state they have industry-standard security policies and procedures in place, and take reasonable measures to protect the confidentiality, security and integrity of personal information collected on their website. This includes the use of encryption to protect sensitive information transmitted online, firewalls and other security technologies to prevent access to the data from unauthorized parties. The terms specify all connections between users and Flocabulary are secured via encryption communication technology (SSL). In addition, the terms state all Flocabulary passwords are salted and hashed using the practices recommended by NIST (National Institute of Standards and Technology).

Flocabulary's terms state their engineering team is committed to creating and maintaining systems to protect a user's personal information. Their terms state only employees who need to access user information in order to perform a specific job (for example, billing or customer service) are granted access to that information. Flocabulary's terms state that partners, including their outside shipping company and their credit card processing company may only use user information to provide specific services. The terms state these companies do not retain, share, store or use personally identifiable information for any secondary purposes beyond filling a user's order. Lastly, the terms state if Flocabulary believes that the security of a user's personal information may have been compromised, they will seek to notify a user as soon as possible.

Compliance

The terms of Flocabulary state they do not knowingly collect personal information from children under the age of 16, but do collect personal information from students and teachers in K-12. The terms state when a school or district purchases Flocabulary, the first step is for teachers or administrators to create classes. Students can only sign up for Flocabulary after the school or district imports student roster information into Flocabulary, or their teacher enters class information and instruct students to create an account with a provided code. Additionally, the terms state students cannot sign-up and create a Flocabulary account unaffiliated with a class or a school-wide district.

When students create a student account on Flocabulary, the terms state they need to enter a code which will associate them with their school and teacher. The terms specify if a student is a child under the age of 16, they must get permission from a parent or legal guardian to use the website. If a child under 16 wishes to sign up for a free trial or subscribe to Flocabulary, the terms state they must obtain parent or legal guardian consent beforehand. The terms specify if Flocabulary learns they have inadvertently collected personal information from a child under 16 without parental consent, they will take the necessary steps to delete it.

Lastly, the terms state a parent, guardian, or student can access, edit, and delete their information or the results of their quizzes at any time if the data has been provided to Flocabulary by their school or district. The terms also state that after a school or district has requested their account termination and subsequent removal of student data, Flocabulary may retain securely stored backups in accordance with their agreements with the school or district, and their data retention policy, after which point all data will be deleted.

Data Collection
SCORE: 60%

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.
  • Geolocation data are collected.
  • Unclear whether this product collects biometric or health data.
  • Behavioral data are collected.
  • Sensitive data are collected.
  • Non-personally identifiable information is collected.
  • 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: 85%

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.
  • The categories of third parties that receive personal information are indicated.
  • Data are shared for analytics.
  • Unclear whether 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.
  • Social or federated login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 85%

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.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 85%

What rights do I have to the data?

  • 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.
  • A data-retention policy is available.
  • Processes for the school, parents, or students to delete data are available.
  • A user's data are deleted upon account cancellation or termination.
  • Unclear whether this product deletes data when no longer necessary.
  • Permissions, roles, or access controls are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 85%

Is the data sold?

  • Data are 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.
  • Users are notified if their information is transferred to a third party.
  • 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.
  • The vendor describes their deidentification process of user information.
  • Unclear whether data are shared for research and/or product improvement.
  • Contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 55%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information is shared for social interactions.
  • Personal information is not displayed publicly.
  • Users can control how their data are displayed.
  • Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
  • 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: 75%

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 can 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.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 85%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected online.
  • 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 applicable.
  • Parental consent is required.
  • Unclear whether this product limits parental consent with respect to third parties.
  • Parents can withdraw consent for the further collection of their child's information.
  • Children's personal information is deleted if collected without parental consent.
  • Parental consent notice and method for submission are provided.
School Purpose
SCORE: 60%

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.
  • Unclear whether this product designates the vendor 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.

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.