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Privacy Evaluation for iTooch 6th Grade Health

Last updated June 12, 2018

Overview

With more than 1,590 exercises, iTooch 6th Grade - Health is a new and fun way of practicing and learning Health for 6th Graders. The terms of iTooch 6th Grade - Health do not disclose whether social interactions are available between users or whether users can make personal information publicly visible. The terms of iTooch 6th Grade - Health state they may collect personal information through use of the service and non-personal information automatically. The terms of iTooch 6th Grade - Health state they take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Lastly, the terms of iTooch 6th Grade - Health state they respect COPPA and do not collect information such as name, address, telephone number, photographs, video or audio from children under 13 years old.

iTooch 6th Grade - Health can be accessed through its website, and is available for download at the iOS App Store and the Google Play Store. The Privacy Policy used for this evaluation can be found on iTooch 6th Grade - Health’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

The terms of iTooch 6th Grade - Health do not disclose whether social interactions are available between users or whether users can make personal information publicly visible.

iTooch 6th Grade - Health

Privacy

The terms of iTooch 6th Grade - Health state they may collect personal information through use of the service and non-personal information automatically. In addition, the terms state children under 13 have no access to social network features and are not allowed to share their scores or accomplishments with others. If the service shares information with third parties, the terms specify they require third parties to process user information under the same terms as their privacy practices. Lastly, the terms state the service also requires opt-in consent for the sharing of any sensitive personal information, and the service does not display any behavioral ads or contextual ads to users. However, there are additional details provided in the app-store that the application is 100% free and may be ad supported. If users prefer an ad-free experience, they can remove ads at any time through an optional in-app purchase in the app’s parameters.

Security

The terms of iTooch 6th Grade - Health state they take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. In addition, the terms specify that third parties that handle personal information are required to use appropriate confidentiality and security measures.

The terms specify that the service uses storage, processing practices, and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems that store personal data. In addition, the terms specify that the service restricts access to personal information to only employees and contractors who need to know that information in order to process user information. However, the homepage does not use encryption, but it also does not collect any personal information and the service does not disclose whether users are notified in the event of a data breach.

Compliance

The terms of iTooch 6th Grade - Health state they respect COPPA and do not collect information such as name, address, telephone number, photographs, video or audio from children under 13 years old. However, the terms do not disclose whether parental consent is required or the method to obtain parental consent if personal information from children under 13 is collected and used by the service. In addition, the terms state the service can collect only the first name but this information is collected in the app, and the service has no access to it. Lastly, the terms specify that they allow users to access, modify, and delete information provided to the service. However, the terms do not disclose any information about use of the service by students that would create education records under FERPA.

Data Collection
SCORE: 40%

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 not collected.
  • 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: 40%

What data does it share?

  • Collected information is shared with third parties.
  • Unclear whether 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.
  • Unclear whether data are shared for analytics.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether 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 placed on third-party data use.
Data Security
SCORE: 35%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Unclear whether this product requires account creation.
  • Unclear whether 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.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 50%

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.
  • Unclear whether 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.
  • Unclear whether the school, parents, or students can delete data.
  • Processes to delete user data are available.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 10%

Is the data sold?

  • Unclear whether 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.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • Unclear whether user information is shared in an anonymous or deidentified format.
  • Unclear whether the vendor describes their deidentification process of user information.
  • Unclear whether 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: 10%

Are there advertisements or tracking?

  • Unclear whether data are shared for third-party advertising and/or marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Behavioral or targeted advertising is not displayed.
  • Unclear whether this product allows data collection by third-party advertising or tracking services.
  • Unclear whether this product uses data to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
  • Unclear whether this 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.
  • Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 30%

Can I provide parental consent?

  • 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.
  • 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: 0%

Is the product intended for school?

  • Unclear whether 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.
  • Unclear whether the product creates education records.
  • Unclear whether this product provides notification of a contract or additional rights.
  • Unclear whether this product designates the vendor 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.