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Privacy Evaluation for IXL

Last updated April 10, 2019

Overview

IXL is the one of the world's most popular subscription-based learning sites for K-12. Used by over 7 million students, IXL provides unlimited practice in more than 7,000 topics, covering math, language arts, science, social studies, and Spanish. The terms of IXL do not disclose whether users can interact with trusted or untrusted users on the service or whether a child or student's personal information can be displayed publicly in any way. The terms state IXL will never sell student data to third parties, but the terms do not disclose whether IXL may sell data from school or parent users to third parties. IXL's terms state they will maintain a comprehensive data security program and have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information they collect and to protect against unauthorized access, disclosure, and use. Furthermore, IXL's terms state their collection, use, and sharing of student data is governed by contracts with the school or district and any applicable laws and regulations including the Family Educational Rights and Privacy Act ("FERPA"), the Children's Online Privacy Protection Act ("COPPA") and applicable state laws.

IXL can be accessed through its website, and is available for download at the iOS App Store, the Google Play Store, and the Amazon App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on IXL’s website, iOS App Store, the Google Play Store, and the Amazon App 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 IXL do not disclose whether users can interact with trusted or untrusted users on the service or whether a child or student's personal information can be displayed publicly in any way. The terms state a school may elect to provide user names or identifiers for student users which are not readily identifiable to anyone outside of the school community in substitution of a full student name. In addition, a school may elect to provide a profile name for a child user and selection of a profile avatar. IXL's terms state they recommend that the parent selects a profile name that does not include the real name or identifying characteristics of the child. The parent may also create a "secret word," which functions similar to a password to access the child profile, although it cannot be used to sign in to the IXL service without the parent first signing in to the parent's account using the parent's login credentials. However, parents and teachers should be aware the terms state a child may change his or her profile avatar, secret word, or profile name, but the parent will see these changes through the parent's account dashboard. IXL's terms state the account dashboard ensures that parents have access to, and control of, their child's use of the service.

Privacy

IXL's terms state the type of personal information the service collects may vary depending on the account type. A family account is purchased by or for a parent. A family account typically includes child profiles that can be used by a parent's child at the parent's direction. A classroom account is purchased by or on behalf of a school, such as by a teacher and is a type of school account. A classroom account typically includes a single teacher user and a small number of student users. A site account is purchased by or on behalf of a school or school district. A site account typically includes an unlimited number of teacher users and a set maximum number of student users. In addition, the terms state IXL takes special precautions to collect only as much information as is reasonably necessary for a child to use the service.

The terms of IXL state they may share information with third parties with consent and at the direction of schools and parents. In addition, third party service providers who have access to student data, are contractually bound to uphold privacy and confidentiality terms no less protective than IXL's terms. IXL's terms also state they consider student data to be strictly confidential and in general do not use student data for any purpose other than improving and providing the services to the school or on the school's behalf. The terms state IXL will never sell student data to third parties, but the terms do not disclose whether IXL may sell data from school or parent users to third parties. In addition, the terms state that from time to time, IXL may send periodic promotional or informational e-mails to school or parent users, but IXL does not disclose whether any third-party marketing e-mails may also be sent to school or parent users. Furthermore, the terms specify IXL does not use student data to send marketing communications, and they do not send marketing communications to student or child users. IXL's terms state they do not display any targeted advertising on the service and do not use student data for any targeted or behavioral advertising purposes.

However, the terms state that IXL and their third-party partners may use cookies and tracking technologies for the purpose of displaying advertisements on other websites or online services on their behalf. The terms state IXL works with third-party online advertising networks which use technology to recognize a user's browser or device and to collect information about their visit to IXL in order to provide customized content, advertising, and commercial messages to school, teacher or district administrative users and other non-student users on other websites or services, or on other devices they may use. Parents and teachers should be aware IXL does not build or amass a profile of a K-12 student for any advertising purposes, other than in furtherance of a K-12 school purpose, or as authorized by a parent. Lastly, IXL's terms state they take certain steps designed to avoid using third-party tracking technologies from collecting information from users of child profiles for targeted advertising purposes, by taking steps to disable tracking technologies only once a subscriber to IXL (e.g., the Parent or Teacher) logs into the service.

Security

IXL's terms state they will maintain a comprehensive data security program and have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information they collect and to protect against unauthorized access, disclosure, and use. However, the terms do not disclose whether personal information is protected with encryption while in transit or while at rest. Additionally, the terms state some schools may elect to use a single-sign on (SSO) service like G Suite for Education rather than usernames and passwords to authenticate student access.

The terms state IXL and their employees, affiliates, service providers, or agents involved in the handling, transmittal, and processing of student data will be required to maintain the confidentiality of student data. In addition, the terms state IXL uses physical security measures to guard against unauthorized access to systems where they store personal data. IXL's terms specify they restrict access to personal information to IXL employees, contractors, and agents who need to know that information in order to operate, develop, or improve the services. IXL's terms state employees may be subject to disciplinary action, including termination, if they fail to meet privacy and confidentiality obligations. Lastly, the terms state that if personal information under IXL's control is compromised as a result of a breach of security, they will take reasonable steps to investigate the situation and take all steps required by applicable laws and agreements with any affected schools to provide notification.

Compliance

IXL's terms state that if a user is under eighteen (18) years of age, they may use the service only with the involvement and consent of a parent, legal guardian, or at the direction of their school. The terms state IXL may collect information about a child authorized by their parent to use the service through the parent's account and if IXL is used by a school for an educational purpose, IXL may collect student data that is provided by the school or by a student. The terms of IXL state they may share information collected from users associated with a school with other users or persons designated by the school, such as teachers and school administrators of that school.

Parents or guardians of a student who uses the IXL service through a school must refer all questions and requests regarding access, modification, or deletion of a student's user account or student data to their child's school. IXL's terms state they will respond promptly to all access, modification, and deletion requests it receives from schools. However, IXL is not required to delete student data that has moved to a personal family account on the service. IXL’s terms state they do not retain student data beyond the time period required to support its educational purpose, unless authorized by a school or parent. In addition, the terms state IXL does not delete or de-identify any student data from an active student user account associated with a school except at the direction of the school. The school is responsible for maintaining current student rosters and identifying student data which the school no longer needs for an educational purpose by removing students from the school's master roster or by submitting a deletion request to IXL.

Furthermore, IXL's terms state their collection, use, and sharing of student data is governed by contracts with the school or district and any applicable laws and regulations including the Family Educational Rights and Privacy Act ("FERPA"), the Children's Online Privacy Protection Act ("COPPA") and applicable state laws. IXL's terms state its service is designed to comply with AB 1584 and pupil education records obtained by IXL from a local educational agency ("LEA") continue to be the property of and under the control of the LEA. Lastly, if a school provides the IXL service to children under 13, they must represent and warrant that they have the authority to provide consent on behalf of parents for IXL to collect information from students under 13 before allowing the students to access the service.

Data Collection
SCORE: 50%

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 not collected.
  • Unclear whether this product collects biometric or health data.
  • Behavioral data are collected.
  • 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 collected online.
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.
  • Use of information is limited to the purpose for which it was collected.
  • 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: 60%

How does it secure data?

  • Unclear whether 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: 95%

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 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.
  • Processes to download user data are available.
Data Sold
SCORE: 65%

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.
  • 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.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 25%

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.
  • Profile information is shared for social interactions.
  • Unclear whether this product displays personal information 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: 55%

Are there advertisements or tracking?

  • Unclear whether data are shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • Behavioral or targeted advertising is not displayed.
  • Data are collected by third-party advertising or tracking services.
  • Data are used to track and target advertisements on other third-party websites or services.
  • Data profiles are 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.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 80%

Can I provide parental consent?

  • Intended for children under 13.
  • 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.
  • 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: 70%

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.
  • 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.