Full privacy evaluation | See all
Updated May 24, 2019


  • Privacy polices do indicate a version or effective date.
  • Data are not sold or rented to third parties.
  • Data are shared for advertising or marketing.
  • Unclear whether this product displays behavioral or contextual advertising.
  • 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.
  • Third parties cannot use data to create ad profiles, data enhancement, and/or targeted advertisements.
The criteria for "Use with Caution" are narrowly focused around data uses related to creating profiles that aren't related to any educational purpose, and using data to target ads. We include both first party (ie, the vendor that builds the service) and third party (any company given access by the vendor) data use. It's worth highlighting that using data to profile students violates multiple state laws, and in some cases also violates federal law.

A service can be designated "Use with Caution" for either a lack of transparency around data use -- which creates the potential for profiling and behavioral targeting -- or for clearly stating that they use data to target advertisements and/or create profiles. As with any application being considered for use within schools, school and/or district staff should review the privacy policies and terms of service to ensure that they meet the legal and practical requirements of their state laws and school policies.

As with the "Not Recommended" criteria, a "Use with Caution" designation is NOT a sign that a vendor is necessarily doing anything unethical or illegal. It is a sign that, based on publicly available policies,  we do not have adequate guarantees that data will not be used by first or third parties to create non-educational profiles or to target behavioral ads.
Use with Caution
Full evaluation
Overall Scoreinfo-bubble

This overall score represents how the service addressed all our evaluation questions. A higher score (up to 100) means the service provides more transparent and comprehensive policies.


Kami allows users to view and annotate documents and PDF files in class. The terms state that students can share their profiles, which include user names and email addresses, within their school, along with sharing user content. The vendor does not monitor or moderate uploaded or shared content. The terms state that the service collects personal information only for the purposes of offering the service and for the educational purposes originally intended. In addition, information is shared with third parties only to support the vendor's services, and third parties are required to adhere to the same privacy and security policies as the vendor and must not share information with other parties. The terms state that both data at rest and in transit is encrypted, and the service takes reasonable security precautions to keep user information safe. Lastly, the terms state that verifiable parental consent is required for students to use the product, users retain ownership of their user submissions, and users can access, modify, or delete their personal information.

Kami can be accessed through its website, and is also available as a Google Chrome Extension. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Kami’s website. Additionally, other policies used for this evaluation include: COPPA Privacy Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Read the Common Sense standard privacy report (SPR)arrow
The standard privacy report (SPR) displays the most important privacy practices from a product’s polices in a single easy-to-read outline. The report displays an alert when a particular privacy practice is risky, unclear, or not evaluated. This alert indicates more time should be focused on these particular details prior to use.
SafetyPromoting responsible use
Evaluating safety takes into consideration best practices that protect a user's physical and emotional health. A higher score (up to 100) means the service provides more transparent and comprehensive responses related to safety.

The terms state that students can only share their profiles within their classroom or school. Teachers and students can both annotate documents and share them with each other, as well as attach audio or video to the content. User profiles display user names and email addresses to other users. The vendor reserves the right to review conduct and content, but they have no obligation to do so, and do not claim responsibility for the content shared in the service.

PrivacyProtecting collected information
Evaluating privacy takes into consideration best practices that protect the disclosure of a user's personal information. A higher score (up to 100) means the service provides more transparent and comprehensive responses related to privacy.

The terms include a separate privacy policy relating specifically to COPPA. Users are notified if there are any material changes to the policies, but there is no review period; continued use of the product means acceptance of the new terms. The vendor collects personal information such as name and email address, and depending on the type of account, also collects physical address, payment information, and name of school. The terms state the service only uses personal information for the purpose of providing the service to users and for the use and benefit of the learning environment. In addition, the product automatically collects information such as IP address, browser, internet provider, referring web pages, operating system, location information (depending on user settings), and more, but the vendor doesn't link that data to other information they collect.

The terms state the service shares personal information with third parties only to perform tasks on the vendor's behalf, and the third parties must adhere to the same privacy policy. Any personal information collected from a child may be disclosed to the parent or teacher who originally registered the child. The terms state the service uses third parties to promote their services, but the terms are not clear about what kind of promotion that is. The terms state the service does not sell information to advertisers or other third parties. However, the terms do not state clearly whether or not the product contains advertising. Third parties with whom information is shared are contractually obligated to not share information with other parties. Lastly, users can upload content to the product, including documents, audio, and video, and may comment on or annotate documents shared with them.

SecurityProtecting against unauthorized access
Evaluating security takes into consideration best practices that protect the integrity and confidentiality of a user's data. A higher score (up to 100) means the service provides more transparent and comprehensive responses related to security.

The terms state that accounts are required in order to use the product. The vendor uses reasonable security, including having a team that works to keep information secure and avoid unauthorized access. Information is encrypted, both at rest and in transit. Data is stored on the Google Cloud Platform, outside the control of the vendor. However, the terms do not mention what action the vendor takes in the event of a data breach. Third parties with whom the vendor shares information are required to use at least the same level of security as the vendor. Lastly, the vendor takes steps to verify any teacher or parent identity before allowing access to a child's personal information.

ComplianceFollowing statutory laws and regulations
Evaluating compliance takes into consideration best practices of companies that collect personal information from children or students and the legal obligations for the privacy and security of that information. A higher score (up to 100) means the service provides more transparent and comprehensive responses related to compliance.

The terms are generally worded to indicate that the product is meant to be used by children and students under 13, but the Terms of Service state that the service is only intended for use by people over the age of 13. Other intended users of the product include teachers, K-12 students, and parents. Teachers and parents are able to create accounts for children. Information is collected from students when their school or teacher has an agreement with the vendor, and the information is used for learning purposes. In addition, information is only collected from children or students when verifiable parental consent has been obtained, which the terms state is the school's responsibility to obtain; proof of consent must be shown to the vendor if requested. The terms clearly state that user submissions are the property of the user, and the vendor doesn't claim any rights except those that allow them to offer their services. The vendor allows authorized individuals access to user information to review student data, modify information, or delete information or user accounts. User information is also deleted when users delete their accounts, unless the vendor is required to comply with legal obligations. Parents may also refuse to allow the vendor to collect further information from their child.

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 streamline making an informed decision about the potential privacy implications of educational technology used to support teaching and learning.

Our core evaluation criteria are freely available and will remain freely available. People are encouraged to read the questions we use and the information security primer we released. 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.