Privacy Evaluation for Kami
Overview
Kami allows users to view and annotate documents and PDF files in class. According to the terms of Kami, personally identifiable information is collected from users such as a user's name, email address, and phone number. Additionally, the terms of Kami state that some of this personally identifiable information is shared with third parties but they do not specify what categories of data are shared. The terms of Kami also state that they do not display advertisements of any kind to users of the product. According to the terms of Kami, users can participate in safe interactions while using the product through comments (between students and teachers). However, the terms of Kami do not specify whether or not unsafe interactions are also allowed. Additionally, the terms of Kami state that all data at rest and in transit is encrypted, and users are notified in the event of a data breach. Further, the terms of Kami state that their product is intended to be used by children younger than the age of 13. Lastly, the terms of Kami state that there is a process available to users who wish to access, modify, and/or delete their personal information.
Kami can be accessed through its website, and is available as a Google Chrome Extension. The Privacy Policy and Terms of Servie used for this evaluation can be found on Kami’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
According to the terms of Kami, it is unclear whether or not the company screens or monitors any content that is posted to the service. Additionally, the terms of Kami are unclear as to whether or not the company takes steps to delete personal information from a user's submissions before posting them. Lastly, the terms of Kami do not specify whether or not any incident of harassment or bullying can be reported.
Privacy
According to the terms of Kami, the company limits the collection of personal information to only information that is necessary to run the services. Additionally, the terms of Kami state that a user's physical location is collected when they use the product. The terms of Kami also state that users can log in through a social log-in system such as Google or Microsoft. According to the terms of Kami, personally identifiable information is never sold to third parties. Additionally, the terms of Kami state that, in the case of a merger, bankruptcy, or acquisition, a user's personal information will be transferred to the new company. Lastly, the terms of Kami state that users will be notified if this ever were to happen.
Security
According to the terms of Kami, users must provide their email address and create a password in order to use the services. Additionally, the terms of Kami state that third parties who have access to users' information are required to use the same level of protection when handling that information as Kami does. Lastly, the terms of Kami state that they take reasonable steps to protect the information that they collect such as encryption and firewalls.
Compliance
According to the terms of Kami, a user's account can be terminated if the user is inactive for 12 consecutive months. Additionally, the terms of Kami state their services are intended to be used by children younger than the age of 13. However, the terms of Kami state that it is the responsibility of the school to obtain parental consent before allowing students to use the product. Further, the terms of Kami state that parents can request to have their child's personal information deleted from the product if they suspect that it was collected without obtaining parental consent first.
Rating
- Intended for children under 13.
- Collection or use of data is limited to product requirements.
- Personal information can be not displayed publicly.
- Users can interact with trusted users.
- Notice is provided in the event of a data breach.
- Parental consent is required before personal information is collected or disclosed.
Data Collection
SCORE: 40%
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.
- Unclear whether this product collects interactions, behaviors, or usage analytics data.
- Sensitive data are collected.
- Data is automatically collected.
- Unclear whether opt-in consent is requested from users at the time personal information is collected.
- Unclear whether personal information of users is collected by a third party.
Data Sharing
SCORE: 80%
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.
- The categories of third parties that receive data are indicated.
- Data are shared for analytics.
- Data are shared for research and/or product improvement.
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
- Third-party login is supported.
- Contractual limits are placed on third-party data use.
Data Security
SCORE: 70%
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Unclear whether multi-factor account protection is available.
- Third-parties with access to information are required to provide the same security protections as the company.
- Reasonable security practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
- All data in transit are encrypted.
- All data are stored in an encrypted format.
- 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 or review user data are available.
- Processes to modify data are available for authorized users.
- A data-retention policy is available.
- Processes for authorized users to delete data are available.
- A user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Unclear whether methods are available to restrict who has access to data.
- Processes to download user data are available.
Data Sold
SCORE: 50%
Is the data sold?
- Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
- 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 that is shared is shared in an anonymous or de-identified format.
- Unclear whether the company describes their de-identification process of user information.
- Data are shared for research and/or product improvement.
- Contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 30%
How safe is this product?
- Users can interact with trusted users.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information must be shared for social interactions.
- Personal information can be not displayed publicly.
- Users can control how their data are displayed to others.
- Unclear whether user-created content is reviewed, screened, or monitored by the company.
- 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: 60%
Are there advertisements or tracking?
- Personal information is not shared for third-party marketing.
- Traditional or contextual advertisements are not displayed.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- Users's information is not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for personalised advertisements.
- Unclear whether this company can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
- Unclear whether 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.
- Intended for parents or guardians.
- Company does have actual knowledge that personal information from users under 13 years of age is collected.
- The company does provide a section, heading, or separate policy for children in their policies.
- Parental consent is required before personal information is collected or disclosed.
- Parental consent is limited 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.
- Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 50%
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.
- Processes to enter education records into the product are not described.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Unclear whether the company is designated as a school official.
- Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 40%
Can I control the use of my data?
- Unclear whether users can control the use of their information through privacy settings.
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- Unclear whether company may combine data with additional data from third-party sources.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Notice is provided if the context in which data are collected changes.
- Consent is obtained if the practices in which data are collected change.
- Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
- Unclear whether users can request to know what personal information has been shared with third parties.
- Unclear whether notice is provided in the event the company receives a government or legal request for a user's 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.