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Privacy Evaluation for Kami

Last updated October 1, 2019

Overview

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 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, the terms state the service does not sell personal information to advertisers or other third parties and no information is used for advertising or tracking purposes. 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, and Acceptable Use Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

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 can 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.

Privacy

The terms state the service 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. 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 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 provide their services, and describe the roles of third party service providers. The terms also state the service does not sell personal information to advertisers or other third parties and no information is used for advertising or tracking purposes. 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.

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, but have obtained security certifications. 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.

Compliance

The terms state the service is only intended for use by people over the age of 13; except for educational use, which comes with an additional COPPA & FERPA student data privacy policy. The terms also state that by using the services, users must be over 13 years of age, or have been granted approved access to the service by their school or parents. 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. Lastly, parents may also refuse to allow the vendor to collect further information from their child.

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 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.
  • Combined information is treated 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: 65%

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.
  • Unclear whether this product limits employee or physical access to user information.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 85%

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.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 65%

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.
  • 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.
  • Contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 60%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users can 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.
  • 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.
  • 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?

  • 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.
  • 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: 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.
  • COPPA parental consent exceptions are indicated.
  • 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.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Parental consent notice and method for submission are provided.
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.
  • Product does create 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.
  • 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.