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Privacy Evaluation for Knewton

Last updated

Overview

Knewton puts achievement within reach for students with adaptive technologies and products that deliver personalized and lasting learning experiences. The terms say that interactions among users of the product may be permitted, but users are responsible for those interactions. In addition, Knewton's terms say they limit their collection of direct identifiers and usage data to only what is necessary for the product. However, the terms do not say whether Knewton may sell a user's data to third parties or whether targeted advertisements are displayed. The terms do say that third parties must protect the privacy and security of personal information shared with them or collected by them. Lastly, the terms state that the product is not meant to be used by children under 13 years of age, and the vendor will delete any child personal information if it has been inadvertently collected. Knewton's terms say that users less than 18 years of age must first seek the consent of their parent or guardian prior to submitting any personal information.

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

Rating

This product received a Warning rating based on the following details:
  • Unclear whether personal information is sold or rented to third parties.
  • Personal information is shared for third-party marketing.
  • Personalised advertising is displayed.
  • Data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for personalised advertisements.
Data Collection
SCORE: 50%

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 collected.
  • Unclear whether this product collects biometric or health data.
  • Interactions, behaviors, or usage analytics data are collected.
  • Sensitive data are collected.
  • Data is automatically collected.
  • Opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is collected by a third party.
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.
  • The categories of third parties that receive data are indicated.
  • Data are shared for analytics.
  • Unclear whether 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: 45%

How does it secure data?

  • 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.
  • Unclear whether 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.
  • Employee or physical access to user information is limited.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether all data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 70%

What rights do I have to the data?

  • Users can create or upload content.
  • Unclear whether 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 to delete data are not 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: 25%

Is the data sold?

  • Unclear whether personal information is 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.
  • 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.
  • 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.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether 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.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information must be shared for social interactions.
  • Personal information can be displayed publicly.
  • Unclear whether this product allows users to control how their data are displayed to others.
  • User-created content is not 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: 35%

Are there advertisements or tracking?

  • Personal information is shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Personalised advertising is displayed.
  • Data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for personalised advertisements.
  • The 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.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 35%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Unclear whether intended for parents or guardians.
  • Unclear whether company has actual knowledge that personal information from users under 13 years of age is collected.
  • The company does not provide a section, heading, or separate policy for children in their policies.
  • Parental consent is required before personal information is collected or disclosed.
  • 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.
  • 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: 75%

Is the product intended for school?

  • Unclear whether 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 described.
  • Additional rights or protections may be provided with an additional school contract.
  • 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?

  • 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).
  • Unclear whether notice is provided if the context in which data are collected changes.
  • Unclear whether consent is obtained if the practices in which data are collected change.
  • 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.