Privacy Evaluation for Knewton
54%
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
- Unclear whether data are sold or rented to third parties.
- Data are shared for third-party advertising and/or marketing.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Unclear whether this product uses data 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.
Data Collection
SCORE: 40%
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.
- Behavioral data are collected.
- Sensitive data are collected.
- 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: 45%
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.
- Unclear whether 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.
- Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 80%
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.
- Unclear whether 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 not available.
- Processes to delete user data are available.
- Processes to download user data are available.
Data Sold
SCORE: 25%
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.
- 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 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.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 30%
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 displayed publicly.
- Unclear whether this product allows users to control how their data are displayed.
- User-created content is not reviewed, screened, or monitored by the vendor.
- 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?
- Data are shared for third-party advertising and/or marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Unclear whether this product uses data 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.
- Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 30%
Can I provide parental consent?
- Intended for children under 13.
- Unclear whether intended for parents or guardians.
- Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
- Unclear whether 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.
- 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: 70%
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.
- 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.
- FERPA parental consent exceptions are indicated.
- 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.