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Privacy Evaluation for LearnZillion

Last updated January 23, 2020

Overview

LearnZillion offers thousands of free Math and English Language lessons that have been developed by teachers directly from the Common Core State Standards. The terms state that teachers and parents who are the managers of a class can see information about their students or children in that class, such as the student’s or child’s name, school affiliation and activity on assignments (including time of activity and any responses to questions, extending to grades for those assignments). According to the terms Information collected from students is never used or disclosed for any third-party advertising or any kind of behaviorally targeted advertising. LearnZillion’s terms state that encryption, firewalls, and reasonable security measures are in place for data while stored and in transit. Lastly, LearnZillion's terms state that when school districts or teachers create primary accounts and invite students to create student accounts, they are acting on behalf of parents to give LearnZillion consent to collect student information described in their policies, and LearnZillion is acting as a service provider or school official to the school district or teacher.

LearnZillion can be accessed through its website. The Privacy Policy and Terms of Service used for this evaluation can be found on LearnZillion’s website. 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 teachers and parents who are the managers of a class can see information about their students or children in that class, such as the student’s or child’s name, school affiliation and activity on assignments (including time of activity and any responses to questions, extending to grades for those assignments). In addition, the terms of LearnZillion state that account administrators can delegate the right to access, modify, and delete student information to school administrators in accordance with district policy.

Privacy

According to the terms of LearnZillion, school districts or teachers can create primary accounts and invite students to create student accounts, and are required to act on the behalf of parents to give LearnZillion consent to collect student information. This can include student records and teacher and student information such as email address, grade level, and zip code. The terms also state that cookies and other tracking mechanisms are used for the purpose of directly supporting the purpose and development of the site.

Additionally, the terms state LearnZillion does not ask or require students to provide information beyond that which is reasonably necessary to use the service. The terms further state LearnZillion does not sell or share any student login information with any third party and they do not automatically collect personal information from student accounts. According to the terms information collected from students is never used or disclosed for any third-party advertising or any kind of behaviorally targeted advertising.

Security

LearnZillion’s terms state that encryption, firewalls, and reasonable security measures are in place for data while stored and in transit. According to the terms, data is only accessed and controlled by the primary account holder (teacher or parent). The terms further state that in the event of a data breach, LearnZillion will provide notification to users within 30 days.

Compliance

LearnZillion's terms state that when school districts or teachers create primary accounts and invite students to create student accounts, they are acting on behalf of parents to give LearnZillion consent to collect student information described in their policies, and LearnZillion is acting as a service provider or school official to the school district or teacher. For these types of primary account, all requests to review, delete or edit student information must come from the school district or teacher, and parents should make use of the school’s policies with respect to reviewing, deleting or editing student information. In addition, the terms state when parents are the primary account holders, they may delete or edit student information through the LearnZillion user interface or by contacting LearnZillion.

If a school district or school requests deletion of data under the control of the school district or school, LearnZillion will promptly delete it, subject to any legal requirement to retain or transfer that data. The terms further state that any information students share with others on the service or content other students may have copied, is not a part of their account and may not be deleted when users delete their account. Lastly, the terms state that if LearnZillion shares student data with one of their service providers, they will require third parties to delete student data when they delete their account.

Data Collection
SCORE: 45%

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.
  • Unclear whether this product collects geolocation data.
  • 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 not supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 85%

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.
  • Employee or physical access to user information is limited.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 95%

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.
  • Processes to download user data are available.
Data Sold
SCORE: 45%

Is the data sold?

  • Data are not sold or rented to third parties.
  • Unclear whether 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.
  • Third-party transfer is contractually required to use the same privacy practices.
  • User information is shared in an anonymous or deidentified format.
  • 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: 60%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information is not 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.
  • 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: 75%

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.
  • 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: 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.
  • 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.
  • Parents can withdraw consent for the further collection of their child's information.
  • Children's personal information is deleted if collected without parental consent.
  • Parental consent notice and method for submission are provided.
School Purpose
SCORE: 70%

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.
  • 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.
  • 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.