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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 interactions, behaviors, or usage analytics data.
  • Unclear whether this product collects sensitive data.
  • 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 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.
  • 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.
  • Employee or physical access to user information is limited.
  • 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: 95%

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.
  • Methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 45%

Is the data sold?

  • Personal information is 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 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.
  • Third-party transfer is contractually required to use the same privacy practices.
  • User information that is shared is shared in an anonymous or de-identified format.
  • 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: 60%

How safe is this product?

  • Users can interact with trusted users.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information must be not shared for social interactions.
  • Personal information can be not displayed publicly.
  • Users can control how their data are displayed to others.
  • 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: 75%

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.
  • 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: 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.
  • 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: 88%

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 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: 70%

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.
  • Company may combine data with additional data from third-party sources.
  • Combined information is treated 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.
  • A grievance or remedy mechanism is not 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.