Privacy Evaluation for Nitro Type
Nitro Type is a web-based game service that provides students with the opportunity to improve their typing skills while competing in races with people from around the world. The terms of Nitro Type state that any individual can create an account with the service, and an email address is not required. However, Nitro Type displays advertisements to all users (even those under 13 years of age) and the only way to remove advertisements is to upgrade a user's account to a paid, Gold Membership account. It is not clear if the upgraded account also removes the advertisement trackers present on the website. While users are not required to enter an age or an email during signup, a full name can be added to a free account after a user has joined the site.
The terms of Nitro Type state that any individual can create an account with the service, and an email address is not required. Friend requests are allowed within the website, and the default setting (configurable via a user's profile) is to allow friend requests.
The terms state there are no interactions with adults or other students (of the same classroom or school). In addition, Nitro Type's terms state they do not routinely monitor a user's account, or disclose information about a user's communications to anyone. Lastly, the terms do not provide significant details about the tools and processes that support safe and appropriate social interactions. However, within the application a user can report other users for abusive behavior.
The terms of Nitro Type state they engage in data minimization practices but do not disclose what third-party services are used to support the operation of the website or application. However, Nitro Type's terms say they may use third-party advertising companies to serve ads and to target advertisements to the user on other websites, or on other applications or services. In addition, it is not clear whether the content of advertisements is filtered or reviewed to eliminate age inappropriate content. Also, it is not clear from the terms what information, if any, is shared with third-parties. The website also makes extensive use of third-party ad trackers.
The terms state Nitro Type supports social login, and it is not clear what data are collected from social or federated login providers (Google, Clever, and Facebook), because the providers use personal information in accordance with their own terms of service and privacy policies. In addition, Nitro Type terms state they use customer contact information from the registration form (email, zip code, age, or occupation) to send a user information about Nitro Type and, if the user chooses, promotional material from some of their partners. Lastly, the service offers an upgrade to a "Gold" account which removes the display of advertisements, but it is not clear if this upgrade also removes the numerous third party trackers used as well.
The terms of Nitro Type state it has security measures in place to protect against the loss, misuse and alteration of the information under its control. The terms specify passwords are never stored as clear text at any point, but rather are hashed thousands of times using unique randomized salts and the best available, reasonable encryption. In addition, the terms of Nitro Type state they request users to contact them in the event of a security breach, however, no other security measures are described in the policies.
The terms of Nitro Type state the service appeals to users under 13 years of age, but users are not required to enter their birth year or date in order to register or maintain an account. However, users under 13 years of age that register for the service are required to obtain parental consent. The terms say Nitro Type displays advertisements to all users (even those under 13 years of age) and the only way to remove advertisements is to upgrade a user's account to a paid, Gold Membership account. Lastly, the terms say users can access, edit, modify, and export their personal information at any time through the service.
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.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Personal information from children under 13 years of age is collected online.
What data does it share?
- Collected information is shared with third parties.
- Unclear whether the categories of information shared with third parties are indicated.
- Unclear whether the purpose for sharing a user's personal information with third parties is indicated.
- Unclear whether use of information is limited to the purpose for which it was collected.
- Unclear whether data are shared for analytics.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether data are shared with third-party service providers.
- Unclear whether the roles of third-party service providers are indicated.
- Unclear whether this product supports social or federated login.
- Unclear whether contractual limits are placed on third-party data use.
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Account creation is required.
- Unclear whether 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.
- Unclear whether this product limits employee or physical access to user information.
- Unclear whether this product encrypts all data in transit.
- All data at rest are encrypted.
- Unclear whether this product provides notice in the event of a data breach.
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.
- Unclear whether the product provides a data-retention policy.
- Unclear whether the school, parents, or students can delete data.
- Processes to delete user data are available.
- Processes to download user data are available.
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.
- Unclear whether 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.
- 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.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
How safe is this product?
- Unclear whether this product supports interactions between trusted users and/or students.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information is shared for social interactions.
- Personal information is not 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
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.
- Data are 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.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- Unclear whether intended for parents or guardians.
- Vendor does not 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 not indicated.
- 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.
Is the product intended for school?
- Unclear whether intended for students.
- Unclear whether personal information or education records are collected from preK-12 students.
- Unclear whether intended for teachers.
- Unclear whether this 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.
- Unclear whether this product transfers parental consent obligations to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.