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Privacy Evaluation for NoRedInk

Last updated August 27, 2021

Overview

NoRedInk builds stronger writers through an online interest-based curriculum, adaptive exercises, and actionable data. The terms say users can store user submissions in their own personal NoRedInk account, in a manner that is not viewable by any other users, or they can share submissions with only certain specified users. The terms say the service itself does not display advertising and NoRedInk does not permit the collection of data by third party advertising or tracking services in the application. However, the terms also say NoRedInk may use first-party cookies or other tracking mechanisms which allow them to target advertising to users on third party platforms who have visited their website, which may include Facebook, LinkedIn, and Twitter.

The terms of NoRedInk say they use industry standard data security measures to protect users' personal information and recommend strong password protection practices. NoRedInk also provides additional details about their security practices that include two-factor authentication and encryption. Lastly, the terms say NoRedInk only collects personal information through the service from a child under 13 where that student’s school, district, and/or teacher has agreed to obtain parental consent for that child to use the services and disclose personal information to NoRedInk. Also the paid premium version of NoRedInk is available under a separate agreement with a school or school district.

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

Safety

The terms say users can store user submissions in their own personal NoRedInk account, in a manner that is not viewable by any other users, or they can share submissions with only certain specified users. The terms say social interactions within NoRedInk are generally organized by class, and student sign-ups are managed via a class code generated when teachers add students into a course. The terms also say teachers and their students can use the service to communicate, and teachers and their school’s administrators can communicate as well. Educators should be aware class codes need to be handled securely and students can create user profiles containing information that would be readily known to their classmates.

Privacy

The terms say NoRedInk will not use, sell, share, or disclose personally identifiable information they receive to market or advertise to students or families. In addition, the terms say the service itself does not display advertising and NoRedInk does not permit the collection of data by third party advertising or tracking services in the application. However, the terms also say NoRedInk may use first-party cookies or other tracking mechanisms which allow them to target advertising to users on third party platforms who have visited their website, which may include Facebook, LinkedIn, and Twitter.

Moreover, the terms say NoRedInk does not use cookies to collect personal information and track users' online activities over time or across different web sites. However, the terms also say third party analytics or advertising providers NoRedInk uses may be able to track users’ online activities over time, but NoRedInk says it does not have access to or control of that information.

Security

The terms of NoRedInk say they use industry standard data security measures to protect users' personal information and recommend strong password protection practices. NoRedInk also provides additional details about their security practices that include two-factor authentication and encryption. Also, the terms say NoRedInk will provide notice to users in the event of a data breach.

Compliance

NoRedInk's terms say that users joining the site must be 18 years of age or older. The terms say NoRedInk only collects personal information through the service from a child under 13 where that student’s school, district, and/or teacher has agreed to obtain parental consent for that child to use the services and disclose personal information to NoRedInk. Additionally, the terms say that any teacher creating an account on the site and creating accounts on behalf of students has the authority to create a legally binding contract for their school or district. According to the terms, the school or district is responsible for getting parental consent to comply with COPPA. Teachers signing up for accounts should verify that they have the required authority within their district, and the appropriate parental consent to create a legally binding contract that meets the school's or district's FERPA obligations and COPPA guidelines. Lastly, the terms say students can access, modify, delete, or export their data, but the information in their accounts may only be changed by their teacher, school, or school district.

Data Collection
SCORE: 80%

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.
  • Geolocation data are not collected.
  • Biometric or health data are not collected.
  • Interactions, behaviors, or usage analytics data are collected.
  • Sensitive data are not 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: 90%

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.
  • 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: 100%

How does it secure data?

  • A user's identity is not verified with additional personal information.
  • Account creation is required.
  • Managed accounts are available.
  • 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: 90%

Is the data sold?

  • Personal information is not 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.
  • Users are notified if their information is transferred to a third party.
  • 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.
  • Data are shared for research and/or product improvement.
  • Contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 85%

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 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 not reviewed, screened, or monitored by the company.
  • User-created content is filtered for personal information before being made publicly visible.
  • Social interactions between users are moderated.
  • Social interactions of users are not logged.
  • Users cannot report abuse or cyberbullying.
Ads & Tracking
SCORE: 80%

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 collected by third-parties for their own purposes.
  • User's information is 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.
  • The company does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 90%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Not 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.
  • Parental consent is not limited 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: 95%

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 available for users to file a complaint.
  • Users can request to know what personal information has been shared with third parties.
  • 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.