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Privacy Evaluation for Padlet

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Overview

Padlet is a digital canvas where users can add photos, videos, audio, text, drawings, graphs, charts, and more. The terms say that padlets can be saved with a range of privacy settings. The terms state that the service may automatically collect information, including personal information, about users and how they use the service. In addition, the terms state that Padlet maintains administrative, technical and physical safeguards to protect against loss, theft, unauthorized use, disclosure, or retrieval of personal information. The terms say Padlet does not sell data to third parties or use personal information for third-party marketing purposes. However, the terms do not say whether Padlet may display targeted advertisements or track users over time and across the internet. Lastly, the terms of service specify that the school, teacher, or district is responsible for any parental consent requirements or obligations covered under COPPA or FERPA.

Padlet can be accessed through its website, and is available for download at the iOS App Store, the G11oogle Play Store, the Amazon App Store, and the Chrome Web Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Padlet’s website, iOS App Store, the Google Play Store, the Amazon App Store, and the Chrome Web Store. Additionally, other policies used for this evaluation include: Content Policy, and Data Practices. 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 padlets can be saved with a range of privacy settings. The ability to leave comments with pictures, video, or audio can be toggled alongside visibility settings. The most permissive settings allow for anonymous comments on public posts. Padlet also offers a school-specific offering that provides additional teacher and student features and privacy protections. In the default Padlet account, profiles are publicly visible to anyone with the URL. The terms warn users that if they are contributing to a padlet, they should exercise caution when sharing personal information regardless of the privacy level. The owners of a padlet could change its privacy visibility settings at any time; a padlet you thought was private today may become totally public tomorrow.

Privacy

The terms state that the service may automatically collect information, including personal information, about users and how they use the service. If Padlet shares user data with third parties as part of providing the service, these third parties will be contractually required to only use the shared data to support Padlet. In addition, the terms state that Padlet will not sell user data and will not user personal information for third-party marketing purposes. However, the terms do not state whether Padlet may display third-party ads to users on its service, or display ads about Padlet outside of the service by tracking users.

Security

The terms state Padlet maintains administrative, technical and physical safeguards to protect against loss, theft, unauthorized use, disclosure, or retrieval of personal information. In addition, Padlet ensures passwords are stored and transferred securely using encryption and salted hashing. The terms state the service is hosted on servers at a third-party facility, with whom Padlet has a contract providing for enhanced security measures. For example, personal information is stored on a server equipped with industry standard firewalls and the hosting facility provides a 24x7 security system, video surveillance, intrusion detection systems and locked cage areas. Lastly, the terms state that if Padlet learns of a security breach, they will attempt to notify users electronically so that they can take appropriate protective steps.

Compliance

The terms of service specify that the school, teacher, or district is responsible for any parental consent requirements or obligations covered under COPPA or FERPA. The terms also specify that Padlet is not intended to be used by people under the age of 13 without the guidance, supervision and consent of their parents, guardians and/or authorized school officials. The terms specify that schools or teachers using the site with children are expected to get parental consent before sharing student information on the site. Lastly, Padlet's terms specify that users may request to access, modify, delete, or export their personal information.

Rating

This product received a Warning rating based on the following details:
  • Personal information is not sold or rented to third parties.
  • Personal information is not shared for third-party marketing.
  • Unclear whether this product displays personalised advertising.
  • Unclear whether data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for personalised 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.
  • 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: 75%

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.
  • Unclear whether 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 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: 65%

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.
  • Unclear whether 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: 45%

How safe is this product?

  • Users can interact with trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information must be shared for social interactions.
  • Personal information can be 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: 20%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Unclear whether this product displays personalised advertising.
  • Unclear whether data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
  • The company cannot 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.
  • Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 35%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Unclear whether intended for parents or guardians.
  • Unclear whether company has 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.
  • Unclear whether this product allows parents to withdraw consent for the further collection of their child's information.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 38%

Is the product intended for school?

  • Unclear whether intended for students.
  • Personal information or education records are collected from preK-12 students.
  • Unclear whether 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 not described.
  • Unclear whether 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.
  • Unclear whether 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.
  • Unclear whether 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.
  • 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.