Privacy Evaluation for Plickers
Plickers lets you poll your class for free, without the need for student devices. The policies for Plickers indicate that users may be able to upload content but that the service does not monitor or filter that content. Further, the policies state that the service will collect location data from users without providing an explanation about why that information is needed to operate the service. The terms do clearly indicate that the service will use reasonable security measures to protect user information and that in the event of a breach, they will provide notice within 72 hours. Finally, they indicate that the service does not allow anyone under 13 to create an account and that any information about students should be loaded by the teacher or school.
The policies for Plickers indicate that users may be able to upload or create content on the service. Further, the policies do not address whether users may communicate with one another through the service, nor any information about how the service handles user interactions.
The policies also indicate that the service may display advertisements to users, but do not address whether those ads are based on personal information or tracking data about the user. Further, the policies state that the service will use a user's information to send marketing communications and that an opt out mechanism is in place for those communications.
Plickers' policies state that the service uses reasonable security practices to protect a user's information, but do not indicate whether the service will use encryption to protect that information. They do clearly indicate that the service will require all third parties who are given access to user information to employ security measures to protect the information. Further, the policies are clear that if there is a security breach involving user data, the service will notify users within 72 hours.
Plicker's policies clearly indicate that accounts on the service are only intended only for users who are older than 13. They also clearly indicate that the service relies on teachers or schools to upload any personal information for students who will use the service. The policies state that any child who uses the service should have verifiable parental consent, but do not address any method for the service to obtain that consent nor that the school should obtain the consent.
The policies do indicate that teachers may access and update information by logging into the service and loading their account page, or by contacting the service. They also clearly indicate that if the service is contacted by a parent who reports the service holds information about a child without consent, that the service will delete the child's information. Finally, the policies are not clear whether users will retain ownership and control of the information the service collects about them.
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.
- Behavioral data are collected.
- Unclear whether this product collects sensitive data.
- Non-personally identifiable information is collected.
- Unclear whether opt-in consent is requested from users at the time personal information is collected.
- Personal information of users is collected by a third party.
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 personal information are indicated.
- Data are shared for analytics.
- 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 supported.
- 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 not 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.
- Unclear whether this product limits employee or physical access to user information.
- Unclear whether this product encrypts all data in transit.
- Unclear whether this product encrypts all data at rest.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Users can create or upload content.
- Unclear whether 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.
- A user's data are deleted upon account cancellation or termination.
- Unclear whether this product deletes data when no longer necessary.
- Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
- Processes to download user data are available.
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 not shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification process of user information.
- 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?
- Users can interact with trusted users and/or students.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
- Personal information is displayed publicly.
- Users can control how their data are displayed.
- User-created content is not reviewed, screened, or monitored by the vendor.
- User-created content is not 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?
- Unclear whether data are shared for third-party advertising and/or marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Unclear whether this product displays behavioral or targeted advertising.
- Unclear whether this product allows data collection by third-party advertising or tracking services.
- Unclear whether this product uses data to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles 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.
Can I provide parental consent?
- Not intended for children under 13.
- Unclear whether this product collects personal information online from children under 13 years of age.
- Unclear whether intended for parents or guardians.
- Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is not applicable.
- Unclear whether this product requires parental consent.
- Unclear whether this product limits parental consent with respect to third parties.
- Parents cannot 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.
Is the product intended for school?
- Intended for students.
- Personal information or education records are not 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.
- 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.