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Privacy Evaluation for Plickers

Last updated July 10, 2020

Overview

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.

Plickers can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Plicker’s website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

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.

Privacy

The privacy policy for Plickers clearly states that only the information that is needed to operate the service is collected from users. The policy also states that the service will collect certain demographic and location data without indicating why that information is needed to operate the service. They also indicate that the service will use tracking tools to collect data to improve the service and that information may be shared with third parties, but the terms are not clear whether any of those third parties place trackers on the service.

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.

Security

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.

Compliance

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.

Data Collection
SCORE: 35%

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.
  • Interactions, behaviors, or usage analytics data are collected.
  • Unclear whether this product collects sensitive data.
  • Data is automatically 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.
Data Sharing
SCORE: 80%

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.
  • 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: 50%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Account creation is not 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.
  • Unclear whether this product limits employee or physical access to user information.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether all data are stored in an encrypted format.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 65%

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 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.
  • Unclear whether this product deletes data when no longer necessary.
  • Unclear whether methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 40%

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 not shared in an anonymous or de-identified format.
  • Unclear whether the company describes their de-identification process of user information.
  • 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 not reviewed, screened, or monitored by the company.
  • 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
SCORE: 15%

Are there advertisements or tracking?

  • Unclear whether personal information are 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 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: 25%

Can I provide parental consent?

  • Not intended for children under 13.
  • Unclear whether this product collects personal information from children under 13 years of age.
  • 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.
  • Unclear whether parental consent is required before personal information is collected or disclosed.
  • 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.
School Purpose
SCORE: 75%

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.
  • Processes to enter education records into the product are described.
  • Additional rights or protections may be provided with an additional school contract.
  • Unclear whether the company is designated as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: 35%

Can I control the use of my data?

  • Unclear whether users can control the use of their information through privacy settings.
  • Use of information is not limited to the purpose for which it was collected.
  • Unclear whether the conext or purpose for which data are collected is indicated.
  • Unclear whether 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.
  • Unclear whether a grievance or remedy mechanism is 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.