Common Sense Privacy Program

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Privacy Evaluation for Privo

Last updated
Applications and services with a Pass rating have met our minimum requirements for privacy and security practices. Before using an application or service with this rating, parents, teachers, schools, and districts are strongly advised to read the full privacy evaluation as a starting point for the process of vetting the application or service. In addition, a more detailed review should happen before any child or student data is shared with a product.

93%

Pass

Learn how we rate

Overview

Privo provides access and identity management that enables third party vendors to obtain verifiable parental consent for the collection of information from a child or student under 13 years of age. Privo's policies indicate that they do not provide social interactions between users or allow user content. Privo does not display ads or share information with other third parties for tracking or advertising. Privo also explains that it uses industry standard physical, electronic, and managerial procedures such as SSL to safeguard and help prevent unauthorized access. Privo's policy lists its privacy solutions, which include an FTC-approved COPPA (Children’s Online Privacy Protection Act) Safe Harbor Program, as well as GDPRkids™ Privacy Assured and Student Digital Privacy Programs.

Privo can be accessed through its website. The Privacy Policy and Terms of Use used for this evaluation can be found on Privo’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Privo's policies indicate that they do not provide social interactions between users or allow user content. The privacy policy and terms of service indicate that third-party sites are not monitored for content.

Privacy

Privo's policy notes that it collects information to allow a parent or guardian to grant consent for their child to use additional Privo Lock enabled services that use the Privo ID for log on. The vendor claims that it does not collect more information than reasonably necessary for a child to participate in a given activity, although it may collect personal data for age-gating. Privo does not display ads or share information with other third parties for advertising or tracking. The policy states that o personal information is displayed publicly.

Security

Privo's policy indicates that the company uses generally accepted security measures and safeguards. Privo also explains that it uses industry standard physical, electronic, and managerial procedures such as SSL to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information they collect.

Compliance

Privo's policy lists the privacy solutions offered by Privo, which include an FTC-approved COPPA (Children’s Online Privacy Protection Act) Safe Harbor Program, as well as GDPRkids™ Privacy Assured and Student Digital Privacy Programs. The policy details various verifiable parental consent options. Further, the policy describes a process by which the parent logs to the child's account and can see all the permissions the parent has set for the child, access the personally identifiable information that Privo has collected from the parent or child, correct factual errors in such information, and can request to have this information deleted or request that Privo no longer collect or maintain such information. The policy states that if a parent or child requests to delete their information this request will be met within 30 days unless there is a legal requirement to retain the information.

Rating

This product received a Pass rating based on the following details:
  • Intended for children under 13.
  • Collection or use of data is limited to product requirements.
  • Personal information can be displayed publicly.
  • Users cannot interact with trusted users.
  • Notice is provided in the event of a data breach.
  • Parental consent is required before personal information is collected or disclosed.
Data Collection
SCORE: 85%

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 not 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: 100%

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 not shared for analytics.
  • Data are not 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: 95%

How does it secure data?

  • A user's identity is 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: 75%

What rights do I have to the data?

  • Users cannot 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.
  • Unclear whether 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 not available.
Data Sold
SCORE: 75%

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.
  • 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 not shared for research and/or product improvement.
  • Contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 80%

How safe is this product?

  • Users cannot interact with trusted users.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information must be not 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 filtered for personal information before being made publicly visible.
  • Social interactions between users are not moderated.
  • Social interactions of users are not logged.
  • Users cannot report abuse or cyberbullying.
Ads & Tracking
SCORE: 85%

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 not collected by third-parties for their own purposes.
  • Users's information is not 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.
  • Unclear whether this company provides 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: 95%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • 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 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 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 are not provided with an additional school contract.
  • Company is not designated as a school official.
  • Parental consent obligations are not transferred to the school or district.
Individual Control
SCORE: 80%

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 will not 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.
  • 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.

Learn more about the SPR Read the report

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.