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Privacy Evaluation for ReadTheory

Last updated January 18, 2020

Overview

ReadTheory provides texts matched to Lexile Levels, and tracks student progress and comprehension through reading exercises. The terms of ReadTheory state they do not allow users to interact with other users in the same classroom, or school. ReadTheory's terms state they may collect a user's personal information and non-personal usage information automatically from data analytics. ReadTheory's terms state they take reasonable steps to release a student's personal information only to third parties who are capable of maintaining the confidentiality, security and integrity of the information. Lastly, ReadTheory's terms state they are compliant with COPPA and obtain parental consent for all users under 13 years of age.

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

Safety

The terms of ReadTheory state they do not allow users to interact with other users in the same classroom, or school. However, ReadTheory's terms state they may share a student's personal information with new teachers who use the Services in their classrooms when a student enrolls in that teachers' class. In addition, ReadTheory terms state they may share a teacher's personal information with other teachers within a school using the same Services. The terms state Student progress reports are accessible only to the students themselves by logging in their Student Account. However, progress reports may also be visible to any Teacher Accounts to whom each student's account is linked.

Privacy

The terms of ReadTheory state they may collect a user's personal information and non-personal usage information automatically from data analytics. However, ReadTheory's terms state they do not require users to provide personal information to use the Service and do not allow users to upload any photographs. ReadTheory’s terms state they will not sell student personal information or disclose a student's personal information to any third party for that third party's own marketing purposes.

However, ReadTheory's terms states they may display non-targeted advertisements to users of the Service, because it is the means by which the Service generates revenue necessary to sustain the site as a completely free resource. In addition, ReadTheory's terms state they may advertise third-party linked websites from which users may purchase or otherwise obtain certain sample goods, freebie offerings or free trial services. The terms specify that they will not use or disclose student information, whether personal information or otherwise, for behavioral targeting of advertisements to students. Advertisements on the Site are non-targeted, which means targeted advertising has been disabled for all ads shown on this Site.

Security

ReadTheory's terms state they take reasonable steps to release a student's personal information only to third parties who are capable of maintaining the confidentiality, security and integrity of the information. ReadTheory's terms state they encrypt the transmission of all teachers' and students' personal information using security measures designed to protect the security, privacy, confidentiality, and integrity of personal information against risks through the use of administrative, technological, and physical safeguards. However, ReadTheory's terms state they do not also disclose whether teacher and student data are encrypted at rest. In the event of a data breach, ReadTheory's terms state they will notify users within 72 hours and the notification may be delivered in the form of email or in general message posting in a prominent location on the Service.

Compliance

ReadTheory's terms state they are compliant with COPPA and obtain parental consent for all users under 13 years of age. ReadTheory requires all users signing up for new Student Accounts, as well as all Teacher Accounts that create Student Accounts on behalf of their students, to review their parental consent information form. ReadTheory's terms state that any users under 13 years of age who continue to use the Site following their parents' or guardians' review of their Parental Information Form are considered to constitute parental consent.

ReadTheory's terms state they do not receive funding from the United States Department of Education, and therefore are not subject to the Family Educational Rights and Privacy Act, or qualify as a "school official" for any purposes. However, although ReadTheory is not an educational institution, they provide services to educational institutions under FERPA and collect statistics on student progress reports that are used in classrooms and by teachers that could, in some situations, constitute "education records" under FERPA. Teachers should consult with administrative staff to get a clear understanding of whether or not their use of this service triggers additional obligations under FERPA.

Data Collection
SCORE: 40%

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.
  • Unclear whether this product collects geolocation data.
  • Unclear whether this product collects biometric or health data.
  • Unclear whether this product collects behavioral data.
  • Unclear whether this product collects sensitive data.
  • Non-personally identifiable information is collected.
  • Combined information is not treated as personally identifiable information (PII).
  • Personal information from children under 13 years of age is collected online.
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.
  • Use of information is limited to the purpose for which it was collected.
  • 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.
Data Security
SCORE: 60%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Account creation is 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.
  • All data in transit are encrypted.
  • Unclear whether this product encrypts all data at rest.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 15%

What rights do I have to the data?

  • Unclear whether opt-in consent is requested from users at the time personal information is collected.
  • Unclear whether users can control their information through privacy settings.
  • Unclear whether users can create or upload content.
  • Users do not retain ownership of their data.
  • Unclear whether this product provides processes to access and review user data.
  • Unclear whether this product provides processes to modify inaccurate data.
  • A data-retention policy is available.
  • Unclear whether the school, parents, or students can delete data.
  • Unclear whether a user can delete all their data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 25%

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.
  • Unclear whether 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.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • User information is 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.
Data Safety
SCORE: 55%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information is shared for social interactions.
  • Personal information is not displayed publicly.
  • Users can control how their data are displayed.
  • User-created content is reviewed, screened, or monitored by the vendor.
  • 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: 50%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • Behavioral or targeted advertising is not displayed.
  • Data are not collected 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.
  • Unclear whether this vendor can send marketing messages.
  • The vendor does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 85%

Can I provide parental consent?

  • Intended for children under 13.
  • Intended for parents or guardians.
  • Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
  • Children's privacy is applicable.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • Parental consent is required.
  • 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: 70%

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.
  • Product does create education records.
  • Notification of a contract or additional rights is not provided.
  • Vendor is not designated as a school official.
  • Parental consent obligations are transferred to the school or district.
  • FERPA parental consent exceptions are not indicated.
  • Unclear whether this product discloses directory 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.