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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: 30%

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 interactions, behaviors, or usage analytics data.
  • 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.
  • Unclear whether 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: 60%

How does it secure data?

  • Unclear whether 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.
  • Unclear whether this product limits employee or physical access to user information.
  • All data in transit are encrypted.
  • Unclear whether all data are stored in an encrypted format.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 25%

What rights do I have to the data?

  • 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 data for authorized users.
  • A data-retention policy is available.
  • Unclear whether authorzied users can delete data.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Unclear whether methods are available to restrict who has access to data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 25%

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.
  • Unclear whether 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.
  • Unclear whether third-party transfers are 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.
  • 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: 55%

How safe is this product?

  • Users can interact with trusted users.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information must be shared for social interactions.
  • Personal information can be not 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: 50%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Traditional or contextual advertisements are displayed.
  • Personalised advertising is not displayed.
  • Data are not 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.
  • Unclear whether this company can send marketing messages.
  • The company does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised advertising.
  • Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 90%

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 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: 75%

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.
  • 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 transferred to the school or district.
Individual Control
SCORE: 55%

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 limited to the purpose for which it was collected.
  • The context 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 not 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.
  • 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.