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Privacy Evaluation for Scholly

Last updated January 19, 2018

Overview

Scholly is a scholarship search platform that helps students earn scholarships. Scholly's terms state they offer chat rooms, message boards, bulletin boards, and similar public forums where a user and other users of the Service can communicate. Scholly's terms state they may disclose any information (other than billing information) to outside third parties and may sell, trade, or otherwise transfer to outside parties a user's personally identifiable information. Lastly, Scholly's terms state they neither knowingly collect any personally identifiable information from children under the age of 13, nor allow children under the age of 13 to register as a User.

Scholly 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 accessed for this evaluation can be found on Scholly’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 terms of Scholly state they may offer chat rooms, message boards, bulletin boards, and similar public forums where a user and other users of the Service can communicate. In addition, the terms state the Service may use personally identifiable and non-personal information about a user to identify users when posting in a public forum. Scholly's terms state they do not treat any user's submission as confidential, and may use any user submission or content for any purpose including advertising, promotional, product research, or other purposes.

Privacy

The terms of Scholly state they collect a wide-range of personal information for scholarship matching purposes. The terms specify that data collected can include first and last name, home or other physical address, city, school and transcript information, gender, race, ethnicity, health information, and billing information. Scholly's terms state they may disclose any information (other than billing information) to outside third parties and may sell, trade, or otherwise transfer to outside parties a user's personally identifiable information.

However, the terms also state a user's email address and any personal customer information will not be sold to or otherwise shared with third parties for marketing purposes. Moreover, Scholly's terms state they may aggregate user data together in an anonymous fashion to generate reporting for internal analysis or distribution and choose to offer the data for promotional purposes and/or monetary gain. Lastly, Scholly does not discuss whether a user's data is transferred to a third party in the event of a bankruptcy, merger, or acquisition.

Security

The terms of Scholly state they have implemented security measures that they consider reasonable and appropriate to protect against the loss, misuse and alteration of the user information under their control. However, while Scholly's terms state they strives to protect a user's personally identifiable information and privacy, they cannot guarantee or warrant the security of any information a user may disclose or transmit to them online and are not responsible for the theft, destruction, or inadvertent disclosure of a user's personally identifiable information.

In addition, the terms state a user is responsible for safeguarding and maintaining the confidentiality of their Account. Scholly's terms state they strive to keep user content secure, but "cannot guarantee that (they) will be successful at doing so, given the nature of the Internet." Accordingly, the terms state a user has the sole responsibility for adequate security, protection, and backup of their content.

Compliance

The terms of Scholly state they neither knowingly collect any personally identifiable information from children under the age of 13, nor allow children under the age of 13 to register as a User. In addition, Scholly's terms state they do not knowingly register or otherwise collect personal information from individuals who identify themselves as being under the age of 13 during the registration process, without prior consent of the child's parent or guardian. In addition, Scholly's terms state they provide no right to a user to access their content on the Website and Scholly has no obligation to return a user's content, or otherwise make it available.

Data Collection
SCORE: 30%

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.
  • 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.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Personal information from children under 13 years of age is not collected online.
Data Sharing
SCORE: 70%

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.
  • Unclear whether data are shared for analytics.
  • Unclear whether 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.
  • Unclear whether this product supports social or federated login.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 30%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Unclear whether this product requires account creation.
  • Unclear whether parental controls or managed accounts are available.
  • Two-factor account protection is available.
  • Unclear whether 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.
Data Rights
SCORE: 25%

What rights do I have to the data?

  • Opt-in consent is requested from users at the time personal information is collected.
  • Unclear whether users can control their information through privacy settings.
  • Users can create or upload content.
  • Users do not retain ownership of their data.
  • Processes to access and review user data are not available.
  • Unclear whether this product provides processes to modify inaccurate data.
  • Unclear whether the product provides a data-retention policy.
  • 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: 15%

Is the data sold?

  • Data are 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.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 15%

How safe is this product?

  • Unclear whether this product supports interactions between 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.
  • Unclear whether this product allows users to control how their data are displayed.
  • Unclear whether 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: 25%

Are there advertisements or tracking?

  • Data are shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • 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.
Parental Consent
SCORE: 40%

Can I provide parental consent?

  • Not intended for children under 13.
  • Unclear whether intended for parents or guardians.
  • Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
  • Unclear whether children's privacy is applicable.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • Parental consent is required.
  • Unclear whether this product limits parental consent with respect to third parties.
  • Parents can 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: 15%

Is the product intended for school?

  • Unclear whether intended for students.
  • Personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • Product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Unclear whether the product creates education records.
  • Unclear whether this product provides notification of a contract or additional rights.
  • 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.

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.