Privacy Evaluation for Scholly
52%
Overview
Scholly helps users find and apply to scholarships. The Privacy Policy states that Scholly uses automated social measures to screen content to prevent abuse, although, the Terms of Service state that Scholly has no obligation to monitor the use of its services. The Privacy Policy clearly outlines that the categories of personal information collected from users include names, addresses, online identifiers, telephone numbers, bank account numbers, credit card and debit card numbers, and even age, gender, race, citizenship status, and national origin. However, the terms do not clearly state whether users are subject to advertising on Scholly’s services. In addition, the terms fail to state whether users’ information is encrypted either when stored or in transit. Lastly, the terms state that individuals under the age of 13 are prohibited from using Scholly’s Services.
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 used 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 Privacy Policy warns users that information posted in messages, chat rooms, forums, and other public posting areas is available to anyone, and cautions posting certain types of information. The terms do not clearly indicate whether social interactions are moderated, and fail to disclose whether or not inappropriate content, harassment, or cyberbullying can be reported. The terms do not state whether users have control over how their personal information is displayed to others.
Privacy
The Privacy Policy discloses that Scholly collects personal information, geolocation data, behavioral data, sensitive data, usage data, and educational records. The terms are not transparent on whether the personal information collected is limited to only data that are specifically required for the product. The terms do not indicate whether Scholly obtains opt-in consent from a user at the time any information is collected, or whether Scholly provides notice or obtains consent from a user if the purpose that the personal information was collected has changed. The Privacy Policy clearly states that service providers “use cookies and web beacons to collect information, and to serve advertisements to you across the Internet based on that information.” The Privacy Policy discloses that personal information is shared with third parties, and outlines what categories of information is shared.
The Privacy Policy outlines the purposes for sharing personal information, including for the purposes of analytics, researching, marketing, processing payments, and to help facilitate advertisements. The terms are unclear on whether advertisements are only directed to individuals on other sites, or whether users on Scholly’s services are also subject to advertisements. The Privacy Policy discloses that Facebook Analytics connects users’ personal information with users’ Facebook accounts to use it for Facebook Analytics’ own advertising purposes. The Privacy Policy provides links for opting out of certain third party advertising. The Privacy Policy states that Scholly does not "sell your personal information at this time." The Privacy Policy indicates that any third-party successor of a data transfer is contractually required to provide the same privacy compliance required of Scholly, however, the Privacy Policy does not clearly state whether users will be notified or given the opportunity to delete their data in connection with Scholly’s transfer of user data in the event of a merger, acquisition, or bankruptcy. The Privacy Policy does not state whether users can opt out of any of Scholly’s promotional communications.
Security
The Privacy Policy indicates that Scholly uses reasonable security standards to protect the confidentiality of users’ personal information. However, the terms fail to state whether Scholly utilizes any encryption of users’ personal information, or whether Scholly has physical access controls for limiting employee access to user information. The Privacy Policy states that Scholly “may attempt to notify” users via email or on Scholly’s websites in the event of a data security systems breach. The Privacy Policy indicates that Scholly may use additional information to verify a users’ identity.
Compliance
The Privacy Policy provides a clear section for Children’s Privacy, and clearly states that Scholly is not intended for persons under the age of 13, and that “if you are under 13, you are not allowed to use the Services or submit any personal information to us." The Privacy Policy provides that Scholly does not knowingly collection information from visitors under the age of 13, and if Scholly learns that a person under the age of 13 has provided it with personal information, that Scholly will delete such personal information. The Privacy Policy clearly indicates that users can create or upload content to the product. However, the Privacy Policy dictates that “any information that is not personal information, such as any suggestions or ideas you provide to us, becomes our property for any use we may determine, without any notice or compensation to the author.”
The Privacy Policy provides a method for users and authorized individuals to access, review, modify, delete, and download the user’s personal information, and the categories of information shared with third parties. However, the Privacy Policy discloses that “Even after you remove information from your profile or delete your account, copies of that information may remain viewable on the Sites and elsewhere,” and that “we may retain certain information to prevent identity theft and other misconduct even if deletion has been requested.”
Rating
- Personal information is not sold or rented to third parties.
- Personal information is shared for third-party marketing.
- Unclear whether this product displays personalised advertising.
- Data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for personalised advertisements.
Data Collection
SCORE: 40%
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.
- Sensitive data are collected.
- 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: 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.
- 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.
- Unclear whether this product supports third-party login.
- Contractual limits are placed on third-party data use.
Data Security
SCORE: 25%
How does it secure data?
- A user's identity is verified with additional personal information.
- Unclear whether this product requires account creation.
- Unclear whether managed accounts are available.
- Unclear whether multi-factor account protection is available.
- Unclear whether 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: 45%
What rights do I have to the data?
- Users can create or upload content.
- Users do not retain ownership of their data.
- Processes to access or review user data are available.
- Processes to modify data are available for authorized users.
- Unclear whether the product provides a data-retention policy.
- Unclear whether authorzied users can delete data.
- A user's data are not 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.
- 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.
- Unclear whether 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: 20%
How safe is this product?
- Unclear whether this product supports interactions between trusted users.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Unclear whether this product allows users to control how their data are displayed to others.
- User-created content is 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: 35%
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Unclear whether this product displays personalised advertising.
- Data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Data profiles are 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.
- Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 50%
Can I provide parental consent?
- Not intended for children under 13.
- Personal information from children under 13 years of age is not collected.
- Unclear whether intended for parents or guardians.
- Company does not 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.
- 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.
- Unclear whether this product allows parents to withdraw consent for the further collection of their child's information.
- Children's personal information is deleted if collected without parental consent.
- Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 19%
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.
- Unclear whether this 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.
- Unclear whether 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: 30%
Can I control the use of my data?
- Unclear whether users can control the use of their information through privacy settings.
- Unclear whether 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.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Unclear whether notice is provided if the context in which data are collected changes.
- Unclear whether 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.
- 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.