Privacy Evaluation for StackUp
Stackup is a service that measures reading time, reading level, and category of online reading & learning on the web, and then maps web sites to pre-defined subject area categories. The terms state students cannot interact with each other within the Stackup platform. Stackup's terms state they do not use sell student data or use student data for behavioral advertising. The terms state Stackup maintains a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of student personal information against risks. Lastly, the terms state that Stackup does not knowingly collect any Personally Identifiable Information from children under 13 without parental consent.
The terms state students cannot interact with each other within the Stackup platform. In addition, educator interactions with their students are limited (for example, a Teacher can view a students dashboard, but cannot change it) and only the student, student’s teachers, and designated school leaders can see a student’s dashboard. Student accounts are not viewable by the general public, and a user must be securely signed in and associated with that particular school, class, or student to be viewed.
Stackup's terms state they do not use sell student data or use student data for behavioral advertising. In addition, the terms state Stackup will not build a personal profile of a student other than for supporting authorized educational or school purposes or as authorized by the parent, student, or teacher. The terms also state that users will be given at least a 10 day notice via email of any material changes to terms. Because the application uses a browser extension to track reading and browsing patterns, users will need to be given clear instructions to turn off tracking when they do not want their reading habits to be observed. Additionally, the terms state third parties have no access to Stackup data, however, the service supports signing-up using “Sign in with Google” which utilizes Google OAuth 2.0.
The terms state Stackup maintains a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of student personal information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. In addition, the terms state personal information is contained behind secured networks and is only accessible by users and a very limited number of Stackup personnel who have special access rights in order to update and maintain the service. Additionally, the terms state personal information is encrypted while in transit and in the event of a data beach Stackup will provide notice to affected users.
The terms state that Stackup does not knowingly collect any Personally Identifiable Information from children under 13 without parental consent. Stackup's terms also state that teachers can request a form to send home to help manage parental consent, but the expectation is that teachers will manage all parental consent required under FERPA and COPPA. Stackup's terms state that schools can use the "School Official" exception to share data with vendors who need that data for a legitimate educational purpose. In addition, teachers using Stackup should review what the expectations and requirements are for sharing student data with third parties. Teachers should also review whether their school or district considers a reading log part of an educational record before using Stackup.
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.
- Behavioral data are collected.
- 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 collected online.
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.
- Unclear whether data are shared for research and/or product improvement.
- Data are shared with third-party service providers.
- Unclear whether the roles of third-party service providers are indicated.
- Social or federated login is supported.
- Contractual limits are placed on third-party data use.
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.
- Unclear whether third-party contractual security protections are required.
- Industry best practices are used to protect data.
- Employee or physical access to user information is limited.
- 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.
What rights do I have to the data?
- Opt-in consent is requested from users at the time personal information is collected.
- Users can control their information through privacy settings.
- Users cannot create or upload content.
- Unclear whether users retain ownership of their data.
- Processes to access and review user data are available.
- Unclear whether this product provides processes to modify inaccurate data.
- A data-retention policy is available.
- Processes for the school, parents, or students to delete data are available.
- Processes to delete user data are available.
- Unclear whether this product provides users the ability to download their data.
Is the data sold?
- Data are 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.
- 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 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.
How safe is this product?
- Users cannot 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.
- 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
Are there advertisements or tracking?
- Data are not shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are not displayed.
- Behavioral or targeted advertising is not displayed.
- Data are not collected by third-party advertising or tracking services.
- Data are not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used 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 cannot opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- 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.
- 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.
- 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.
- Parental consent notice and method for submission are provided.
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 provided.
- Vendor is designated as a school official.
- Parental consent obligations are transferred to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.