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Privacy Evaluation for StackUp

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Overview

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.

Stackup can be accessed through its website. The Privacy Policy accessed for this evaluation can be found on Stackup’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 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.

Privacy

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.

Security

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.

Compliance

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.

Rating

This product received a Pass rating based on the following details:
  • Personal information is not sold or rented to third parties.
  • Personal information is not shared for third-party marketing.
  • Personalised advertising is not displayed.
  • Data are not collected by third-parties for their own purposes.
  • User's information is not used to track and target advertisements on other third-party websites or services.
  • Data profiles are not created and used for personalised advertisements.
Data Collection
SCORE: 45%

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.
  • Interactions, behaviors, or usage analytics data are collected.
  • Unclear whether this product collects sensitive data.
  • Data is automatically collected.
  • 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: 65%

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.
  • Unclear whether data are shared for research and/or product improvement.
  • Third-party services are used to support the product.
  • Unclear what the roles of third-party service providers are.
  • 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.
  • 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.
  • Employee or physical access to user information is limited.
  • 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: 70%

What rights do I have to the data?

  • Users cannot create or upload content.
  • Unclear whether users retain ownership of their data.
  • Processes to access or review user data are available.
  • Unclear whether this product provides processes to modify data for authorized users.
  • A data-retention policy is available.
  • Processes for authorized users to delete data are available.
  • A user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • 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: 35%

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.
  • Unclear whether 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: 45%

How safe is this product?

  • Users cannot 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.
  • Unclear whether 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: 80%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Traditional or contextual advertisements are not displayed.
  • Personalised advertising is not displayed.
  • Data are not collected by third-parties for their own purposes.
  • User's information is not used to track and target advertisements on other third-party websites or services.
  • Data profiles are not created and used for personalised advertisements.
  • Unclear whether this company can send marketing messages.
  • The company does provide promotional sweepstakes, contests, or surveys.
  • Users cannot opt out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 65%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Unclear whether 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.
  • 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.
School Purpose
SCORE: 88%

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 may be provided with an additional school contract.
  • Company is designated as a school official.
  • Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 50%

Can I control the use of my data?

  • 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.
  • Unclear whether this product treats combined information 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.
  • Unclear whether 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.