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Privacy Evaluation for Sushi Monster

Last updated July 30, 2021

Overview

Sushi Monster is a game to practice, reinforce, and extend math fact fluency. The terms say that the service may allow users to create their own profile, which may be displayed publicly or semi-publicly. The terms also say that the service may collect personal information and demographic Information from users. The terms say the service does not sell users' data to third parties. However, the terms also say a user's data is used to display targeted advertisements, send third-party marketing communications, and track users on other apps and services across the internet. The terms say the service has implemented and maintains reasonable organizational, technical, administrative and physical security controls that are designed to protect the security, confidentiality and integrity of personal information collected through the service. Lastly, teachers are strongly encouraged to review the parental consent procedures within their school or district before sharing student information.

Sushi Monster is available for download at the iOS App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Sushi Monster’s iOS App Store. Additionally, other policies used for this evaluation include: Privacy Policy for HMH PreK–12 Products and Privacy Policy (GDPR). This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Sushi Monster's terms say that the service may allow users to create their own profile, which may be displayed publicly or semi-publicly. The terms also say that a user's profile page may be set up to display information such as the user's display name, images, location, groups that the user has joined, and optional information added by the user including -- for example -- the user's tagline, photographs and educational materials.

The terms say that the user can post to chat rooms, message boards, other user's profiles, bulletin boards, or similar forums. The terms describe that these interactions may be public or semi-public, and could potentially be accessible via search. The terms say that the service may also publish a user's name, voice, likeness and other personal information that is part of their user content, and they may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.

Lastly, the terms say that a user may send messages or invitations from the service, and that people sending messages from the service should be aware that their e-mail address, mobile number, name and/or user name may be included along with any message.

Privacy

The terms of Sushi Monster say that the service may collect personal information and demographic information from users. In addition, the service may automatically collect non-personal usage information when a user visits or interacts with the service. The terms say that on mobile devices, the service might track a device's location. The service may also combine a user’s non-personally identifiable demographic information or usage nformation with the personal information they collect directly on the service, but will treat the combined data as personal information.

The terms say that the service may share a user’s non-personal information, such as aggregated user statistics or data related to a user and their activities, with third parties. However, the terms also say that personal information will not be shared with third parties for direct marketing purposes unless the user provides consent. Users should be aware that the terms say that a person's name, voice, likeness and other personal information that is part of their user content could be used for advertising, marketing, publicity and promotional activities.

Additionally, the service may supplement the information they collect directly from users on the service with external information from third parties. The terms say that third parties, including advertisers and advertising service providers, may collect information about users. These third parties may use their own tracking technologies on a user’s device, or collect a user’s personal Information. While the terms say that the service will not use personally identifiable information to target ads, the terms also say that a user may be served with targeted and contextual advertising, including location-based advertising.

Security

The terms say the service has implemented and maintains reasonable organizational, technical, administrative and physical security controls that are designed to protect the security, confidentiality and integrity of personal information collected through the service. The terms also say that all data sent to and from the service is protected with encryption. The terms also say that data that are covered under COPPA or FERPA are encrypted at rest whenever possible. The terms say that if the service is not able to encrypt data, the service will use other means to protect that data.

In the terms, the service describes that privacy and information security training is provided to employees. They also describe how access to personal information is limited to specific employees. The servcice uses third-party cloud service providers in the delivery and operation of their learning platform, and data is stored on the servers of their cloud service providers. The terms describe contractual requirements are in place with these cloud service providers and are designed to protect user data.

Compliance

The terms say that the tools and services covered under the policies are designed for teachers and schools working with K-12 students. The terms highlight that, under COPPA, schools can provide consent for parents for online tools used for an educational purpose. The terms also say that the service meets the criteria for a "school official" under FERPA. The terms say that the service does not knowingly collect personal information from children under the age of 13 without verified parental consent - and for applications used within schools, the terms say that this consent can be provided by the school. In addition, if personal information or education records are collected, the service allows users to access, update, or correct their data.

The terms say the service meet FERPA's requirements for qualifying as a school official because they give the school direct control over the use and maintenance of the education records. The terms also say that the service does not re-disclose or use this personal information except for the purposes of providing the learning platform to the school. The terms say that the service may post additional information or a separate children's Privacy Policy on any website or app store page for a service directed to children under 13 years of age. These additional policies explain what types of personal information may be collected, and what options parents have to approve or limit collection from children. However, this means that users will need to navigate five different sets of policies to determine the privacy and data security practices of the service. Educators are strongly encouraged to review the parental consent procedures within their school or district before sharing student information.

Data Collection
SCORE: 55%

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.
  • Geolocation data are collected.
  • 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.
  • 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: 85%

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.
  • The categories of third parties that receive personal information are indicated.
  • 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.
  • Social or federated login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 80%

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.
  • 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.
  • All data at rest are encrypted.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 75%

What rights do I have to the data?

  • Users can create or upload content.
  • Unclear whether users retain ownership of their data.
  • Processes to access and review user data are available.
  • Processes to modify inaccurate data are available.
  • A data-retention policy is available.
  • Processes for the school, parents, or students to delete data are available.
  • A user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 55%

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.
  • User information is shared in an anonymous or deidentified format.
  • 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: 45%

How safe is this product?

  • Users can interact with 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.
  • Users can control how their data are displayed.
  • 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: 60%

Are there advertisements or tracking?

  • Data are shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • Behavioral or targeted advertising is displayed.
  • Data are collected by third-party advertising or tracking services.
  • Data are used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for data enhancement, and/or targeted advertisements.
  • The vendor can send marketing messages.
  • The vendor does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of traditional, contextual, or behavioral 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 online.
  • 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.
  • 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.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 60%

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.
  • Unclear whether this product provides notification of a contract or additional rights.
  • 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.

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.