Privacy Evaluation for Sushi Monster
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'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.
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.
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.
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.
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.
- 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.
- Personal information of users is collected by a third party.
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 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.
- The roles of third-party service providers are indicated.
- Third-party 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.
- Managed accounts are available.
- Unclear whether multi-factor account protection is available.
- 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.
- All data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
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 or review user data are available.
- Processes to modify data are available 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.
- Unclear whether methods are available to restrict who has access to data.
- Processes to download user data are available.
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.
- User information that is shared is shared in an anonymous or de-identified format.
- 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.
How safe is this product?
- Users can interact with trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Users can control how their data are displayed to others.
- 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
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Traditional or contextual advertisements are displayed.
- Personalised advertising is displayed.
- 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.
- The company does provide promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected.
- 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.
- Unclear whether this product provides parental consent notice and method for submission.
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.
- Unclear whether 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.
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.
- Company may combine data with additional data from third-party sources.
- Combined information is treated 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.