Thumbnail

Privacy Evaluation for ThingLink

Last updated January 17, 2020

Overview

ThingLink provides an easy way to save and share notes and observations about real-world spaces, situations and artifacts. The terms state certain features let uses make additional information available to the public, and users have the option to share their ThingLink activities with their friends, or through email, SMS text, or various social media sites. In addition, users can browse ThingLink without providing personal information, but they must register in order to access most of the features of the service. ThingLinks's terms state they use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information they collect and that they share with third-party service providers. The terms state that ThingLink recognizes that children under 13 may use the service under the supervision of a parent or an educational institution acting as an agent of their parent.

ThingLink 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 ThingLink’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Acceptable Use Policy, Cookie Policy, and Privacy Architecture. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms state users may choose to provide additional information which may be shared with others on the service or through their public profile, such as their name, email address, nickname or online alias, other ThingLink accounts they choose to follow, and Immersive Images. In addition, if a user registers a ThingLink account with an email address on a domain owned by their employer, educational institution, or organization, ThingLink may help collaborators and administrators find that user and their team by making some of their basic information—like their name, team name, profile picture, and email address—visible to other users on the same domain.

The terms state certain features let uses make additional information available to the public, and users have the option to share their ThingLink activities with their friends, or through email, SMS text, or various social media sites. Lastly, all ThingLink profiles are typically made available to the public, however a user may elect to make their content private. If a user makes all of the content on their profile private, then their profile will not appear in a directory search of the service, but a user may still be able to access their profile if they know the URL for their profile.

Privacy

The terms state the services allow for the collection, use, and disclosure of a user's personally identifiable information and aggregate data with third parties. In addition, users can browse ThingLink without providing personal information, but they must register in order to access most of the features of the service. ThingLink's terms state they do not collect data for collection’s sake, and access is limited and appropriate. ThingLink requires third-party vendors to agree to privacy commitments in order to share information with them. Some areas of the service allow users to post or provide content such as profile information, videos, images, music, comments, questions, and other content.

The terms also state ThingLink will not sell information or transfer information about users to third parties for the purpose of providing or facilitating third-party marketing. The terms state that in order to personalize a user's experience using the service, ThingLink may use personal information to target their marketing messages to groups of users, and to serve relevant advertisements. The terms also state they allow third-party tracking of users to analyze and track usage, determine the popularity of certain content, and deliver content that may be more targeted to a user's interests. However, for users under 13 years of age ThingLink does not permit third party behavioral advertising on the service.

Security

ThingLinks's terms state they use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information they collect and that they share with third-party service providers. In addition, the terms state personal data and backups are stored in protected databases located behind a firewall and with both physical and software-based access controls. All personal information is encrypted while in transit and at rest. In the event that any personal information is compromised as a result of a breach of security, ThingLink's terms state they will take reasonable steps to investigate the situation and where appropriate, notify individuals whose information may have been compromised.

Compliance

The terms state that ThingLink recognizes that children under 13 may use the service under the supervision of a parent or an educational institution acting as an agent of their parent. When that happens, ThinkLink's terms state they take additional precautions to protect the privacy of children under 13. The terms state that if ThingLink determines the child is under 13 years of age, they will ask for a parent's name and email address so that we can notify the parent that the kid has created an account and seek the parent's consent to allow the kid's participation. If the parent provides consent, ThingLink may collect additional information from the kid, including a profile avatar, which could include a photograph, or other content uploaded by the child to the service. However, a child under 13 will not be permitted to engage in the core functionality of the service unless ThingLink receives verifiable parental consent.

In addition, children may only access the services at the direction of their teacher or school district by using an invitation code provided to them by their teacher or educational institution. ThingLink's terms state that it is authorized by schools and districts under the FERPA “school official” exception to receive and use educational data to provide educational services. Parents and teachers may access, modify, delete, and consent to the collection and use of the child's personal information. However, ThingLink's privacy policy does not govern the collection, use, or disclosure of personal information through the service by the educational institution or organization which has given a child or student access to the service. Parents are advised by ThingLink to contact their educational organization to better understand their privacy practices as well.

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.
  • 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.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Personal information from children under 13 years of age is collected online.
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.
  • 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.
  • 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: 85%

How does it secure data?

  • 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: 95%

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 can create or upload content.
  • 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.
  • Processes to delete user data are available.
  • Processes to download user data are available.
Data Sold
SCORE: 35%

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.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • 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.
Data Safety
SCORE: 50%

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 not 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.
  • Social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 65%

Are there advertisements or tracking?

  • Data are not 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 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.
  • The vendor can send marketing messages.
  • The vendor does provide promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 80%

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.
  • COPPA parental consent exceptions are indicated.
  • Parental consent is required.
  • Unclear whether this product limits parental consent with respect to third parties.
  • Parents can 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: 70%

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.

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.