Privacy Evaluation for ThingLink
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. ThingLink's terms state they use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all the 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.
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.
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. 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. 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 behavioral advertising on 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. 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.
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.
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.
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.
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.
- 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.
- Unclear whether this product encrypts all data in transit.
- All data at rest are encrypted.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- 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.
- 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.
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.
- 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.
- 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 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.
- Social interactions between users are moderated.
- Social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Data are shared for third-party advertising and/or marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Behavioral or targeted advertising is not displayed.
- Data are collected by third-party advertising or tracking services.
- Unclear whether this product uses data to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
- The vendor can send marketing messages.
- Unclear whether this vendor provides 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.
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected online.
- 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.
- 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.