Privacy Evaluation for Tickle
59%
Overview
Tickle is a platform that connects electronic devices together so that they can interact with each other. Tickle's terms state they do not provide users with social interaction features, or make information visible to others, but pictures or other multimedia may be submitted by users to the service. Tickle's terms do not clearly indicate the version or effective date of the policies in violation of CalOPPA. Tickle's terms state they follow accepted industry standards during the process of collecting personal information and require that all of their employees are kept up-to-date on secure privacy and security practices. Lastly, Tickle's terms state they allow parents or guardians of children under the age of 13 to review, delete, manage, or refuse to share their child’s information with third parties.
Tickle is available for download at the iOS App Store. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Tickle’s website, and iOS App Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The terms of Tickle state they do not provide users with social interaction features, or make their information visible to others, but pictures or other multimedia may be submitted by users to the Service.
Privacy
Tickle's terms do not clearly indicate the version or effective date of the policies in violation of CalOPPA. In addition, the policies contain grammatical errors. During registration, users are required to give contact information including their e-mail address, residence, name and surname, and billing information. In addition, Tickle's terms state they may collect non-personal analytical information and a user's location while using the mobile application.
Tickle's terms state they use third-party behavioral tracking methods and a user's personal information to deliver personalized advertisements based on a user's behavior and their keyword searches on the Internet. Tickle's terms state they may also send marketing information to users about products, services, special deals, tailored promotions, or newsletters that they believe a user may be interested in based on their personal information.
Security
Tickle's terms state they follow accepted industry standards during the process of collecting personal information and require that all of their employees are kept up-to-date on secure privacy and security practices. In addition, the terms state encryption technology is utilized to safely store users' personal information and personally identifiable information is kept in a secure environment. Lastly, in the event of a data breach, Tickle will notify users by their email address, on the website, or other recognizable aspect of their App.
Compliance
Tickle's terms state they allow parents or guardians of children under the age of 13 to review, delete, manage, or refuse to share their child’s information with third parties. However, the terms state creating an account on the Tickle App is not allowed for children under 13 years of age without consent from their parent or guardian. In addition, in compliance with FERPA, Tickle allows a parent or guardian to access their children's education records.
Tickle's terms state they provide third party advertising services that display users with targeted advertisements according to their preferences, behavior, and keyword searches on the Internet. Under COPPA, Tickle's terms state they do not knowingly collect personal information from children under 13 and that Tickle is not considered a service which markets directly to children. However, the service would most likely still appeal to children under 13 years of age, because of the subject matter, visual content, age of models, and activities provided on the service.
Tickle's terms also contain two paragraphs relating to SOPIPA and FERPA that state that their service complies with the requirements of both laws. However, the terms do not contain information that highlights how they would determine when they need to comply with these laws.
Data Collection
SCORE: 50%
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.
- Unclear whether personal information of users is collected by a third party.
Data Sharing
SCORE: 45%
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.
- Unclear whether third-party services are used to support the product.
- Unclear what the roles of third-party service providers are.
- Unclear whether this product supports third-party login.
- 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.
- Unclear whether managed accounts are available.
- 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.
- Unclear whether this product encrypts all data in transit.
- All data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
Data Rights
SCORE: 35%
What rights do I have to the data?
- Users can create or upload content.
- 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.
- Unclear whether the product provides a data-retention policy.
- Processes for authorized users to delete data are available.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Unclear whether this product deletes data when no longer necessary.
- Unclear whether 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: 25%
Is the data sold?
- Unclear whether personal information is 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.
- 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.
- 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: 25%
How safe is this product?
- Unclear whether this product supports interactions between trusted users.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information must be shared for social interactions.
- Personal information can be not displayed publicly.
- Unclear whether this product allows users to control how their data are displayed to others.
- User-created content is reviewed, screened, or monitored by the company.
- User-created content is not 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: 50%
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.
- Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for personalised advertisements.
- The company can send marketing messages.
- The company does provide promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 45%
Can I provide parental consent?
- Not intended for children under 13.
- Personal information from children under 13 years of age is not 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 not provide a section, heading, or separate policy for children in their policies.
- Parental consent is not required before personal information is collected or disclosed.
- Parental consent is limited with respect to third parties.
- Unclear whether this product allows parents to withdraw consent for the further collection of their child's information.
- Unclear whether this product deletes children's personal information if collected without parental consent.
- Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 50%
Is the product intended for school?
- Intended for students.
- Unclear whether personal information or education records are collected from preK-12 students.
- Intended for teachers.
- Product is not primarily used by, designed for, and marketed toward students in grades preK–12.
- Processes to enter education records into the product are not described.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Company is designated as a school official.
- Unclear whether this product transfers parental consent obligations 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.
- Unclear whether consent is obtained if the practices in which data are collected change.
- 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.