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Privacy Evaluation for Tickle

Last updated October 31, 2017

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.
  • 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 not collected online.
Data Sharing
SCORE: 55%

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.
  • Unclear whether data are shared with third-party service providers.
  • Unclear whether the roles of third-party service providers are indicated.
  • Unclear whether this product supports social or federated 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 parental controls or managed accounts are available.
  • 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.
Data Rights
SCORE: 55%

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.
  • Unclear whether this product provides processes to modify inaccurate data.
  • Unclear whether the product provides a data-retention policy.
  • Processes for the school, parents, or students to delete data are available.
  • Unclear whether a user can delete all their data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 25%

Is the data sold?

  • Unclear whether data are 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.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • Unclear whether 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: 25%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users and/or students.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information is shared for social interactions.
  • Personal information is not displayed publicly.
  • Unclear whether this product allows users to control how their data are displayed.
  • User-created content is reviewed, screened, or monitored by the vendor.
  • 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?

  • 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.
  • Unclear whether this product uses data 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: 35%

Can I provide parental consent?

  • Not 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.
  • Unclear whether children's privacy is applicable.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • Parental consent is not required.
  • 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.
  • Unclear whether the product creates education records.
  • Unclear whether this product provides notification of a contract or additional rights.
  • Vendor is designated as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
  • FERPA parental consent exceptions are indicated.
  • 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.