Privacy Evaluation for Udemy
65%
Overview
Udemy is an online learning and teaching marketplace with over 130,000 courses and 35 million students where users can learn programming, marketing, data science, and more. The terms say a user's profile data may be publicly viewable by others and parts of the service let users interact with other users or share content publicly, including by posting reviews on a course page, asking or answering questions, sending messages to students or instructors, or posting photos or other work. In addition, the terms say Udemy sells personal information of its users to third parties for advertising purposes and Udemy may use personal information to display targeted ads and use third-party advertising services like Taboola, Facebook, Google’s ad services, and other ad networks to deliver advertising to users on other websites and applications across the internet. The terms also say Udemy takes reasonable security measures to protect against unauthorized access, alteration, disclosure, or destruction of users' personal data that they collect and store. Lastly, students and instructors must be at least 18 years of age to create an account on Udemy and users can access, modify, and delete their data at any time through the services.
Udemy 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 Udemy’s website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Rating
- Data are sold or rented to third parties.
- Data are shared for third-party advertising and/or marketing.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for data enhancement, and/or targeted advertisements.
Data Collection
SCORE: 55%
What data does it collect?
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Unclear whether the collection or use of data is limited to product requirements.
- Geolocation data are not collected.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- Sensitive data are collected.
- 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.
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.
- 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.
Data Security
SCORE: 30%
How does it secure data?
- A user's identity is not verified with additional personal information.
- Account creation is required.
- Unclear whether 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.
- Unclear whether this product limits employee or physical access to user information.
- Unclear whether this product encrypts all data in transit.
- Unclear whether this product encrypts all data at rest.
- Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 70%
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 not deleted when no longer necessary.
- Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
- Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 40%
Is the data sold?
- 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.
- 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.
- 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: 45%
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.
- Social interactions between users are not moderated.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 60%
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.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are 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.
- Users can opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 60%
Can I provide parental consent?
- Not intended for children under 13.
- Personal information from children under 13 years of age is not collected online.
- Intended for parents or guardians.
- Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
- Unclear whether 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.
School Purpose
SCORE: 50%
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.
- Unclear whether this product provides notification of a contract or additional rights.
- Unclear whether this product designates the vendor 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.