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Privacy Evaluation for Waggle

Last updated October 19, 2020

Overview

Waggle describes its service as an online learning platform that combines trusted Coach content to create a safe and engaging environment for students to accelerate learning and build resilience and confidence in ELA and Math. Waggle's policy notes that it does not make a user's information visible to the public, but does provide private messaging services between users and information provided in these forums will be received by the specified user’s account. Waggle's policy indicates that does not share non-personal information automatically collected with third parties, or a user’s personally identifiable information with any other third party besides its third party service providers.

Waggle can be accessed through its website. The Privacy Policy and Terms of Use used for this evaluation can be found on Waggle’s website. Additionally, other policies used for this evaluation include: GDPR. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Waggle does not make a user's information visible to the public, but does provide private messaging services between users, and information provided in these forums will be received by the specified user’s account. However, Waggle's terms state they have no obligation to monitor the private messaging system.

Privacy

Waggle's terms state they do not share personal and non-personal automatically collected usage information with third parties, or a user’s personally identifiable information with any other third party besides its third party service providers. In addition, the terms state Waggle does not sell or use personally identifiable information collected from students at K-12 schools to engage in behavioral targeting of advertisements. Lastly, Waggle shares anonymized information about individual students with third party service providers so they can analyze data about individual students’ use of Waggle and provide personalized content, support, reports and other adaptive learning products to improve the efficacy of the service.

Security

Waggle's policy indicates that it takes security seriously and to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, In addition, Waggle's policy explains that it has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure personal information, including appropriate data breach response. Lastly, Waggle notes that it attempts to comply with all the requirements of COPPA and does not collect personal information directly from children, but directly from school administrators or teachers when they create an account for a child with a classroom code.

Compliance

The terms of Waggle state they attempt to comply with all the requirements of COPPA and does not collect personal information directly from children, but only from school administrators or teachers when they create an account for a child with a classroom code. Waggle's terms state they are under the direct control of the educational institution it works with in respect to the use and maintenance of educational records and student education records will be kept confidential and will not be disclosed to third parties. A parent or guardian can contact their child’s school to review any personal information regarding their children that the school administrator or teacher provided to Waggle. However, Waggle's terms do not disclose how verifiable parental consent should be obtained.

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 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: 80%

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.
  • 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.
  • Unclear whether this product supports social or federated login.
  • 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: 65%

What rights do I have to the data?

  • Users can create or upload content.
  • Unclear whether users retain ownership of their data.
  • Processes to access and review user data are available.
  • Processes to modify inaccurate data are available.
  • Unclear whether the product provides a data-retention policy.
  • 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.
  • 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: 55%

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.
  • User information can not 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.
  • Data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 60%

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.
  • User-created content is not filtered for personal information before being made publicly visible.
  • Social interactions between users are not moderated.
  • Social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 85%

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 not displayed.
  • Data are not 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.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 85%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected online.
  • Not 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.
  • 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.
  • Unclear whether this product provides notification of a contract or additional rights.
  • Vendor is designated as a school official.
  • Parental consent obligations are transferred 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.