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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.
  • Interactions, behaviors, or usage analytics data are collected.
  • Unclear whether this product collects sensitive data.
  • Data is automatically 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 data are indicated.
  • Data are shared for analytics.
  • Data are shared for research and/or product improvement.
  • Third-party services are used to support the product.
  • The roles of third-party service providers are indicated.
  • Unclear whether this product supports third-party 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.
  • Managed accounts are available.
  • Unclear whether multi-factor account protection is available.
  • 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.
  • All data in transit are encrypted.
  • All data are stored in an encrypted format.
  • 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 or review user data are available.
  • Processes to modify data are available for authorized users.
  • Unclear whether the product provides a data-retention policy.
  • Processes for authorized users to delete data are available.
  • A user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • 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: 55%

Is the data sold?

  • Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
  • 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 that is shared is shared in an anonymous or de-identified format.
  • Unclear whether the company describes their de-identification process of user information.
  • 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: 60%

How safe is this product?

  • Users can interact with trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information must be shared for social interactions.
  • Personal information can be displayed publicly.
  • Users can control how their data are displayed to others.
  • User-created content is not reviewed, screened, or monitored by the company.
  • 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?

  • Personal information is not shared for third-party marketing.
  • Traditional or contextual advertisements are displayed.
  • Personalised advertising is not displayed.
  • Data are not collected by third-parties for their own purposes.
  • Users's information is not used 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.
  • Users can opt out of contextual, or personalised 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.
  • Not 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 provide a section, heading, or separate policy for children in their policies.
  • Parental consent is required before personal information is collected or disclosed.
  • 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: 75%

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.
  • Processes to enter education records into the product are described.
  • Unclear whether additional rights or protections may be provided with an additional school contract.
  • Company is designated as a school official.
  • Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 65%

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.
  • 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.
  • Consent is not obtained if the practices in which data are collected change.
  • Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
  • Users can request to know what personal information has been shared with third parties.
  • Notice is not 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.