Adobe Spark is an integrated web and mobile solution that enables everyone, especially teachers and their students of all ages to easily create and share impactful visual stories. Adobe Spark provides a free, premium, and education version of its product with two different account types: an Adobe ID, or an Enterprise or Federated ID. The account and content of Adobe IDs are owned and controlled by the student, not the school and are better suited to higher education or adult students over 18 years of age. The Enterprise or Federated ID accounts and content are owned and controlled by the school, not the student, and they are required if used by primary or secondary schools with students in K-12 under 18 years of age.
Adobe Spark's terms state they may market, track, and profile students with Adobe IDs, but these features are turned off by default for Enterprise or Federated ID accounts. Adobe's terms state they provide reasonable administrative, technical, and physical security controls to protect a user’s personal information and content. The terms state users must be 13 or older to register for an individual Adobe ID. Lastly, the terms state schools that use the primary and secondary education product are required to register an enterprise-level Adobe ID for a child under 13, but only after obtaining express parental consent.
Adobe Spark can be accessed through its website and supports three different story applications:
Spark Video lets users turn their story into a captivating animated narrated video in just minutes and is available for download at the iOS App Store.
Spark Page turns stories into modern, professional, attention-grabbing web pages and is available for download at the iOS App Store.
Additionally, other policies used for this evaluation include:
- Student Policy
- Adobe Spark– A Guide for Schools & Educators
- K-12 (Primary and Secondary) Education Named User Additional Terms
- California Consumer Privacy Rights
- Guidelines for law enforcement seeking customer data
- Adobe Cloud Services Compliance Overview
- Adobe marketing and advertising practices
- Cookies Policy
- Opt-Out Policy
The terms state that Adobe Spark EDU provides interactive features for users to login and engage with social media sites, such as Facebook, Twitter, or Google. If users use these features, these sites may send Adobe Spark personal information about a user. Schools can also block access to Behance which is a platform that allows users to showcase and discover creative work. Further, Internet image search and Adobe Stock are turned off in Adobe Spark by default for Enterprise or Federated ID accounts. In addition, Adobe Spark allows users to post comments, upload pictures, or submit content which may be publicly available to others. Adobe recommends users be careful when they share their personal information with others and do not share anything they wouldn’t want publicly known unless they are sure they have control over who sees what they post. Lastly, the terms state users are responsible for determining the privacy limitations that are placed on their content and for applying the appropriate level of access to their content. If users do not choose an access level to apply to their content, Adobe Spark may default to its most permissive setting.
Adobe Spark's terms state they may market, track, and profile students with Adobe IDs, but these features are turned off by default for Enterprise or Federated ID accounts. However, the terms state Adobe does not share personal information about users with third parties for their own marketing purposes unless the consumer agreed to that sharing. Lastly, the terms also state Adobe will not sell student data from any type of student account to third parties and will not use personal information in student records to target advertising to any type of account.
Adobe's terms state they provide reasonable administrative, technical, and physical security controls to protect a user’s personal information and content. The terms also state users' personal information and files are stored on Adobe’s servers and they support encryption of personal information while in transit and at rest. Lastly, Adobe's terms state they will notify the student or school in accordance with the relevant breach notification law.
Adobe Spark provides a free, premium, and education version of its product with two different account types: an Adobe ID, or an Enterprise or Federated ID. The account and content of Adobe IDs are owned and controlled by the student, not the school and are better suited to higher education or adult students over 13 years of age. The Enterprise or Federated ID accounts and content are owned and controlled by the school, not the student, and they are required if used by primary or secondary schools with students in K-12 under 18 years of age.
The terms state Adobe cannot agree to act as a ‘school official’ for FERPA purposes as the user agreement is with the individual student, not with the school. However, Adobe's terms state they will respond to data access, correction, and deletion requests about user account information made by an authenticated student. In addition, students can self-access, correct, delete, and export their own stored content at any time.
Enterprise or Federated ID
The terms state Adobe contractually agrees to act as ‘school official’ for FERPA purposes, and to secure student data accordingly. As a data processor for the school, Adobe's terms state they give schools the tools they need to promptly respond to account data access, correction, and deletion requests submitted to them by students or their parents. However, only schools, not students, are empowered to access, correct, and delete student accounts and stored content.
Educators should be aware the FTC’s guidance indicates that an operator such as Adobe acting as a ‘school official’ does not need to obtain direct consent from parents of students using the service—even if they are under the age of 13. COPPA allows schools to act as either as an intermediary for parental consent or “the parent’s agent in the process of collecting personal information online from students in the school context,” where the operator collects users’ personal information only for the use and benefit of the school.
Every privacy rating includes an overall score. A higher score (up to 100%) means the product provides more transparent privacy policies with better practices to protect user data. The score is best used is as an indicator of how much additional work a person will need to do to make an informed decision about a product.
|Basic Score||Full Score|
The privacy evaluation process summarizes the policies of an application or service into concern categories based on a subset of evaluation questions that can be used to quickly identify particular practices of a vendor’s policies. These concerns are composed of evaluation questions that can be used to calculate scores relative to that concern.
|Concern||Basic Score||Full Score|
|Data Collection: Protecting personal information||83||60|
|Data Sharing: Protecting data from third parties||100||85|
|Data Security: Protecting against unauthorized access||67||85|
|Data Rights: Controlling rights to data||88||95|
|Data Sold: Preventing sale of data||75||35|
|Data Safety: Promoting responsible use||67||75|
|Ads & Tracking: Prohibiting the exploitation of users' decision making process||86||80|
|Parental Consent: Protecting children’s personal information||100||65|
|School Purpose: Following student data privacy laws||100||50|
|Individual Control: Controlling data use||NA||45|
Each statute or regulation is associated with one or more evaluation questions. As such, we can calculate scores for each statute or regulation using only those questions associated with the statute or regulation. Each specific statute or regulation's score serves as an indirect proxy indicating the likelihood of the application or service satisfying all of its compliance obligations.
|Statute||Basic Score||Full Score|
|California Online Privacy Protection Act (CalOPPA)||93||77|
|Children's Online Privacy Protection Act (COPPA)||86||70|
|Family Educational Rights and Privacy Act (FERPA)||94||61|
|Student Online Personal Information Protection Act (SOPIPA)||92||69|
|General Data Protection Regulation (GDPR)||90||72|
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Privacy policies do not indicate a change log or past policy version is available.
1.2: Policy Notice
- Users are notified if there are any material changes to the policies.
- Privacy policies indicate the method used to notify a user when policies are updated.
1.3: Policy Changes
- Users are notified prior to any material changes to the policies.
- Changes to the policies are effective immediately and continued use of the product indicates consent.
1.4: Policy Coverage
- Privacy policies indicate the products that are covered by the policies.
1.5: Privacy Contact
1.6: Policy Principles
- Privacy policies do indicate privacy principles, layered notices, or a table of contents.
1.7: Policy Language
- Privacy policies are available in multiple languages.
1.8: Intended Use
- Intended for children under 13.
- Intended for teens.
- Intended for adults over 18.
- Intended for parents or guardians.
- Intended for students.
- Unclear whether intended for teachers.
2: Focused Collection
2.1: Data Collection
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Unclear whether this product collects geolocation data.
- Unclear whether this product collects biometric or health data.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are not collected.
- Data is automatically collected.
2.2: Data Source
- Personal information or education records are collected from preK-12 students.
- Personal information from children under 13 years of age is collected.
2.3: Data Excluded
- Unclear whether specific types of personal information excluded from collection.
2.4: Data Limitation
- Collection or use of data is limited to product requirements.
3: Data Sharing
3.1: Data Shared With Third Parties
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
3.2: Data Use by Third Parties
- The purpose for sharing a user's personal information with third parties is indicated.
- Data are shared for analytics.
- Unclear whether data are shared for research and/or product improvement.
- Personal information is not shared for third-party marketing.
3.3: Data Not Shared With Third Parties
- Unclear whether there are specific categories of information that are not shared with third parties.
3.4: Data Sold to Third Parties
- Personal information is not sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Personal information about users is obtained from third parties.
3.6: Third-Party Links
- Unclear whether links to third-party external websites are age-appropriate.
3.7: Third-Party Data Access
- Unclear whether third parties are authorized to access a user's information.
3.8: Third-Party Data Collection
- Personal information of users is collected by a third party.
3.9: Third-Party Data Misuse
- Unclear whether personal information can be deleted from a third party.
3.10: Third-Party Service Providers
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
- The categories of third parties that receive data are indicated.
3.12: Third-Party Policies
- Links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
- Company may combine data with additional data from third-party sources.
- Unclear whether data shared with third parties can be combined with other data.
3.14: Third-Party Authentication
- Third-party login is supported.
- Personal information from third-party login providers is collected.
- Personal Information is shared with third-party login providers.
3.15: De-identified or Anonymized Data
- 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.
3.16: Third-Party Contractual Obligations
- Contractual limits are placed on third-party data use.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
4: Respect for Context
4.1: Data Use
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
4.2: Data Combination
- Unclear whether this product treats combined information as personally identifiable information (PII).
4.3: Data Notice
- Unclear whether notice is provided if the context in which data are collected changes.
4.4: Data Changes
- Unclear whether consent is obtained if the practices in which data are collected change.
4.5: Policy Enforcement
- Accounts may be terminated if users engage in any prohibited activities.
5: Individual Control
5.1: User Content
- Users can create or upload content.
5.2: User Consent
- Opt-in consent is requested from users at the time personal information is collected.
5.3: Remedy Process
- A grievance or remedy mechanism is available for users to file a complaint.
5.4: Data Settings
- Users can control the use of their information through privacy settings.
5.5: Data Disclosure
- Users can opt out from the disclosure or sale of their data to a third party.
- 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.
5.6: Intellectual Property
- Users retain ownership of their data.
- A copyright license is claimed to data or content collected from a user.
- Unclear whether any copyright license to a user's data is limited in scope or duration.
6: Access and Accuracy
6.1: Data Access
- Processes to access or review user data are available.
- Methods are available to restrict who has access to data.
- Processes to review student data are available for the school, parents, or students.
6.2: Data Integrity
- Unclear whether the company attempts to maintain the accuracy of data they collect.
6.3: Data Correction
- Processes to modify data are available for authorized users.
- Processes for the school, parents, or students to modify inaccurate student information are available.
- The time period for the company to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- Exceptions to the data retention policy exist.
6.5: Data Deletion
- Data are deleted when no longer necessary.
- A user's data are deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Processes for authorized users to delete data are available.
- The time period for the company to delete data is indicated.
6.6: Data Portability
- Processes to download user data are available.
- Unclear whether a user can assign an authorized account manager or legacy contact.
7: Data Transfer
7.1: Data Handling
- User information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
- Notice is provided to users if the company assigns its rights or delegates its duties to another company.
- Unclear whether users are notified if their information is transferred to a third party.
7.2: Transfer Request
- Unclear whether user information can be deleted prior to its transfer to a third party.
7.3: Onward Contractual Obligations
- Unclear whether third-party transfers are contractually required to use the same privacy practices.
8.1: User Identity
- A user's identity is verified with additional personal information.
8.2: User Account
- Account creation is required.
- Managed accounts are available.
- Multi-factor account protection is available.
8.3: Third-Party Security
- Third-parties with access to information are required to provide the same security protections as the company.
8.4: Data Confidentiality
- Reasonable security practices are used to protect data.
- Employee or physical access to user information is limited.
8.5: Data Transmission
- All data in transit are encrypted.
8.6: Data Storage
- Unclear whether all data are stored in an encrypted format.
- The company is clear what jurisdiction a user's personal information is subject to.
8.7: Data Breach
- Notice is provided in the event of a data breach.
8.8: Data Oversight
- Data-privacy and/or security-compliance audits are performed.
9: Responsible Use
9.1: Social Interactions
- 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.
9.2: Data Visibility
- Personal information can be displayed publicly.
- Users can control how their data are displayed to others.
9.3: Monitor and Review
- User-created content is reviewed, screened, or monitored by the company.
- User-created content is filtered for personal information before being made publicly visible.
- Social interactions between users are moderated.
- Unclear whether social interactions of users are logged.
9.4: Report Content
- Users cannot filter or block inappropriate content.
- Users can report abuse or cyberbullying.
9.5: Internet Safety
- The company provides links to resources that support safe and appropriate social interactions.
10.1: Vendor Communications
- A user can receive service- or administrative-related communications from the company.
10.2: Traditional Advertising
- Traditional or contextual advertisements are displayed.
10.3: Behavioral Advertising
- Personalised advertising is not displayed.
10.4: Ad Tracking
- 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.
10.5: Filtered Advertising
- Ads displayed to children are filtered for inappropriate content.
10.6: Marketing Communications
- The company can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Company does not respond to "Do Not Track" or other opt-out mechanisms.
- The company does provide a method for users to opt-out from third-party tracking.
11.1: Children Under 13
- 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.
- Unclear whether this product restricts or prohibits account creation for users under 13 years of age.
11.2: Students in K–12
- Product is 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.
11.3: Parental Consent
- Parental consent is required before personal information is collected or disclosed.
- 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.
- Unclear whether this product deletes children's personal information if collected without parental consent.
- Parental consent notice and method for submission are provided.
- Parental consent obligations are transferred to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing the policies is indicated.
- A user is required to waive the right to a jury trial, or settle any disputes by arbitration.
- A user is required to waive the right to join a class action lawsuit.
- A company will disclose personal information to law enforcement.
- Unclear whether the company has signed a privacy pledge or received a privacy certification.
11.6: International Laws
- A user's data are subject to International data transfer or jurisdiction laws.
- The company has indicated it is a Data Controller or Data Processor.