Amazon describes its Alexa product as allowing users to instantly connect to Alexa to play music, control your smart home, and get information, news, weather, and more using just your voice. For Alexa, Amazon's policy states that it will store user messages in the cloud so that they’re available on the user's Alexa App and select Alexa Enabled Products. Amazon's policy explains that it will gather personal information, and the information it learns from customers helps them personalize and continually improve the user's Amazon experience. While the policy describes an account for the initial setup, for "hands free" devices, like the Amazon Echo, a user can access Alexa by saying the wake word (Alexa, Echo, Amazon, or Computer). The policy indicates that parental controls are available, and parents can add or update certain information.
Amazon's policy explains that it will gather personal information, and the information it learns from customers helps them personalize and continually improve the user's Amazon experience. For example, the Echo Look device uses photos to recommend new garments that will pair well with the tops and bottom the user wore. In order to receive recommendations, the photo must be taken with the Echo Look device and contain a visible outfit with a top and bottom (they can't currently provide pairing recommendations for dresses). With regard to third parties, Amazon's policy states that they do not have access to, or control over, cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by their Privacy Notice or this Interest-Based Ads page.
However, Amazon's policy explains that it intends transparency in that a user can tell when a third party is involved, and it intends to minimize sharing in that it shares customer information related to those transactions with that third party. Also, Amazon's policy states that it does not provide any personal information to advertisers or to third party sites that display interest-based ads. Third party providers have access to personal information needed to perform their functions, but may not use it for other purposes. Advertising preferences and customer communication preferences are available to adjust settings for personal information.
For Amazon Alexa products, the policy states that users provide their phone number when registering for Alexa Communication. For security purposes, the policy notes that Amazon will verify this number by sending the user an SMS message (carrier charges may apply). The policy explains that other users who know the user's contact details will be able to contact them using Alexa Communication, and that registration name and contact details may be used to identify the user to other users, and that the user's phone number also may be displayed as a caller ID on outbound calls. While the policy describes an account for the initial setup, for "hands free" devices, like the Amazon Echo, a user can access Alexa by saying the wake word (Alexa, Echo, Amazon, or Computer). For other devices, like certain Fire tablets, the policy details that a person can access Alexa by pressing a button. Amazon's policy states that it works to protect the security of user information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information the user inputs.
Amazon's policy notes that they offer some services intended for children, and in some cases they may know a child is using the services (for example, when using a child profile). In these situations, the policy notes that children may share and Amazon may collect personal information that requires verifiable parental consent under the Children's Online Privacy Protection Act (collectively, "Child Personal Information"). However, its policy states that Amazon.com does not sell products for purchase by children, they only sell children's products for purchase by adults. If a user is under 18, the policy insists that user may use Amazon.com only with the involvement of a parent or guardian. In addition, by default, approval will be required for each voice purchase from Amazon through a kid skill before the purchase will be completed. Parents can allow purchases in kid skills without additional approval by changing this default setting in their Alexa app.
Further, Amazon's policy reserves the right (but not the obligation) to remove or edit such content, but also notes that it does not regularly review posted content. The policy indicates that parental controls are available, and parents can add or update certain information. However, Amazon notes that when a user updates information, it usually keeps a copy of the prior version for its records. Finally, the policy details that the company will use child personal information to provide and improve products and services, including personalizing offerings and recommendations for children, communicating information, enforcing parental controls, and giving parents visibility into how their children use products and services.
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||25||40|
|Data Sharing: Protecting data from third parties||75||75|
|Data Security: Protecting against unauthorized access||33||35|
|Data Rights: Controlling data use||88||55|
|Data Sold: Preventing sale of data||75||30|
|Data Safety: Promoting responsible use||38||40|
|Ads & Tracking: Prohibiting the exploitation of users' decision making process||50||60|
|Parental Consent: Protecting children’s personal information||67||70|
|School Purpose: Following student data privacy laws||0||0|
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)||75||73|
|Children's Online Privacy Protection Act (COPPA)||63||56|
|Family Educational Rights and Privacy Act (FERPA)||67||38|
|Student Online Personal Information Protection Act (SOPIPA)||62||46|
|General Data Protection Regulation (GDPR)||71||52|
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Privacy policies indicate a changelog 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
- Unclear whether users are notified prior to any material changes to the policies.
- Changes to the policies are not effective immediately and continued use of the product requires additional consent.
1.4: Policy Coverage
- Privacy policies indicate the products that are covered by the policies.
1.5: Policy Contact
1.6: Policy Principles
- Privacy policies do indicate any privacy principles, layered notices, or a table of contents.
1.7: Policy Language
- Privacy policies are not available in multiple languages.
1.8: Intended Use
- Intended for children under 13.
- Unclear whether intended for teens.
- Intended for adults over 18.
- Intended for parents or guardians.
- Unclear whether 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.
- Geolocation data are collected.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is collected.
- Unclear whether free or reduced lunch status is collected.
2.2: Data Source
- Unclear whether personal information or education records are collected from preK-12 students.
- Personal information from children under 13 years of age is collected online.
2.3: Data Exclusion
- Specific types of personal information are not collected.
2.4: Data Limitation
- Unclear whether the 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.
- Data are shared for research and/or product improvement.
- Data are shared for third-party advertising and/or marketing.
3.3: Data Not Shared With Third Parties
- Specific categories of information are not shared with third parties.
3.4: Data Sold to Third Parties
- Data are not sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Personal information from users is acquired 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
- 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 if found to be misused.
3.10: Third-Party Service Providers
- Data are shared with third-party service providers.
- The roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
- The categories of third parties that receive personal information are indicated.
3.12: Third-Party Policies
- Unclear whether links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
- Data can be combined with data from third-party sources.
- Unclear whether data shared with third parties can be combined by third parties for their own purposes.
3.14: Third-Party Authentication
- Unclear whether this product supports social or federated login.
- Unclear whether personal information from social or federated login providers is collected.
- Unclear whether personal Information is shared with social or federated login providers.
3.15: De-identified or Anonymized Data
- Unclear whether user information is shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification 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 deidentified information.
4: Respect for Context
4.1: Data Use
- Use of information is not limited to the purpose for which it was collected.
- The purpose for which data atr collected is indicated.
4.2: Data Combination
- Unclear whether this product treats combined information as personally identifiable information (PII).
4.3: Data Notice
- Notice is provided if the context in which data are collected changes.
4.4: Data Changes
- 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
- Unclear whether opt-in consent is requested from users at the time personal information is collected.
5.3: Remedy Process
- Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
5.4: Data Settings
- Users can control 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 for commercial purposes.
- Notice is not provided in the event the vendor receives a government or legal request for a user’s information.
5.6: Intellectual Property
- Unclear whether users retain ownership of their data.
- A copyright license is claimed to data or content collected from a user.
- Any copyright license to a user's data is limited in scope or duration.
- Unclear whether notice is provided to users when their content is removed or disabled because of an alleged copyright violation.
6: Access and Accuracy
6.1: Data Access
- Processes to access and review user data are available.
- Permissions, roles, or access controls are available to restrict who has access to data.
- Processes to review data are available for the school, parents, or students.
6.2: Data Integrity
- Unclear whether the vendor maintains the accuracy of data they collect.
6.3: Data Correction
- Processes to modify inaccurate data are available.
- Processes for the school, parents, or students to modify data are available.
- Unclear whether the time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- Unclear whether the retention time period of a user's data can be changed upon a valid inspection request.
6.5: Data Deletion
- Unclear whether this product deletes data when no longer necessary.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Unclear whether a user can delete all their data.
- Processes for the school, parents, or students to delete data are available.
- Unclear whether the time period for the vendor to delete data is indicated.
6.6: Data Portability
- Unclear whether this product provides users the ability to download their data.
- 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.
- Unclear whether notice is provided to users if the vendor 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
- Unclear whether this product requires account creation.
- Unclear whether parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
8.3: Third-Party Security
- Third-party contractual security protections are required.
8.4: Data Confidentiality
- Industry best practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
8.5: Data Transmission
- All data in transit are encrypted.
8.6: Data Storage
- Unclear whether this product encrypts all data at rest.
- Unclear whether personal information of users is stored with a third party.
8.7: Data Breach
- Unclear whether this product provides notice in the event of a data breach.
8.8: Data Oversight
- Unclear whether this product performs data-privacy and security-compliance audits.
9: Responsible Use
9.1: Social Interactions
- Unclear whether this product supports interactions between trusted users and/or students.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
9.2: Data Visibility
- Personal information is displayed publicly.
- Unclear whether this product allows users to control how their data are displayed.
9.3: Monitor and Review
- 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.
9.4: Report Content
- Users can filter or block inappropriate content.
- Unclear whether users can report abuse or cyberbullying.
9.5: Internet Safety
- The vendor provides links to tools or processes that support safe and appropriate social interactions.
10.1: Vendor Communications
- A user can receive service- or administrative-related communications from the vendor.
10.2: Traditional Advertising
- Traditional or contextual advertisements are displayed.
10.3: Behavioral Advertising
- Behavioral or targeted advertising is displayed.
10.4: Ad Tracking
- 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.
10.5: Filtered Advertising
- Children do not receive any inappropriate advertisements.
10.6: Marketing Communications
- 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.
10.8: Do Not Track
- Unclear whether this product responds to Do Not Track or other opt-out mechanisms.
- The vendor does provide a method for users to opt-out from third-party tracking.
11.1: Children Under 13
- Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- Account creation is restricted for users under 13 years of age.
- Vendor does restrict in-app purchases for users under 13 years of age.
- Unclear whether the vendor participates in an FTC-approved COPPA safe harbor program.
11.2: Students in K–12
- Unclear whether this product is 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.
- Unclear whether this product designates the vendor as a school official.
11.3: Parental Consent
- 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.
- 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.
- The vendor can use collected information to support the “internal operations” of the product.
- COPPA parental consent exceptions are indicated.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.
- Unclear whether this product transfers parental consent obligations to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing any dispute 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 vendor will disclose personal information to law enforcement.
- Unclear whether the vendor has signed a privacy pledge or received a privacy certification.
11.6: International Laws
- Unclear whether a user's data are subject to International data transfer or jurisdiction laws, such as the GDPR.
- Unclear whether the vendor has indicated it is a Data Controller or Data Processor.