Apple Siri is a virtual assistant that is part of Apple's iOS, watchOS, macOS, and tvOS operating systems. The assistant uses voice queries and a natural-language user interface to answer questions, make recommendations, and perform actions by delegating requests to a set of Internet services. Apple’s terms state that protecting children is an important priority for everyone at Apple. Apple believes in transparency and giving parents the information they need to determine what is best for their child. In addition, Apple states Siri searches and requests are associated with a unique identifier and not an Apple ID — so personal information is not gathered to sell to advertisers or other organizations. Apple's terms state that security and privacy are fundamental to the design of all Apple hardware, software, and services. Lastly, Apple's terms state they understand the importance of taking extra precautions to protect the privacy and safety of children using Apple products and services.
Additionally, other relevant policies used for this evaluation include:
- Privacy Principles
- Approach to Privacy
- Family Privacy Disclosure for Children
- Apple Media Services Terms and Conditions
- iCloud Terms and Conditions
- iCloud Security Overview
- iOS Security Guide
- Your California Privacy Disclosures
Apple’s terms state that protecting children is an important priority for everyone at Apple. Apple believes in transparency and giving parents the information they need to determine what is best for their child. The terms state Apple works hard to offer controls for parents that are intuitive and customizable. By creating an Apple ID for their child, a parent enables them to enjoy the same Family Sharing features as the parent and other family members. A child's Apple ID allows them to share music, movies, TV shows, books, applications, photos, calendars, location data and use Siri to ask questions and complete tasks with parents and their family. A child is also able to have their own personalized Apple ID experience using all of the services and content available to an Apple ID account holder.
However, parents should be aware that their child may share information with others depending on the Apple features and services that he or she uses, that may include their child’s name and contact information. Apple's terms state they offer interactive services which allow users to post content to share publicly and that personal information and content users share may be visible to other users and can be read, collected, or used by them. Lastly, the terms state there may be times when parents want to limit their child's access to certain types of content or resources available to the rest of the Family. To help parents manage their child's access to Apple ID services and features, Apple offers a few different sets of controls for parents that include Restrictions, Screen Time, and Family Sharing.
Apple's terms state they believe privacy is a fundamental human right, and build privacy and security into all their products from the ground up, including their apps and services. When a parent creates an Apple ID, the terms state Apple may collect a variety of information, including their name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information and credit card information. In addition, when a parent creates an Apple ID for their child, Apple may collect device identifiers, cookies, IP addresses and the geographic locations and time zones in which his or her Apple device is used. In addition, Apple states Siri searches and requests are associated with a unique identifier and not an Apple ID — so personal information is not gathered to sell to advertisers or other organizations. Apple states users can reset that identifier at any time by turning Siri off and back on, effectively restarting their relationship with Siri which will delete the user data associated with the Siri identifier.
The terms state personal information will only be shared by Apple to provide or improve their products, services and advertising by third party apps. Personal information will not be shared with third parties for their own marketing purposes. However, Apple may use, transfer and disclose non-personal information for any purpose. This means that Apple’s websites, online services, interactive applications, email messages, and third-party app advertisements may use tracking technologies to help Apple better understand user behavior, tell the company which parts of their websites people have visited, and facilitate and measure the effectiveness of advertisements and searches. In third-party apps, users may see ads based on other information, but a child's Apple ID may still be able to receive non-targeted advertising on those devices.
Apple's "Limit Ad Tracking" control is enabled by default for all devices associated with a child's Apple ID, to ensure they do not receive targeted advertising from third-party apps. In addition, third-party apps in the Kids Category of the App Store are prohibited from serving behavioral advertisements to children. Lastly, Apple's terms state they do not track their customers over time and across third party websites to provide targeted advertising, and do not take any decisions involving the use of algorithms or profiling that would significantly affect users.
Apple's terms state that security and privacy are fundamental to the design of all Apple hardware, software, and services. Apple takes an integrated approach to ensure that every aspect of the user's experience has security and privacy built in. The terms state that when personal data is stored by Apple, they use computer systems with limited access housed in facilities using physical security measures. Apple's terms state they communicate privacy and security guidelines to all Apple employees and strictly enforce privacy safeguards within the company.
Additionally, the terms state iCloud is built with industry-standard security practices and employs strict policies to protect data. iCloud secures user data by encrypting it when it’s sent over the Internet, storing it in an encrypted format when kept on the server, and using secure tokens for authentication. The terms specify this means that user data is protected from unauthorized access both while it is being transmitted to devices and when it is stored in iCloud. iCloud uses a minimum of 128-bit AES encryption, and never provides encryption keys to any third parties. Apple retains the encryption keys in our own data centers and iCloud also stores Apple ID passwords and credentials in such a way that Apple cannot read or access them.
Lastly, Apple's terms state that end-to-end encryption requires that users have two-factor authentication turned on for their Apple ID. Keeping software up-to-date and using two-factor authentication are the most important things that users can do to maintain the security of their devices and data.
The terms state that in order to comply with the Children's Online Privacy Protection Act (COPPA), which govern the online collection of data from children, Apple may take additional steps to verify that the user granting permission for the creation of a child's Apple ID is his or her parent or legal guardian. Accordingly, parents will be asked to verify their current iTunes, iCloud or Apple Store payment method. Depending on the payment method, this may be done by methods such as the security code from a credit card or a round-trip SMS verification. The terms state Apple requests this information so that they may verify a parent's identity as the Family Organizer and obtain their consent to the collection of personal information from their child. If at any time a parent would like to access, correct or delete data associated with Family Sharing or their child's Apple ID, they should contact Apple.
Lastly, Apple's terms state it is important for parents to be aware that third-party apps may be collecting data about children. Parental consent does not apply to the data collection practices of any third parties. Third parties, including the developers of apps downloaded by any Family member and accessible by a child through Family Sharing, may collect, use, or disclose a child's information, and these third parties are responsible for obtaining separate verifiable consent. Apple's terms encourage parents to ask their child to check with them before they grant access to any of their personal information to third-party apps.
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||65|
|Data Sharing: Protecting data from third parties||100||90|
|Data Security: Protecting against unauthorized access||67||75|
|Data Rights: Controlling rights to data||88||95|
|Data Sold: Preventing sale of data||75||50|
|Data Safety: Promoting responsible use||83||50|
|Ads & Tracking: Prohibiting the exploitation of users' decision making process||86||70|
|Parental Consent: Protecting children’s personal information||100||75|
|School Purpose: Following student data privacy laws||0||0|
|Individual Control: Controlling data use||NA||60|
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||87|
|Children's Online Privacy Protection Act (COPPA)||88||77|
|Family Educational Rights and Privacy Act (FERPA)||81||62|
|Student Online Personal Information Protection Act (SOPIPA)||83||64|
|General Data Protection Regulation (GDPR)||90||74|
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.
- 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 not collected.
- Biometric or health data are collected.
- Interactions, behaviors, or usage analytics data are collected.
- Unclear whether this product collects sensitive data.
- Data is automatically 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.
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.
- 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
- Specific categories of information 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
- Links to third-party external websites are not 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.
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 not 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 not supported.
- Unclear whether personal information from third-party login providers is collected.
- Unclear whether 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.
- 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
- Combined information is treated 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 not 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.
- 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
- 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.
- Unclear whether 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
- Unclear whether 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
- 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
- Unclear whether this product provides notice 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 not 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.
- Unclear whether user-created content is filtered for personal information before being made publicly visible.
- Unclear whether social interactions between users are moderated.
- Unclear whether 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 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
- Unclear whether 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.
- Unclear whether 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.
- Account creation is restricted or prohibited for users under 13 years of age.
11.2: Students in K–12
- Unclear whether this 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.
- Unclear whether the 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.
- Children's personal information is deleted if collected without parental consent.
- Parental consent notice and method for submission are provided.
- 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 the policies is indicated.
- Unclear whether a user is required to waive the right to a jury trial, or settle any disputes by arbitration.
- Unclear whether 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.