iCivics provides educational games such as Argument Wars to engage students in meaningful civic learning. They provide teachers well-written, inventive, and free resources that enhance their practice and inspire their classrooms. The terms state the service allows users to comment on content that has been uploaded to iCivics and the service takes reasonable measures to delete personal information from a user's postings before they are made publicly visible. In addition, the terms state the service does not sell personal information to third parties, but does not disclose whether personal information can be used for third-party marketing or behavioral advertising purposes. The terms disclose personal information is stored in a secure location, including on password controlled servers which are accessible only by designated employees who are trained in the proper handling of personal information. However, the terms do not disclose whether personal information is protected with reasonable security features such as encryption. Lastly, the terms disclose if a child under the age of 13 signs up for a user account they must first obtain parental approval and provide a parent's email address for confirmation.
personally identifying information that you provide is stored in a secure location
including on password controlled servers which are accessible only by designated employees who are trained in the proper handling of such personally identifying information
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||75||NA|
|Data Sharing: Protecting data from third parties||75||NA|
|Data Security: Protecting against unauthorized access||67||NA|
|Data Rights: Controlling data use||75||NA|
|Data Sold: Preventing sale of data||75||NA|
|Data Safety: Promoting responsible use||75||NA|
|Ads & Tracking: Prohibiting the exploitation of users' decision making process||50||NA|
|Parental Consent: Protecting children’s personal information||100||NA|
|School Purpose: Following student data privacy laws||0||NA|
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)||92||NA|
|Children's Online Privacy Protection Act (COPPA)||78||NA|
|Family Educational Rights and Privacy Act (FERPA)||83||NA|
|Student Online Personal Information Protection Act (SOPIPA)||65||NA|
|General Data Protection Regulation (GDPR)||82||NA|
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Did not evaluate whether 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
- Did not evaluate whether 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: Policy Contact
1.6: Policy Principles
- Privacy policies do indicate any privacy principles, layered notices, or a table of contents.
1.7: Policy Language
- Did not evaluate whether privacy policies are available in multiple languages.
1.8: Intended Use
- Intended for children under 13.
- Did not evaluate whether intended for teens.
- Did not evaluate whether intended for adults over 18.
- Did not evaluate whether intended for parents or guardians.
- Unclear whether intended for students.
- Did not evaluate 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.
- Did not evaluate whether this product collects geolocation data.
- Did not evaluate whether this product collects biometric or health data.
- Did not evaluate whether this product collects behavioral data.
- Did not evaluate whether this product collects sensitive data.
- Non-personally identifiable information is collected.
- Did not evaluate whether free or reduced lunch status is collected.
2.2: Data Source
- Did not evaluate whether personal information or education records are collected from preK-12 students.
- Did not evaluate whether this product collects personal information online from children under 13 years of age.
2.3: Data Exclusion
- Did not evaluate whether specific types of personal information are not collected.
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
- Did not evaluate whether the purpose for sharing a user's personal information with third parties is indicated.
- Did not evaluate whether data are shared for analytics.
- Did not evaluate whether data are shared for research and/or product improvement.
- Unclear whether data are shared for third-party advertising and/or marketing.
3.3: Data Not Shared With Third Parties
- Did not evaluate whether there are specific categories of information that 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
- Did not evaluate whether personal information from users is acquired from third parties.
3.6: Third-Party Links
- Did not evaluate whether third-party external websites are age-appropriate.
3.7: Third-Party Data Access
- Did not evaluate 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
- Did not evaluate 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
- Did not evaluate whether the categories of third parties that receive personal information are indicated.
3.12: Third-Party Policies
- Did not evaluate whether links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
- Did not evaluate whether data can be combined with data from third-party sources.
- Did not evaluate 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.
- Did not evaluate whether personal information from social or federated login providers is collected.
- Did not evaluate whether personal Information is shared with social or federated login providers.
3.15: De-identified or Anonymized Data
- Did not evaluate whether user information is shared in an anonymous or deidentified format.
- Did not evaluate 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.
- Did not evaluate whether contractual limits prohibit third parties from reidentifying deidentified information.
4: Respect for Context
4.1: Data Use
- Use of information is limited to the purpose for which it was collected.
- The purpose for which data atr collected is indicated.
4.2: Data Combination
- Did not evaluate whether this product treats combined information as personally identifiable information (PII).
4.3: Data Notice
- Did not evaluate whether notice is provided if the context in which data are collected change.
4.4: Data Changes
- Did not evaluate whether consent is obtained if the practices in which data are collected change.
4.5: Policy Enforcement
- Did not evaluate whether accounts may be terminated if users engage in any prohibited activities.
5: Individual Control
5.1: User Content
- Unclear whether 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
- Did not evaluate whether a grievance or remedy mechanism is available for users to file a complaint.
5.4: Data Settings
- Did not evaluate whether users can control their information through privacy settings.
5.5: Data Disclosure
- Did not evaluate whether users can opt out from the disclosure or sale of their data to a third party.
- Did not evaluate whether users can request to know what personal information has been shared with third parties for commercial purposes.
- Did not evaluate whether notice is provided in the event the vendor receives a government or legal request for a user’s information.
5.6: Intellectual Property
- Did not evaluate whether users retain ownership of their data.
- Did not evaluate whether a copyright license is claimed to data or content collected from a user.
- Did not evaluate whether any copyright license to a user's data is limited in scope or duration.
- Did not evaluate 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.
- Did not evaluate whether 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
- Did not evaluate 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.
- Did not evaluate whether the time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- Did not evaluate whether the retention time period of a user's data can be changed upon a valid inspection request.
6.5: Data Deletion
- Did not evaluate whether this product deletes data when no longer necessary.
- A user's data are deleted upon account cancellation or termination.
- Did not evaluate whether a user can delete all their data.
- Processes for the school, parents, or students to delete data are available.
- Did not evaluate whether the time period for the vendor to delete data is indicated.
6.6: Data Portability
- Did not evaluate whether this product provides users the ability to download their data.
- Did not evaluate 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.
- Did not evaluate whether notice is provided to users if the vendor assigns its rights or delegates its duties to another company.
- Did not evaluate whether users are notified if their information is transferred to a third party.
7.2: Transfer Request
- Did not evaluate whether user information can be deleted prior to its transfer to a third party.
7.3: Onward Contractual Obligations
- Third-party transfer is contractually required to use the same privacy practices.
8.1: User Identity
- Did not evaluate whether a user's identity is verified with additional personal information.
8.2: User Account
- Account creation is required.
- Parental controls or managed accounts are available.
- Did not evaluate whether two-factor account protection is available.
8.3: Third-Party Security
- Did not evaluate whether third-party contractual security protections are required.
8.4: Data Confidentiality
- Industry best practices are used to protect data.
- Employee or physical access to user information is limited.
8.5: Data Transmission
- Unclear whether this product encrypts all data in transit.
8.6: Data Storage
- Unclear whether this product encrypts all data at rest.
- Did not evaluate whether personal information of users is stored with a third party.
8.7: Data Breach
- Notice is provided in the event of a data breach.
8.8: Data Oversight
- Data-privacy and security-compliance audits are performed.
9: Responsible Use
9.1: Social Interactions
- Users can interact with trusted users and/or students.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
9.2: Data Visibility
- Personal information is not displayed publicly.
- Did not evaluate whether this product allows users to control how their data are displayed.
9.3: Monitor and Review
- User-created content is reviewed, screened, or monitored by the vendor.
- User-created content is filtered for personal information before being made publicly visible.
- Unclear whether social interactions between users are moderated.
- Did not evaluate whether social interactions of users are logged.
9.4: Report Content
- Did not evaluate whether users can filter or block inappropriate content.
- Did not evaluate 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
- Unclear whether this product displays traditional or contextual advertisements.
10.3: Behavioral Advertising
- Unclear whether this product displays behavioral or targeted advertising.
10.4: Ad Tracking
- 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.
10.5: Filtered Advertising
- Did not evaluate whether children may receive inappropriate advertisements.
10.6: Marketing Communications
- The vendor can send marketing messages.
- Did not evaluate whether this vendor provides promotional sweepstakes, contests, or surveys.
- Did not evaluate whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Did not evaluate whether this product responds to Do Not Track or other opt-out mechanisms.
- Did not evaluate whether the vendor provides 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.
- Did not evaluate whether this product restricts account creation for users under 13 years of age.
- Did not evaluate whether this product restricts in-app purchases for users under 13 years of age.
- Did not evaluate 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.
- Did not evaluate whether the product creates education records.
- Did not evaluate whether this product provides notification of a contract or additional rights.
- Did not evaluate whether this product designates the vendor as a school official.
11.3: Parental Consent
- Parental consent is required.
- Did not evaluate 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.
- Did not evaluate whether the vendor can use collected information to support the “internal operations” of the product.
- Did not evaluate whether this product discloses COPPA parental consent exceptions.
- Did not evaluate whether the vendor indicates FERPA parental consent exceptions.
- Did not evaluate whether this product discloses directory information.
- Did not evaluate whether this product transfers parental consent obligations to the school or district.
11.4: Legal Requirements
- Did not evaluate whether the legal jurisdiction that applies to the laws governing any dispute is indicated.
- Did not evaluate whether a user is required to waive the right to a jury trial, or settle any disputes by arbitration.
- Did not evaluate whether a user is required to waive the right to join a class action lawsuit.
- A vendor will disclose personal information to law enforcement.
- Did not evaluate whether the vendor has signed a privacy pledge or received a privacy certification.
11.6: International Laws
- Did not evaluate whether a user's data are subject to International data transfer or jurisdiction laws, such as the GDPR.
- Did not evaluate whether the vendor has indicated it is a Data Controller or Data Processor.