Overview
Bark continuously monitors online interactions to provide parents, guardians, and teachers with email and/or text alerts when potential online dangers (such as cyberbullying) or potential signs of trouble (such as depression) are identified in email or text messages and/or interactions with designated social media sites or websites involving registered children or students. Bark's terms require parents and teachers to authorize Bark to access, monitor, review, and store all online interactions and other communications to and from registered child and student accounts. Bark's terms state they may collect all personal and non-personal usage information provided by the registered child or student account that includes, but is not limited to first and last name, email address, contacts, connections, payments, messages, location information, and other communications.
In addition, Bark's terms state they have adopted technical and organizational measures to preserve and protect users' personal information that the service monitors from unauthorized use or access and from being altered, lost or misused. Lastly, the terms state users have the right to access, rectify, erase, block and oppose any processing of their personal data that Bark has collected.
Bark can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. In addition, Bark is available through the Google G-Suite Marketplace. The Privacy Policy and Terms of Use used for this evaluation can be found on Bark’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Terms of Service, and Bark School Monitoring Terms of Service. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
Bark's terms require parents and teachers to authorize Bark to access, monitor, review, and store all online interactions and other communications to and from registered child and student accounts. An educator, parent, or a school has the ability to filter or block inappropriate content or social interactions and determine whether abusive behavior, or cyberbullying has occurred.
Privacy
Bark's terms state they may collect all personal and non-personal usage information provided by the registered child or student account that includes, but is not limited to first and last name, email address, scontacts, connections, payments, messages, location information, and other communications. When users register for a Bark account they must also provide the names of their third-party services (such as Gmail, Microsoft Office 365, Facebook or Twitter) and the user name and password for each account to be connected to the Bark service for monitoring purposes.
The terms state Bark may allow third party service providers to place cookies on the service to provide behavioral advertising and to perform analytic or marketing functions where users are notified of them and have have provided consent. Furthermore, the terms state third parties may collect information about a user's online activities over time and across different websites when they use the services. However, the terms indicate that a user's personal information may be sold to third parties.
Lastly, the terms state Bark may provide de-identified user data on an anonymous aggregate basis to third party business partners, including for conducting academic research and surveys or commercial analytics, and to publish periodic sector or segmented information and reports about behavior patterns and tendencies of children and student's online behavior.
Security
Bark's terms state they have adopted technical and organizational measures to preserve and protect users' personal information that the service monitors from unauthorized use or access and from being altered, lost or misused. The terms also state Bark takes into account the technological state of art, the features of the information stored and the risks to which information is exposed. In addition, the terms state the service limits access to user data only to employees who need to know it to enable Bark to perform the services. However, the terms indicate that encryption of user data in transit or while at rest implemented. The terms state that if Bark learns of a security breach, then they will attempt to notify users electronically as soon as reasonably possible so that they can take appropriate steps.
The terms of Bark state the school or district is responsible for setting the default configuration of the services that controls the supervision and monitoring of activities, and determines the personal data to be monitored and collected from children and students. The setting of those configurations constitutes instructions for Bark to process user data on their behalf as necessary to provide the services. The level and degree of user data surveillance and monitoring is entirely under a school or district's control.
Compliance
The terms state users have the right to access, rectify, erase, block and oppose any processing of their personal data that Bark has collected. In addition, users can update, amend or delete their contact information at any time by visiting the settings page on the service. However, any requests to access, modify, or delete user information must be sent to the school or district because the terms state Bark will forward any such requests received by them to the respective school or district who is responsible for responding to any user requests.
The terms state the service is designed to be a tool for parents and others to use to facilitate safe online interactions for children. However, the terms state the service is neither designed nor intended to be attractive to children under the age of 13. While the Bark service includes analysis of online interactions by children, the terms state Bark does not knowingly collect data from children under the age of 13 without first receiving verified parental consent. Lastly, the terms state user data from students may include personally identifiable information from education records that are subject to FERPA and Bark is to be considered a "School Official" and will comply with FERPA.
Overall Score
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 | |
|---|---|---|
| Comprehensive Assessment | 79 | 63 |
Concerns
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 | 50 | 50 |
| Data Sharing: Protecting data from third parties | 75 | 80 |
| Data Security: Protecting against unauthorized access | 100 | 75 |
| Data Rights: Controlling rights to data | 88 | 80 |
| Data Sold: Preventing sale of data | 75 | 30 |
| Data Safety: Promoting responsible use | 100 | 80 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 33 | 45 |
| Parental Consent: Protecting children’s personal information | 100 | 80 |
| School Purpose: Following student data privacy laws | 100 | 70 |
Statutes
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 | 69 |
| Children's Online Privacy Protection Act (COPPA) | 76 | 62 |
| Family Educational Rights and Privacy Act (FERPA) | 83 | 64 |
| Student Online Personal Information Protection Act (SOPIPA) | 73 | 56 |
| General Data Protection Regulation (GDPR) | 86 | 69 |
Privacy Policy Details
1: Transparency
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
- Users are not 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
- Users can contact the vendor about any privacy policy questions, complaints, or material changes to the policies.
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.
- Intended for teens.
- Intended for adults over 18.
- Intended for parents or guardians.
- Intended for students.
- 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.
- Biometric or health data are collected.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is collected.
- Free or reduced lunch status is 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 online.
2.3: Data Exclusion
- Unclear whether specific types of personal information are not collected.
- Unclear whether specific types of collected information are excluded from the privacy policy.
2.4: Data Limitation
- Collection or use of data is not 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
- Unclear 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
- Personal information from users is acquired 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 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
- Links to privacy policies of third-party companies are not available.
3.13: Third-Party Data Combination
- Data cannot 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.
- Personal information from social or federated login providers is collected.
- 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 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
- Unclear whether 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
- A grievance or remedy mechanism is not 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.
- Users can request to know what personal information has been shared with third parties for commercial purposes.
- Notice is provided in the event the vendor receives a government or legal request for a user’s information.
5.6: Intellectual Property
- Users retain ownership of their data.
- Unclear whether 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.
- 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
- The vendor does not maintain 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.
- The retention time period of a user's data can be changed upon a valid inspection request.
6.5: Data Deletion
- Data are deleted when no longer necessary.
- A user's data are not deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Processes for the school, parents, or students to delete data are available.
- 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.
- 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: Security
8.1: User Identity
- 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.
- Unclear whether two-factor account protection is available.
8.3: Third-Party Security
- Unclear 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
- All data in transit are encrypted.
8.6: Data Storage
- All data at rest are encrypted.
- Unclear 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
- Unclear whether this product performs data-privacy and security-compliance audits.
9: Responsible Use
9.1: Social Interactions
- Users can interact with trusted users and/or students.
- Unclear whether 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 not displayed publicly.
- Users cannot 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.
- Social interactions between users are moderated.
- Social interactions of users are logged.
9.4: Report Content
- Users can filter or block inappropriate content.
- 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: Advertising
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
- 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.
- Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
- Unclear whether children may receive inappropriate advertisements.
10.6: Marketing Communications
- The vendor can send marketing messages.
- The vendor does provide promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
- Users cannot opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Vendor does not respond to Do Not Track or other opt-out mechanisms.
- Unclear whether the vendor provides a method for users to opt-out from third-party tracking.
11: Compliance
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 not restricted for users under 13 years of age.
- Unclear whether this product restricts 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
- Product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Product does create education records.
- Unclear whether this product provides notification of a contract or additional rights.
- Vendor is designated 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.
- Children's personal information is not deleted if collected without parental consent.
- Parental consent notice and method for submission are provided.
- Unclear whether the vendor can use collected information to support the “internal operations” of the product.
- COPPA parental consent exceptions are not indicated.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Directory information is not disclosed.
- Parental consent obligations are transferred 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.
11.5: Certification
- Unclear whether the vendor 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, such as the GDPR.
- The vendor has indicated it is a Data Controller or Data Processor.