Overview

Clever provides a platform for learning applications to connect with schools and school districts to have a central location to manage their technology. Clever does not directly provide social interactions through its services, but some elements enable schools to interact with parents, students, teachers and third party applications, for the benefit of the student’s education. In addition, Clever's terms say they collect personal information when a school administrator registers a school with Clever and non-personal usage information is collected automatically through use of the service. Clever's terms say they maintain strict administrative, technical and physical procedures to protect information stored in their servers. Lastly, Clever's terms say they consider student data that schools provide to be education records, as defined by the Family Educational Rights and Privacy Act (“FERPA”).

Clever can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Clever’s website, and iOS App Store. Additionally, other policies used for this evaluation include: Clever Additional Terms of Use for Schools, Clever Additional Terms for Parent Accounts, Privacy Principles, Security Principles, and Compliance Principles. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Clever does not directly provide social interactions through its services, but some elements enable schools to interact with parents, students, teachers and third party applications, for the benefit of the student’s education. The terms state that users are fully responsible for interactions with other users. Users can control their profile visibility, but it is unclear from the terms what information is visible on the profile.

Privacy

Clever's terms state they collect personal information when a school administrator registers a school with Clever and non-personal usage information is automatically collected through use of the service. Information collected may include a name, school name, school district, school email address and/or account name and password, phone number, message content, and information relating to the school's information systems. The type of student data Clever collects will depend on how the school uses the service and the learning applications which the school connects through the service.

Clever may maintain anonymized or aggregated data, including usage data, for analytics purposes. For example, Clever may use and share aggregate or anonymized data to study and improve the service, user functionality, and product offerings. Clever’s terms state they will never share or sell student data with third parties for marketing purposes or targeted advertising. In addition, Clever does not permit third party advertising networks to collect information about users’ use of the service over time and across websites for the purpose of serving targeted advertising.

Security

Clever's terms state they recommend users create strong passwords to access the service that use a combination of upper and lower case letters, numbers and symbols, and are not reused with any other service to avoid unauthorized use. Clever provides access controls to personal information on the service such as password credentials and two factor authentication. Clever's terms state they maintain strict administrative, technical and physical procedures to protect information stored in their servers. Contractors and third-party service providers who may have access to student data in the course of performing their services are subject to confidentiality and data security requirements. In addition, only those employees who require access to personal information to perform their job functions are provided access. Lastly, Clever uses industry-standard Secure Socket Layer (SSL) encryption technology to safeguard data in transit, while other security safeguards include: data encryption at rest, firewalls, and physical access controls to building and files.

Compliance

Clever's terms state they consider student data that schools provide to be education records, as defined by the Family Educational Rights and Privacy Act (“FERPA”). Clever states they treat student data as confidential and not to be used for any purpose other than to provide the services on the school's behalf, in accordance with contractual agreements with the school. Clever's terms state they do not knowingly collect any information from children under the age of 13 unless the school has obtained appropriate parental consent for the student to use the service. Because Clever collects and uses student data at the direction and under the control of a school, Clever relies on each school to provide appropriate notice to parents of the school's use of third party service providers such as Clever, and for the Schools to provide consent. Users should be aware that Clever requires them to contact the school directly in order to review, modify, or delete personal information.

Clever's terms require schools they contract with to provide each student with login credentials and confirm that it has obtained appropriate parental consents, before any student is permitted to access the service. If a student contacts Clever with a question about the service, Clever will collect personal information from that student only as necessary to respond to the student's request and direct the student to contact the student's school, and they will then delete or anonymize the personal data of the student after providing their response.

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 ScoreFull Score
Comprehensive Assessment9071

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.

ConcernBasic ScoreFull Score
Data Collection: Protecting personal information8360
Data Sharing: Protecting data from third parties10085
Data Security: Protecting against unauthorized access10090
Data Rights: Controlling rights to data8885
Data Sold: Preventing sale of data7575
Data Safety: Promoting responsible use6750
Ads & Tracking: Prohibiting the exploitation of users' decision making process9380
Parental Consent: Protecting children’s personal information10075
School Purpose: Following student data privacy laws10088
Individual Control: Controlling data useNA60

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.

StatuteBasic ScoreFull Score
California Online Privacy Protection Act (CalOPPA)9478
Children's Online Privacy Protection Act (COPPA)8871
Family Educational Rights and Privacy Act (FERPA)9375
Student Online Personal Information Protection Act (SOPIPA)9579
General Data Protection Regulation (GDPR)9772
The California Consumer Privacy Act (CCPA)9376

Privacy Policy Details

1: Transparency

1.1: Policy Version
  • Privacy policies do indicate a version or effective date.
  • Privacy policies 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
  • Users can contact the company about any privacy policy questions, complaints, or material changes to the policies.
1.6: Policy Principles
  • Privacy policies do indicate 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.
  • 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.
  • Unclear whether this product collects biometric or health data.
  • Interactions, behaviors, or usage analytics data are collected.
  • Sensitive data are 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
  • Specific types of personal information are excluded from collection.
  • Unclear whether specific types of collected information are excluded from the privacy policy.
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
  • 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
  • Unclear whether 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
  • 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
  • Unclear whether 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.
  • 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
  • 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
  • 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.
  • 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.
  • Unclear whether 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.
  • Unclear whether the time period for the company 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 in the event of a merge, acquisition, or bankruptcy.
  • Users are notified if their information is transferred to a third party.
7.2: Transfer Request
  • 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: Security

8.1: User Identity
  • Unclear whether 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
  • 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.
  • Unclear whether 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
  • Unclear whether 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.
  • Social interactions between users are not moderated.
  • Social interactions of users are logged.
9.4: Report Content
  • Unclear whether users can filter or block inappropriate content.
  • Unclear whether users can report abuse or cyberbullying.
9.5: Internet Safety
  • Unclear whether the company provides links to resources that support safe and appropriate social interactions.

10: Advertising

10.1: Company Communications
  • A user can receive service- or administrative-related communications from the company.
10.2: Traditional Advertising
  • Traditional or contextual advertisements are not 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.
  • User'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.
  • The company does provide promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
  • Unclear whether this product provides users the ability to 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.
  • Unclear whether the company provides a method for users to opt-out from third-party tracking.

11: Compliance

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
  • Product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Processes to enter education records into the product are described.
  • 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.
  • Children's personal information is deleted 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.
11.5: Certification
  • The company 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.
  • Unclear whether the company has indicated it is a Data Controller or Data Processor.