Overview
Clubhouse: Drop-in audio chat can be accessed at the following locations: website and Apple App Store. The following 3 policies were used to evaluate Clubhouse: Drop-in audio chat: 1, 2, and 3. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
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 | 53 | NA |
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 | NA |
| Data Sharing: Protecting data from third parties | 75 | NA |
| Data Security: Protecting against unauthorized access | 17 | NA |
| Data Rights: Controlling rights to data | 88 | 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 | 33 | NA |
| Parental Consent: Protecting children’s personal information | 33 | NA |
| School Purpose: Following student data privacy laws | 50 | NA |
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 | NA |
| Children's Online Privacy Protection Act (COPPA) | 59 | NA |
| Family Educational Rights and Privacy Act (FERPA) | 61 | NA |
| Student Online Personal Information Protection Act (SOPIPA) | 58 | NA |
| General Data Protection Regulation (GDPR) | 50 | NA |
Privacy Policy Details
1: Transparency
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
- Did not evaluate whether users are notified if there are any material changes to the policies.
- Did not evaluate whether 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.
- Did not evaluate whether changes to the policies are effective immediately and continued use of the product indicates consent.
1.4: Policy Coverage
- Did not evaluate whether privacy policies indicate the products that are covered by the policies.
1.5: Policy Contact
- Did not evaluate whether users can contact the vendor about any privacy policy questions, complaints, or material changes to the policies.
1.6: Policy Principles
- Did not evaluate whether privacy policies 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
- Not 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.
- Not intended for students.
- Did not evaluate whether intended for teachers.
2: Focused Collection
2.1: Data Collection
- Personally identifiable information (PII) is collected.
- Did not evaluate whether 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.
- Did not evaluate whether this product collects non-personally identifiable information.
- 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.
- Did not evaluate 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
- 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.
- 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
- Did not evaluate whether 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
- Did not evaluate whether data are shared with third-party service providers.
- Did not evaluate whether 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
- Social or federated login is supported.
- 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
- Unclear whether 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
- Did not evaluate whether use of information is limited to the purpose for which it was collected.
- Did not evaluate whether the purpose for which data are 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
- Users can create or upload content.
5.2: User Consent
- Did not evaluate whether 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.
- Did not evaluate whether the school, parents, or students can review data.
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.
- Did not evaluate whether the school, parents, or students can modify data.
- Did not evaluate whether the time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
- Did not evaluate whether the product provides a data-retention policy.
- 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.
- Did not evaluate whether 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
- Did not evaluate whether third-party transfers are contractually required to use the same privacy practices.
8: Security
8.1: User Identity
- Did not evaluate whether 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.
- 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.
- Did not evaluate whether this product limits employee or physical access to user information.
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
- Unclear whether this product provides notice in the event of a data breach.
8.8: Data Oversight
- Did not evaluate 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.
- Did not evaluate whether users can interact with untrusted users, including strangers and/or adults.
- Did not evaluate whether profile information is shared for social interactions.
9.2: Data Visibility
- Personal information is displayed publicly.
- Did not evaluate whether this product allows users to control how their data are displayed.
9.3: Monitor and Review
- Did not evaluate whether user-created content is 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 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
- Did not evaluate whether the vendor provides links to tools or processes that support safe and appropriate social interactions.
10: Advertising
10.1: Vendor Communications
- Did not evaluate whether 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
- Did not evaluate whether children may receive inappropriate advertisements.
10.6: Marketing Communications
- Did not evaluate whether this vendor can send marketing messages.
- Did not evaluate whether this vendor provides promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
- Did not evaluate whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
- Did not evaluate whether this product provides users the ability to 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: Compliance
11.1: Children Under 13
- Did not evaluate whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
- Did not evaluate whether 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
- Unclear whether this product requires parental consent.
- Did not evaluate whether this product limits parental consent with respect to third parties.
- Did not evaluate whether this product allows parents to withdraw consent for the further collection of their child's information.
- Did not evaluate 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.
- 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.
- Did not evaluate whether a vendor will disclose personal information to law enforcement.
11.5: Certification
- 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.