Overview

Coolmath is an online tool for middle and high school age users and teachers to review math topics through interactive games. The policy does not indicate if users are able to interact with one another while using the site. The policy states Coolmath collects information directly from users and user devices, from third parties, and by automated means.

In addition, the policy confirms Coolmath and third parties use tracking tools to observe user behaviors over time and across other sites. The policy states data may be shared to companies who perform services on Coolmath's behalf, to serve interest-based ads that support the business, for analytics and tracking, and for legal compliance. The policy also states aggregated data may be shared with third parties for research, compliance, or any other reason. The policy confirms the services are supported by tailored advertising; ad servers use information collected from users to serve interest-based advertisements on the website and apps. The policy confirms Cool math and third parties use cookies and other tracking technologies to better understand user interests and behaviors and browsing activities over time across websites and platforms.

Coolmath can be accessed through its website and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Coolmath’s website, at the iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: About our Ads. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The policy does not indicate if users are able to interact or if interactions are monitored by Coolmath. In addition, it is not clear if personal information is publicly visible in any way.

Privacy

The privacy policy for Coolmath is up to date, but the terms of use does not list an effective date. The policy confirms Coolmath may share data such as name, address, username, Google Analytics User ID, IP address, internet activity information, and cookie information with service providers, advertising partners, and through business transfers. The policy specifies third party services such as payment processors and advertising partners are used to support Coolmath. The policy does not indicate if third party or social logins are supported by Coolmath. According to the policy, Coolmath may disclose information in the event of a business acquisition, merger, sale, transfer, or bankruptcy; the policy does not indicate if users will be notified.

Security

The policy does not indicate if user accounts are protected by multi-factor authentication. Furthermore, the policy does not indicate if data encryption is used or if users will be notified in the event of a data security breach.

Compliance

The policy does not indicate if Coolmath has a retention policy. The policy states, if a user is under 18 and wants to purchase a subscription, the parent or guardian must register and agree to the terms on behalf of the user, however it is unclear if verifiable consent is collected.

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 Assessment3531

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 information5040
Data Sharing: Protecting data from third parties10080
Data Security: Protecting against unauthorized access020
Data Rights: Controlling rights to data2510
Data Sold: Preventing sale of data2520
Data Safety: Promoting responsible use00
Ads & Tracking: Prohibiting the exploitation of users' decision making process3635
Parental Consent: Protecting children’s personal information040
School Purpose: Following student data privacy laws10025
Individual Control: Controlling data useNA15

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)5656
Children's Online Privacy Protection Act (COPPA)3138
Family Educational Rights and Privacy Act (FERPA)5736
Student Online Personal Information Protection Act (SOPIPA)5544
General Data Protection Regulation (GDPR)3330
The California Consumer Privacy Act (CCPA)3837

Privacy Policy Details

1: Transparency

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
  • Unclear 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: 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
  • Unclear whether 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.
  • 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
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Personal information from children under 13 years of age is not collected.
2.3: Data Excluded
  • Unclear whether specific types of personal information excluded from collection.
  • Unclear whether specific types of collected information are excluded from the privacy policy.
2.4: Data Limitation
  • Unclear whether the 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 shared for third-party 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
  • Unclear whether personal information is 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
  • Unclear whether links to third-party external websites are 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
  • Unclear whether links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
  • Company may combine data with additional data from third-party sources.
  • Data shared with third parties can be combined with other data.
3.14: Third-Party Authentication
  • Unclear whether this product supports third-party login.
  • 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 not 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.
  • Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.

4: Respect for Context

4.1: Data Use
  • Unclear whether 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
  • 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
  • Unclear whether 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
  • Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
5.4: Data Settings
  • Unclear whether users can control the use of their information through privacy settings.
5.5: Data Disclosure
  • Unclear whether 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
  • Unclear whether 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.

6: Access and Accuracy

6.1: Data Access
  • Unclear whether this product provides processes to access and review user data.
  • Unclear whether methods are available to restrict who has access to data.
  • Unclear whether the school, parents, or students can review student data.
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
  • Unclear whether the product provides a data-retention policy.
  • Unclear whether exceptions to the data retention policy exist.
6.5: Data Deletion
  • Unclear whether this product deletes data when no longer necessary.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Unclear whether a user can delete all their data.
  • Unclear whether authorzied users can delete data.
  • 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.
  • 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
  • Unclear whether a user's identity is verified with additional personal information.
8.2: User Account
  • Account creation is not required.
  • Unclear whether managed accounts are available.
  • Unclear whether 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.
  • Unclear 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 all data are stored in an encrypted format.
  • Unclear 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
  • Unclear whether this product performs data-privacy and/or security-compliance audits.

9: Responsible Use

9.1: Social Interactions
  • Unclear whether this product supports interactions between trusted users.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information must be shared for social interactions.
9.2: Data Visibility
  • Unclear whether personal information can be displayed publicly.
  • Unclear whether this product allows users to 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.
  • Unclear whether social interactions between users are moderated.
  • Unclear whether 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
  • Unclear whether this product displays traditional or contextual advertisements.
10.3: Behavioral Advertising
  • Personalised advertising is displayed.
10.4: Ad Tracking
  • Data are collected by third-parties for their own purposes.
  • User's information is used to track and target advertisements on other third-party websites or services.
  • Data profiles are 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
  • Unclear whether this company can send marketing messages.
  • Unclear whether this company provides promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
  • 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.
  • Unclear whether the company provides a method for users to opt-out from third-party tracking.

11: Compliance

11.1: Children Under 13
  • Unclear whether company has 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
  • Unclear whether 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.
  • Unclear whether this product provides parental consent notice and method for submission.
  • 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.
  • 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
  • Unclear whether 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.