Overview
Curriki is a community for teaching or studying that facilitates finding and sharing educational content. The terms of Curriki state the service is dedicated to supporting learning communities. Any comments, resources, content, and information users submit to the public areas of the services, such as the forums, can be read, collected, or used by other users and the public. The terms of Curriki state they collect personal information and non-personal information automatically from the use of the service. The terms of Curriki state they provide reasonable security to protect personal information submitted to the service Lastly, the terms of Curriki state they do not knowingly collect or maintain personal information from users under 13 years of age.
Curriki can be accessed through its website. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Curriki’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The policies indicate that Curriki provides a forum where PII and shared content can be made public. In order to interact with the service PII is collected and displayed publicly and users of the product have the potential to interact with untrusted users. Some information can be withheld (such as email addresses) but the policies are unclear as to how, and what, PII is shared and how it can be managed. The policy does indicate that PII “can be read, collected, or used by other users and the public.” Policies also state that the vendor does not screen, review or delete PII from user created content and moderating is not provided. In addition, the policies do not clearly state if social interactions are logged, if abusive behavior can be reported, or if tools and process for safe interactions are provided, or if users can interact with trusted users. Lastly, there is also no mention of an ability to block, filter, or monitor social interactions, however the policies do clearly state that the product is not intended for students.
Privacy
The terms state user personal information is collected and includes automatically collected information. Collection of personal information is limited to only the data required to provide, operate and improve the services. In addition, the policies state that personal information is not sold or rented to third parties and information is not obtained on users from third party sources to be combined. Social federated login is supported and personal information is collected from those sources, but is not shared with third-parties unless user authorized. The policies indicate that contractual limits are placed on third-party vendor use of data and third parties are not authorized to access user PII.
In addition, the policies state behavioral ads are not displayed but there are no references to traditional ads. The policies clearly state Curriki is not intended for users under 13, minors or students and therefore ads and links are considered age-appropriate for adult users. Users can create and upload content and opt-in permission is required at time of upload but further opt-in consent is not sought.
Security
Curriki's policies state that a user must register for an account to use the service and two-factor authentication is not required. Policies also indicate that authorized account mangers or legacy contacts are not provided to access and download user data and different classes of user accounts or managed accounts are not provided. The policies further indicate that reasonable security measures are taken and transit encryption is used but specifics on storage procedures are not provided. In addition, the terms state users will be notified in the event of a data breach. Third party providers must use personal information in accordance with Curriki's privacy policy and employee access to user info is restricted.
Compliance
The policies clearly indicate that the product is not intended for children under the age of 13 or teens between 13 and 18 years of age, but is aimed at adults such as educators and parents. Therefore student information is not collected and information on children under 13 or minors is not knowingly collected. The policies indicate that methods are not implemented to prevent children or minors from creating an account, but information will be deleted upon discovery or request. The policies also clearly state that, due to the fact Curriki is not aimed at minors or children, they do not obtain verifiable consent under COPPA or provide information about FERPA rights or disclose information under such requirements.
Furthermore, the policies state the product is not intended for students so information on restricting data, reviewing student information, maintaining accuracy of data or modifying / deleting student data are not provided in the policies. Policies do indicate a user may update their own information or request their account to be deleted (this will be processed within 14 days of request), however, user uploaded information and some PII (not specified in the policies) will remain on the service after account deletion. Policies also state that there is no time-period for automatically deleting or limiting information retention after inactivity.
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 | 77 | 68 |
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 | 83 | 80 |
| Data Sharing: Protecting data from third parties | 100 | 80 |
| Data Security: Protecting against unauthorized access | 67 | 85 |
| Data Rights: Controlling rights to data | 63 | 60 |
| Data Sold: Preventing sale of data | 75 | 45 |
| Data Safety: Promoting responsible use | 33 | 40 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 79 | 65 |
| Parental Consent: Protecting children’s personal information | 100 | 90 |
| School Purpose: Following student data privacy laws | 100 | 81 |
| Individual Control: Controlling data use | NA | 90 |
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) | 94 | 76 |
| Children's Online Privacy Protection Act (COPPA) | 74 | 66 |
| Family Educational Rights and Privacy Act (FERPA) | 79 | 69 |
| Student Online Personal Information Protection Act (SOPIPA) | 85 | 76 |
| General Data Protection Regulation (GDPR) | 90 | 73 |
| The California Consumer Privacy Act (CCPA) | 78 | 72 |
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 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: 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 available in multiple languages.
1.8: Intended Use
- Not intended for children under 13.
- Not intended for teens.
- Intended for adults over 18.
- Intended for parents or guardians.
- Not 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 not collected.
- Biometric or health data are not collected.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are not collected.
- Data is automatically collected.
2.2: Data Source
- Personal information or education records are not collected from preK-12 students.
- Personal information from children under 13 years of age is not 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.
- Unclear whether 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 not 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
- Personal information is not sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Personal information about users is not 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 not authorized to access a user's information.
3.8: Third-Party Data Collection
- Personal information of users is not 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 available.
3.13: Third-Party Data Combination
- Company will not 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 not shared with third-party login providers.
3.15: De-identified or Anonymized Data
- Unclear whether user information that is shared is 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
- 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
- Combined information is treated 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 not 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
- Users can control the use of their information through privacy settings.
5.5: Data Disclosure
- Users cannot 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.
- Notice is provided in the event the company receives a government or legal request for a user's information.
5.6: Intellectual Property
- Users do not 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 not limited in scope or duration.
6: Access and Accuracy
6.1: Data Access
- Processes to access or review user data are available.
- 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 not 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 do not exist.
6.5: Data Deletion
- Data are not deleted when no longer necessary.
- A user's data are deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Unclear whether authorzied users can delete data.
- The time period for the company to delete data is indicated.
6.6: Data Portability
- Processes to download user data are not available.
- A user can not 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 not notified if their information is transferred to a third party.
7.2: Transfer Request
- User information can not 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
- A user's identity is not verified with additional personal information.
8.2: User Account
- Account creation is required.
- Managed accounts are not available.
- Multi-factor account protection is not 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
- 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
- Notice is provided in the event of a data breach.
8.8: Data Oversight
- Data-privacy and/or security-compliance audits are not performed.
9: Responsible Use
9.1: Social Interactions
- Unclear whether this product supports interactions between trusted users.
- 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 displayed publicly.
- Users can control how their data are displayed to others.
9.3: Monitor and Review
- User-created content is not reviewed, screened, or monitored by the company.
- User-created content is not filtered for personal information before being made publicly visible.
- Social interactions between users are not 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 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.
- Unclear whether this company provides 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 not 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 not 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.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Company is not designated as a school official.
11.3: Parental Consent
- Parental consent is required before personal information is collected or disclosed.
- Parental consent is not limited 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 not provided.
- Parental consent obligations are not transferred to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing the policies is indicated.
- Unclear whether a user is required to waive the right to a jury trial, or settle any disputes by arbitration.
- Unclear whether 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 not 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.
- Unclear whether the company has indicated it is a Data Controller or Data Processor.