Overview

Flipgrid describes itself as a video discussion platform for millions of PreK to PhD educators, students, and families in 180+ countries. Flipgrid's policy indicates that it doesn't control content, but enables "Grid Owners," a category of users, to do so. Flipgrid's terms indicate that it does not sell users’ personal information to third parties or use personal information to market or advertise to users. Several categories of accounts are available, including Grid Owner, student, and school accounts. A teacher or school Grid Owner may act as the agent of the parent or legal guardian of a student and provide consent on behalf of the parent, and Flipgrid's policy includes a link to a parent consent form to facilitate this process.

Flipgrid 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 Flipgrid’s website, iOS App Store and the Google Play Store. Additionally, other policies used for this evaluation include: Children's Privacy Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Flipgrid's policy indicates that it doesn't control content, but enables "Grid Owners," a category of users, to do so. Also, they note that Grid Owners have certain options with respect to the privacy settings of their Grids. Flipgrid gives the example that teacher or School Grid Owners must password-protect the Grid and can also moderate their Grid. The policy explains that parents and students should send all requests regarding these privacy settings directly to the Grid Owner. In their policy, the Grid Owner controls what is public and can moderate content and interactions. Depending on the Grid's privacy settings, as set by the Grid Owner, users may be able to post Videos to SNSs (e.g., Facebook or Twitter). If a user chooses to do this, Flipgrid indicates that it will provide information to such SNSs in accordance with such user's elections.

Privacy

Flipgrid's policy explains that when a Grid Owner creates an account on the Service, Flipgrid collects the Grid Owner’s first name, last name, email address, password, instruction type, and country. Users may also be students and schools, although implicitly the Grid Owners are teachers. In addition to the cookies Flipgrid sets, the policy also notes that third parties can also set cookies when you visit their sites. For example, companies they hire to provide services on Flipgrid's behalf, such as site analytics, may place cookies when users visit their sites. Flipgrid's terms indicate that it does not sell users’ personal information to third parties or use personal information to market or advertise to users. Lastly, Flipgrid's terms explain that the service does not use personal information to track and target advertisements to users' on third party websites or services.

Security

Flipgrid's policy claims that its security procedures and practices are consistent with industry standards applicable to their collection and use of personal information. Several categories of accounts are available, including Grid Owner, student, and school accounts. Flipgrid explains in its policy that when a Grid Owner logs into an existing account through their Microsoft or Google account, they may collect his/her first and last name, email address and other information specific to that third party account to authenticate the Grid Owner. There is no discussion of encryption in the privacy policy. In the event of an unauthorized release, disclosure, or acquisition of User information, Flipgrid indicates that it will notify affected individuals (either directly or through Grid Owners), as required by applicable law.

Compliance

Flipgrid's policy allows Grid Owners (presumably teachers) to monitor content for other users like schools and students. By enrolling a student under 13 to use the Service, Flipgrid's policy indicates that the school provides such consent to us and agrees that the students’ activities while on the service are subject to their terms and conditions online agreement. Flipgrid's policy for children gives parents of students under 13 certain rights with respect to its collection, use, retention, and disclosure of their student’s information. This includes the right to review, update, or delete student information. Flipgrid notes that they are required under the Children Online Privacy Protection Act ("COPPA") to obtain verifiable parental consent in order to collect, use or disclose personal information from children, but notes that a teacher or school Grid Owner may act as the agent of the parent or legal guardian of a student and provide consent on behalf of the parent. Flipgrid's policy includes a link to a parent consent form to facilitate this process.

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 Assessment7654

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 information2535
Data Sharing: Protecting data from third parties5060
Data Security: Protecting against unauthorized access6745
Data Rights: Controlling data use8870
Data Sold: Preventing sale of data7530
Data Safety: Promoting responsible use6350
Ads & Tracking: Prohibiting the exploitation of users' decision making process10075
Parental Consent: Protecting children’s personal information10070
School Purpose: Following student data privacy laws10050

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)9267
Children's Online Privacy Protection Act (COPPA)7658
Family Educational Rights and Privacy Act (FERPA)7253
Student Online Personal Information Protection Act (SOPIPA)8860
General Data Protection Regulation (GDPR)6853

Privacy Policy Details

1: Transparency

1.1: Policy Version
  • Privacy policies do indicate a version or effective date.
  • Privacy policies do not 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 cannot 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.
  • Unclear whether 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.
  • Behavioral data are collected.
  • Unclear whether this product collects sensitive data.
  • Non-personally identifiable information is collected.
  • Unclear whether 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
  • 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.
  • 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.
  • Data are not 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
  • Unclear whether the categories of third parties that receive personal information 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
  • Data can be combined with data from third-party sources.
  • 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.
  • Personal information from social or federated login providers is collected.
  • Unclear whether 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
  • Unclear whether 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
  • Unclear whether 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
  • 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
  • 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
  • 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
  • Unclear whether 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.
  • Notice is not 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 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.
  • Unclear whether the time period for the vendor to delete data is indicated.
6.6: Data Portability
  • Processes to download user data are not available.
  • 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.
  • Unclear whether 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.
  • 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 this product encrypts all data at rest.
  • 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.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information is not shared for social interactions.
9.2: Data Visibility
  • Personal information is displayed publicly.
  • Users can control how their data are displayed.
9.3: Monitor and Review
  • Unclear 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 not moderated.
  • Unclear whether social interactions of users are logged.
9.4: Report Content
  • Users can filter or block inappropriate content.
  • Unclear whether 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
  • Traditional or contextual advertisements are not displayed.
10.3: Behavioral Advertising
  • Behavioral or targeted advertising is not displayed.
10.4: Ad Tracking
  • Data are not collected by third-party advertising or tracking services.
  • Data are not used to track and target advertisements on other third-party websites or services.
  • Data profiles are not created and used 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.
  • Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
  • Unclear whether this product provides users the ability to 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.
  • Unclear whether this product designates the vendor as a school official.
11.3: Parental Consent
  • Parental consent is required.
  • Parental consent is limited with respect to third parties.
  • Parents can withdraw consent for the further collection of their child's information.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Parental consent notice and method for submission are provided.
  • The vendor can use collected information to support the “internal operations” of the product.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • Unclear whether the vendor indicates FERPA parental consent exceptions.
  • Unclear whether this product discloses directory information.
  • 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.
  • Unclear whether the vendor has indicated it is a Data Controller or Data Processor.