Additionally, other relevant policies used for this evaluation include:
- Our Privacy and Security Principles
- Legal Frameworks For Data Transfers
- Google's Subprocessors
- Google’s Partners
- Google Advertising
- Type of cookies used by Google
- Google Cloud Privacy
- Google Cloud Security
- Google Cloud Compliance
- Google Cloud Transparency
Google's terms remind parents that their child’s Google Account is like their own account and offers access to many of Google’s products and services, including general audience services that parents may use themselves, such as Chrome, Search, Gmail, Google Play, Hangouts, and Google Assistant. Most of these products and services have not been designed or tailored for children, and a child may use them to communicate with others or to find content that a parent may consider inappropriate.
Google's terms state many of its services let users interact with other trusted and untrusted users and share information with other people, for example, people with whom a user chooses to communicate or share content. If a user has a Google Account, they may display their profile name, profile photo, and actions a user takes on Google or on third-party applications connected to their Google Account. Additionally, a child’s information, including their name, photo, email address, and Google Play purchases, may be shared with members of a family group with Google Family Link.
Google's terms remind users that when they share information publicly, their content may become accessible through search engines, including Google Search. When a user is signed in and interacts with Google services, like leaving comments on a YouTube video or reviewing a song in Google Play, their name and photo appear next to their activity. The terms state users may manage their contact information, such as their name, email, and phone number, and choose whether their name and photo appears next to their activity, like reviews and recommendations, that may also appear in ads depending on their shared endorsements setting.
The terms also state a child will be able to share information, including photos, videos, audio, and location, publicly and with others, when signed in with their Google Account. When a child shares information publicly, it may be accessible through search engines like Google Search. Google Dashboard is a service that allows users to manage information associated with specific products and control what others see about a user across Google services. In addition, the terms state that Google provides "My Activity" controls that allow users to review and control data that are created when they use Google services, like searches they have done, or visits to Google Play. Users can also browse by date and by topic, and delete part or all of their activity on Google services.
Google provides additional safety resources for families:
Google's terms state they build a range of services that help millions of people daily to explore and interact with the world in new ways. The terms state Google understands it needs to build privacy that works for everyone, which is a responsibility that comes with creating products and services that are free and accessible for all. The terms also state that users may provide information to Google which personally identifies them, such as their name, email address, or billing information, or other data that can be reasonably linked to a user by Google, such as information they associate with their Google Account.
In addition, Google's terms state they collect information about a child’s activity in their services, which they use to do things like recommend apps they might like on Google Play. A child’s activity information that they collect may include things like search terms, videos they watch, voice and audio information when they use audio features, people with whom they communicate or share content, and Chrome browsing history they’ve synced with their Google Account. If a child uses Google's services to make and receive calls or send and receive messages, for example by using Google Hangouts, Google may collect telephony log information. The terms state a child can visit their Google Account to find and manage activity information that is saved in their account and parents can also manage their activity information by signing in to their child’s Google Account.
When it comes to privacy, Google's terms state they know one size doesn’t fit all. Every Google Account is built with on/off data controls, so users can choose the privacy settings that are right for them. And as technology evolves, Google's terms state its privacy controls evolve as well, ensuring that privacy is always an individual choice that belongs to the user. The terms state Google may use users' personal information to provide third-party marketing, but disclose they do not sell users' personal information to third parties. In addition, the terms state Google may display targeted advertisements to users, but that users can modify their interests, and choose whether their personal information is used to make ads more relevant to them, and turn on or off certain advertising services. The terms also state that Google allows specific partners to collect information from a user's browser or device for advertising and measurement purposes using their own cookies or similar technologies.
However, Google's terms state they will not serve personalized ads to a child, which means ads will not be based on information from a child’s account. Instead, ads may be based on information like the content of the website or app a parent's child is viewing, the current search query, or general location (such as city or state). Additionally, the terms state Google does not collect or use data in Google Cloud or G Suite services for advertising purposes and there are no ads in G Suite Services or Google Cloud Platform. Lastly, Google's terms state they don’t show users personalized ads based on sensitive categories, such as race, religion, sexual orientation, or health.
Google provides additional privacy resources:
Google's terms state they respect the privacy of their users, which means protecting the data they trust Google with. To keep every Google product and service secure for their users, the terms state Google engineers and employs one of the most advanced security infrastructures in the world. This means constantly strengthening Google's built-in security technologies to detect and protect against evolving online threats before they ever reach Google's users. However, the terms state keeping users safe online doesn’t stop with Google – it extends to the whole Internet. The terms also state Google shares their security learnings, experiences, and tools with partners, organizations, and competitors around the world, because Internet-wide security demands industry-wide collaboration.
The terms state Google reviews their information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to their systems. Google's terms state they restrict access to personal information to Google employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. Before onboarding third-party subprocessors, Google conducts an audit of the security and privacy practices of subprocessors to ensure subprocessors provide a level of security and privacy appropriate to their access to data and the scope of the services they are engaged to provide. In addition, the terms state Google uses encryption to keep users' data private while in transit with SSL (Secure Sockets Layer)/TLS (Transport Layer Security) and while stored on their servers. The terms state that if Google becomes aware of a data breach incident, Google will notify users of the incident promptly and without undue delay, and promptly take reasonable steps to minimize harm and secure users' data.
Google provides additional security resources:
Google's terms state they know it’s important for parents and guardians to understand what personal information they collect in association with their child’s Google Account, why they collect it, and how parents can update, manage, export, and delete that information. If a parent or guardian creates a new account for their child with Family Link, they can access, update, remove, and export their child’s information by signing into their Google Account. As part of the account creation process, the terms state Google may ask for personal information like first and last name, email address, and birthdate. Google may also use payment information to verify that a user meets age requirements, if, for example, if a user enters an incorrect birthday indicating they are not old enough to have a Google Account.
When a child turns 13, they are eligible to manage their account on their Google own. In addition, the terms state parents and guardians can also use the Family Link app or Family Link settings on the web to edit or modify their child’s Google Account information, review app activity and app permissions, and manage their child’s ability to grant certain permissions to apps to do things like access information from their child’s Android device (such as location, microphone, and contacts). Parents can also use Family Link to help manage their child’s access to certain features, apps, and services on Android, or change their Android permissions. Lastly, the terms state if at any time a parent or guardian wishes to stop further collection or use of their child's information, they can delete their child’s Google Account by clicking “Delete account” on their child’s Account Info page in Family Link or on the Family group page in My Account.
Google provides additional family resources:
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|
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||65|
|Data Sharing: Protecting data from third parties||100||95|
|Data Security: Protecting against unauthorized access||100||95|
|Data Rights: Controlling rights to data||88||95|
|Data Sold: Preventing sale of data||75||65|
|Data Safety: Promoting responsible use||67||70|
|Ads & Tracking: Prohibiting the exploitation of users' decision making process||50||60|
|Parental Consent: Protecting children’s personal information||100||65|
|School Purpose: Following student data privacy laws||0||0|
|Individual Control: Controlling data use||NA||85|
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)||79||79|
|Children's Online Privacy Protection Act (COPPA)||74||70|
|Family Educational Rights and Privacy Act (FERPA)||75||64|
|Student Online Personal Information Protection Act (SOPIPA)||63||64|
|General Data Protection Regulation (GDPR)||93||85|
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
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
- Intended for children under 13.
- Intended for teens.
- Intended for adults over 18.
- Unclear whether intended for parents or guardians.
- Unclear whether intended for students.
- Unclear whether 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.
- Biometric or health data are collected.
- 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 collected.
2.3: Data Excluded
- Unclear whether specific types of personal information excluded from collection.
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.
- Data are not shared for research and/or product improvement.
- Personal information is 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
- 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
- Links to privacy policies of third-party companies are not available.
3.13: Third-Party Data Combination
- 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.
- 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 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
- 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.
- 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 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.
- 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.
- The time period for the company to delete data is indicated.
6.6: Data Portability
- Processes to download user data are available.
- 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 notice is provided to users if the company assigns its rights or delegates its duties to another company.
- 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
- Third-party transfer is contractually required to use the same privacy practices.
8.1: User Identity
- 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.
- 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 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
- Users can filter or block inappropriate content.
- Users can report abuse or cyberbullying.
9.5: Internet Safety
- The company provides links to resources that support safe and appropriate social interactions.
10.1: Vendor Communications
- A user can receive service- or administrative-related communications from the company.
10.2: Traditional Advertising
- Traditional or contextual advertisements are displayed.
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
- 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.
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Unclear whether this product responds to "Do Not Track" or other opt-out mechanisms.
- The company does provide a method for users to opt-out from third-party tracking.
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 not 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
- Parental consent is required before personal information is collected or disclosed.
- Unclear whether this product limits parental consent 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.
- 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.
- 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.
- Unclear whether the company 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.
- The company has indicated it is a Data Controller or Data Processor.