Overview
HMH iRead is a digital foundational reading program designed to close the achievement gap early. HMH iRead's terms specify that the service may allow users to create their own profile, which may be displayed publicly or semi-publicly. The terms of HMH iRead specify that the service may collect Personal Information and Demographic Information from users. The terms state that all data sent to and from their platform are protected via Transport Layer Security, or TLS.
HMH iRead 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 HMH iRead’s website, iOS App Store, the Google Play Store. Additionally, other policies used for this evaluation include: Intervention Technology Privacy Policy and K-12 Learning Platforms Privacy Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
HMH iRead's terms specify that the service may allow users to create their own profile, which may be displayed publicly or semi-publicly. The terms state that a user's profile page may be set up to display information such as the user's display name, images, location, groups that the user has joined, and optional information added by the user including -- for example -- the user's tagline, photographs and educational materials.
The terms state that the user can post to chat rooms, message boards, other user's profiles, bulletin boards, or similar forums. The terms describe that these interactions may be public or semi-public, and could potentially be accessible via search. The terms state that the Service may also publish a user's name, voice, likeness and other Personal Information that is part of their User Content, and they may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.
Lastly, the terms state that a user may send messages or invitations from the Service, and that people sending messages from the service should be aware that their e-mail address, mobile number, name and/or user name may be included along with any message.
Privacy
The terms of HMH iRead specify that the service may collect Personal Information and Demographic Information from users. In addition, the service may automatically collect non-personal usage information when a user visits or interacts with the service. The terms state that on mobile devices, the service might track a device's location. The Service may also combine a user’s non-personally identifiable Demographic Information or Usage Information with the Personal Information they collect directly on the Service, but will treat the combined data as Personal Information. However, the terms also state that the Service may change their Privacy Policy at any time without notice to a user.
The terms state that the service may share a user’s non-Personal Information, such as aggregated user statistics or data related to a user and their activities, with third parties. However, the terms state that Personal Information will not be shared with third parties for direct marketing purposes unless the user provides consent. Users should be aware that the terms state that a person's name, voice, likeness and other Personal Information that is part of their User Content could be used for advertising, marketing, publicity and promotional activities.
Additionally, the Service may supplement the information they collect directly from users on the Service with external information from third parties. The terms state that third parties, including advertisers and advertising service providers, may collect information about users. These third parties may use their own tracking technologies on a user’s Device, or collect a user’s personal Information. While the terms state that the Service will not use Personally identifiable information to target ads, they also state that a user may be served with targeted and contextual advertising, including location-based advertising.
Security
The terms state that all data sent to and from their platform are protected via Transport Layer Security, or TLS. The terms also specify that data that are covered under COPPA or FERPA are encrypted at rest whenever possible. The terms state that if the Service is not able to encrypt data, the Service will use other means to protect that data. The terms do not provide clear information on whether or not sensitive information that is not covered under COPPA or FERPA is encrypted at rest.
In the terms, the Company describes that privacy and information security training is provided to employees. They also describe how access to personal information is limited to specific employees. The Company uses third-party cloud service providers in the delivery and operation of their learning platform, and data is stored on the servers of their cloud service providers. The terms describe contractual requirements in place with these cloud service providers that are designed to protect user data.
Compliance
The terms specify that the tools and services covered under their policies are designed for teachers and schools working with K12 students. The terms highlight that, under COPPA, schools can provide consent for parents for online tools used for an educational purpose. The terms also state that the Company meets the criteria for a "school official" under FERPA.
The terms specify that the service does not knowingly collect Personal Information from children under the age of 13 without verified parental consent - and for applications used within schools, the terms state that this consent can be provided by the school. However, if personal information is collected, the service allows users to access, update, or correct their Personal Information.
The service states they meet FERPA's requirements for qualifying as a school official because they give the school direct control over the use and maintenance of the education records. The terms also state that the Service does not re-disclose or use this personal information except for the purposes of providing the learning platform to the school.
The terms state that the Service posts additional information or a separate Children's Privacy Policy on any website or app store page for a Service directed to children under 13 years of age. These additional policies explain what types of Personal Information may be collected, and what options parents have to approve or limit collection from children. However, this means that users will need to navigate five different sets of policies to determine the privacy and data security practices of the Service.
Teachers are strongly encouraged to review the parental consent procedures within their school or district before sharing student information.
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 | 82 | 60 |
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 | 65 |
| Data Sharing: Protecting data from third parties | 100 | 90 |
| Data Security: Protecting against unauthorized access | 100 | 80 |
| Data Rights: Controlling rights to data | 88 | 60 |
| Data Sold: Preventing sale of data | 75 | 60 |
| Data Safety: Promoting responsible use | 67 | 35 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 64 | 65 |
| Parental Consent: Protecting children’s personal information | 100 | 65 |
| School Purpose: Following student data privacy laws | 100 | 75 |
| Individual Control: Controlling data use | NA | 70 |
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 | 72 |
| Children's Online Privacy Protection Act (COPPA) | 79 | 65 |
| Family Educational Rights and Privacy Act (FERPA) | 86 | 66 |
| Student Online Personal Information Protection Act (SOPIPA) | 80 | 74 |
| General Data Protection Regulation (GDPR) | 93 | 69 |
| The California Consumer Privacy Act (CCPA) | 80 | 70 |
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 not 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
- Intended for children under 13.
- Unclear whether intended for teens.
- Unclear whether 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.
- 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 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.
- 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.
- 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
- 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
- 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
- Personal information cannot 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 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.
- Personal information from third-party login providers is collected.
- 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.
- 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
- Unclear 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
- 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 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.
- Unclear whether users can request to know what personal information has been shared with third parties.
- Notice is not 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.
- 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
- Processes to access or review user data are available.
- Unclear whether 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
- The company does not attempt 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
- A data-retention policy is available.
- Unclear whether exceptions to the data retention policy exist.
6.5: Data Deletion
- Data are deleted when no longer necessary.
- A user's data are not deleted upon account cancellation or termination.
- Processes to delete user data are not available.
- Processes for authorized users to delete data are available.
- 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
- Third-party transfer is 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
- Unclear whether this product requires account creation.
- 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
- Unclear whether this product performs data-privacy and/or security-compliance audits.
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
- 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
- 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
- Traditional or contextual advertisements are not 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 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.
- The company does provide promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
- Users cannot 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.
- The company does provide a method for users to opt-out from third-party tracking.
11: Compliance
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.
- Unclear whether this product restricts or prohibits account creation 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 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.
- Children's personal information is deleted if collected without parental consent.
- Unclear whether this product provides parental consent notice and method for submission.
- Parental consent obligations are 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
- 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.