Overview
IXL is the one of the world's most popular subscription-based learning sites for K-12. Used by over 7 million students, IXL provides unlimited practice in more than 7,000 topics, covering math, language arts, science, social studies, and Spanish. The terms of IXL say users can interact with trusted users on the service but do not disclose whether a child or student's personal information can be displayed publicly in any way. The terms say IXL will never sell student data to third parties, however the terms also say IXL may sell data from school or parent users to third parties. IXL's terms say they will maintain a comprehensive data security program and have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information they collect and to protect against unauthorized access, disclosure, and use. Furthermore, IXL's terms say their collection, use, and sharing of student data is governed by contracts with the school or district and any applicable laws and regulations including the Family Educational Rights and Privacy Act ("FERPA"), the Children's Online Privacy Protection Act ("COPPA") and applicable state laws.
IXL can be accessed through its website, and is available for download at the iOS App Store, the Google Play Store, and the Amazon App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on IXL’s website, iOS App Store, the Google Play Store, and the Amazon App Store. Additionally, other policies used for this evaluation include: IXL Service 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
The terms of IXL say users can interact with trusted users on the service but do not disclose whether a child or student's personal information can be displayed publicly in any way. The terms say a school may elect to provide user names or identifiers for student users which are not readily identifiable to anyone outside of the school community in substitution of a full student name. In addition, a school may elect to provide a profile name for a child user and selection of a profile avatar. IXL's terms say they recommend that the parent selects a profile name that does not include the real name or identifying characteristics of the child. The parent may also create a "secret word," which functions similar to a password to access the child profile, although it cannot be used to sign in to the IXL service without the parent first signing in to the parent's account using the parent's login credentials. However, parents and teachers should be aware the terms say a child may change his or her profile avatar, secret word, or profile name, but the parent will see these changes through the parent's account dashboard. IXL's terms say the account dashboard ensures that parents have access to, and control of, their child's use of the service.
Privacy
IXL's terms say the type of personal information the service collects may vary depending on the account type. A family account is purchased by or for a parent. A family account typically includes child profiles that can be used by a parent's child at the parent's direction. A classroom account is purchased by or on behalf of a school, such as by a teacher and is a type of school account. A classroom account typically includes a single teacher user and a small number of student users. A site account is purchased by or on behalf of a school or school district. A site account typically includes an unlimited number of teacher users and a set maximum number of student users. In addition, the terms state IXL takes special precautions to collect only as much information as is reasonably necessary for a child to use the service.
The terms of IXL say they may share information with third parties with consent and at the direction of schools and parents. In addition, third party service providers who have access to student data, are contractually bound to uphold privacy and confidentiality terms no less protective than IXL's terms. IXL's terms also say they consider student data to be strictly confidential and in general do not use student data for any purpose other than improving and providing the services to the school or on the school's behalf. The terms say IXL will never sell student data to third parties, but the terms do say that IXL may sell data from school or parent users to third parties. In addition, the terms say that from time to time, IXL may send periodic promotional or informational e-mails to school or parent users, but IXL does not disclose whether any third-party marketing e-mails may also be sent to school or parent users. Furthermore, the terms specify IXL does not use student data to send marketing communications, and they do not send marketing communications to student or child users. IXL's terms say they do not display any targeted advertising on the service and do not use student data for any targeted or behavioral advertising purposes.
However, the terms say that IXL and their third-party partners may use cookies and tracking technologies for the purpose of displaying advertisements to users on other websites or online services on their behalf. The terms say IXL works with third-party online advertising networks which use technology to recognize a user's browser or device and to collect information about their visit to IXL in order to provide customized content, advertising, and commercial messages to school, teacher or district administrative users and other non-student users on other websites or services, or on other devices they may use. Parents and teachers should be aware IXL does not build or amass a profile of a K-12 student for any advertising purposes, other than in furtherance of a K-12 school purpose, or as authorized by a parent. Lastly, IXL's terms say they take certain steps designed to avoid using third-party tracking technologies from collecting information from users of child profiles for targeted advertising purposes, by taking steps to disable tracking technologies only once a subscriber to IXL (e.g., the Parent or Teacher) logs into the service but those steps are limited to use of cookies.
Security
IXL's terms say they will maintain a comprehensive data security program and have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information they collect and to protect against unauthorized access, disclosure, and use. However, the terms do not disclose whether personal information is protected with encryption while in transit or while at rest. Additionally, the terms say some schools may elect to use a single-sign on (SSO) service like G Suite for Education rather than usernames and passwords to authenticate student access.
The terms state IXL and their employees, affiliates, service providers, or agents involved in the handling, transmittal, and processing of student data will be required to maintain the confidentiality of student data. In addition, the terms state IXL uses physical security measures to guard against unauthorized access to systems where they store personal data. IXL's terms specify they restrict access to personal information to IXL employees, contractors, and agents who need to know that information in order to operate, develop, or improve the services. IXL's terms state employees may be subject to disciplinary action, including termination, if they fail to meet privacy and confidentiality obligations. Lastly, the terms state that if personal information under IXL's control is compromised as a result of a breach of security, they will take reasonable steps to investigate the situation and take all steps required by applicable laws and agreements with any affected schools to provide notification.
Compliance
IXL's terms say that if a user is under eighteen (18) years of age, they may use the service only with the involvement and consent of a parent, legal guardian, or at the direction of their school. The terms say IXL may collect information about a child authorized by their parent to use the service through the parent's account and if IXL is used by a school for an educational purpose, IXL may collect student data that is provided by the school or by a student. The terms of IXL state they may share information collected from users associated with a school with other users or persons designated by the school, such as teachers and school administrators of that school.
Parents or guardians of a student who uses the IXL service through a school must refer all questions and requests regarding access, modification, or deletion of a student's user account or student data to their child's school. IXL's terms state they will respond promptly to all access, modification, and deletion requests it receives from schools. However, IXL is not required to delete student data that has moved to a personal family account on the service. IXL’s terms state they do not retain student data beyond the time period required to support its educational purpose, unless authorized by a school or parent. In addition, the terms state IXL does not delete or de-identify any student data from an active student user account associated with a school except at the direction of the school. The school is responsible for maintaining current student rosters and identifying student data which the school no longer needs for an educational purpose by removing students from the school's master roster or by submitting a deletion request to IXL.
Furthermore, IXL's terms state their collection, use, and sharing of student data is governed by contracts with the school or district and any applicable laws and regulations including the Family Educational Rights and Privacy Act ("FERPA"), the Children's Online Privacy Protection Act ("COPPA") and applicable state laws. IXL's terms state its service is designed to comply with AB 1584 and pupil education records obtained by IXL from a local educational agency ("LEA") continue to be the property of and under the control of the LEA. Lastly, if a school provides the IXL service to children under 13, they must represent and warrant that they have the authority to provide consent on behalf of parents for IXL to collect information from students under 13 before allowing the students to access the service.
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 | 72 | 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 | 75 | 50 |
| Data Sharing: Protecting data from third parties | 100 | 90 |
| Data Security: Protecting against unauthorized access | 67 | 60 |
| Data Rights: Controlling data use | 88 | 95 |
| Data Sold: Preventing sale of data | 50 | 75 |
| Data Safety: Promoting responsible use | 25 | 25 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 58 | 60 |
| Parental Consent: Protecting children’s personal information | 100 | 80 |
| School Purpose: Following student data privacy laws | 100 | 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 | 77 |
| Children's Online Privacy Protection Act (COPPA) | 70 | 69 |
| Family Educational Rights and Privacy Act (FERPA) | 89 | 69 |
| Student Online Personal Information Protection Act (SOPIPA) | 77 | 73 |
| General Data Protection Regulation (GDPR) | 79 | 82 |
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
- 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: 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 available in multiple languages.
1.8: Intended Use
- 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 not 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
- 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.
- Data are shared for third-party advertising and/or 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
- Data are sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Unclear whether 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
- The categories of third parties that receive personal information are indicated.
3.12: Third-Party Policies
- Links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
- Unclear whether data can be combined with data from third-party sources.
- Unclear whether 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.
- Unclear whether personal information from social or federated login providers is collected.
- Personal Information is shared with social or federated login providers.
3.15: De-identified or Anonymized Data
- User information is shared in an anonymous or deidentified format.
- The vendor describes their deidentification 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 deidentified information.
4: Respect for Context
4.1: Data Use
- 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
- 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 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 for commercial purposes.
- Unclear whether notice is provided in the event the vendor 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.
- Unclear whether 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 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.
- 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.
- The time period for the vendor to delete data is indicated.
6.6: Data Portability
- Processes to download user data are 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.
- Users are notified if their information is transferred to a third party.
7.2: Transfer Request
- 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
- Account creation is required.
- Parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
8.3: Third-Party Security
- Third-party contractual security protections are required.
8.4: Data Confidentiality
- Industry best practices are used to protect data.
- Employee or physical access to user information is limited.
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.
- 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
- Data-privacy and security-compliance audits are performed.
9: Responsible Use
9.1: Social Interactions
- Users can interact with trusted users and/or students.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
9.2: Data Visibility
- Unclear whether this product displays personal information 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.
- 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 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 displayed.
10.3: Behavioral Advertising
- Behavioral or targeted advertising is not displayed.
10.4: Ad Tracking
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
- Children do not receive any 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
- Users can 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.
- The vendor does provide a method for users to opt-out from third-party tracking.
11: Compliance
11.1: Children Under 13
- Vendor does not have actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- Account creation is restricted for users under 13 years of age.
- Vendor does restrict 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.
- Notification of a contract or additional rights is provided.
- Vendor is designated as a school official.
11.3: Parental Consent
- Parental consent is required.
- 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.
- 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
- 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.
- The vendor has indicated it is a Data Controller or Data Processor.