Overview

Kodable's website describes its product as programming for kids with easy to follow lessons focused on student outcomes so users can teach their students to code. Kodable's policy asks users to let them know about inappropriate content of which the user becomes aware. Information collected under this policy may be used by Kodable and others. It could be used to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to user interests on Kodable's service and other websites and better understand the user's online activity. Kodable's policy indicates that during the registration process for teachers and parents, they will ask users to create an account, which includes name, an email address and a password. Kodable's policy indicates that it does not knowingly collect any personally identifiable Information information from children under 13 and that children may play its games without sharing information.

Kodable can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use used for this evaluation may be downloaded as PDFs from Kodable’s website and the iOS App Store. Additionally, other policies used for this evaluation include: End User License Agreement. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Kodable's policy asks users to let them know about inappropriate content of which the user becomes aware. If the user finds something that violates Kodable's guidelines, the policy indicates that Kodable will review it. However, there's not much in the policies to indicate that the users may interact with one another, upload content, or post anything publicly.

Privacy

Kodable indicates in its policies that it may collect information in connection with parent and teacher accounts. This may include name, email address, postal address, phone number, student information, teacher, class, or admin information, school information, payment information, and other information the user chooses to provide. Also, Kodable's policies explain that they automatically collect information about the user. The policy explain that the company collects log information about a user's use of the service, including the type of browser, access times, pages viewed, IP address and the page visited before Kodable's service. Information collected under this policy may be used by Kodable and others. It could be used to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to user interests on Kodable's service and other websites and better understand the user's online activity.

Security

Kodable's policy indicates that during the registration process for teachers and parents, they will ask users to create an account, which includes name, an email address and a password. According to the policies, children may use the platform, but may not create accounts on their own. Kodable notes in its policy that it takes reasonable measures to help protect information about users from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Compliance

Kodable's policy indicates that it does not knowingly collect any personally identifiable Information information from children under 13 and that children may play its games without sharing information. Kodable asks that if users are under age 18, please: (i) have their parent or legal guardian review this EULA; and (ii) do not install or play the Kodable Game without the permission of the parent, legal guardian, or teacher. Kodable's policy explains that users may update, correct or delete information about the user at any time by logging into their online account and editing the account 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 ScoreFull Score
Comprehensive Assessment4940

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 parties5070
Data Security: Protecting against unauthorized access5030
Data Rights: Controlling rights to data8855
Data Sold: Preventing sale of data2525
Data Safety: Promoting responsible use010
Ads & Tracking: Prohibiting the exploitation of users' decision making process5045
Parental Consent: Protecting children’s personal information3340
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)7560
Children's Online Privacy Protection Act (COPPA)4344
Family Educational Rights and Privacy Act (FERPA)5644
Student Online Personal Information Protection Act (SOPIPA)6251
General Data Protection Regulation (GDPR)5040

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.
  • Unclear whether 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 can contact the vendor about any privacy policy questions, complaints, or material changes to the policies.
1.6: Policy Principles
  • Privacy policies do not 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.
  • 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.
  • Unclear whether this product collects geolocation data.
  • 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 not collected from preK-12 students.
  • Personal information from children under 13 years of age is not collected online.
2.3: Data Exclusion
  • 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.
  • 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
  • Unclear whether there are specific categories of information that are not shared with third parties.
3.4: Data Sold to Third Parties
  • Unclear whether data are 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
  • 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 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
  • 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.
  • Unclear whether data shared with third parties can be combined by third parties for their own purposes.
3.14: Third-Party Authentication
  • Unclear whether this product supports social or federated login.
  • Unclear whether 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
  • User information is not 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
  • Use of information is not 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
  • Opt-in consent is not requested from users at the time personal information is collected.
5.3: Remedy Process
  • A grievance or remedy mechanism is not available for users to file a complaint.
5.4: Data Settings
  • Users can control their information through privacy settings.
5.5: Data Disclosure
  • Unclear whether 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
  • Unclear whether users retain ownership of their data.
  • Unclear whether 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.
  • Unclear whether the time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
  • Unclear whether the product provides a data-retention policy.
  • The retention time period of a user's data can be changed upon a valid inspection request.
6.5: Data Deletion
  • Unclear whether this product deletes data 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
  • 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.
  • Notice is provided to users if the vendor assigns its rights or delegates its duties to another company.
  • Users are not 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
  • 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
  • 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
  • Unclear whether this product provides notice 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
  • Unclear whether this product supports interactions between trusted users and/or students.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information is shared for social interactions.
9.2: Data Visibility
  • Unclear whether this product displays personal information publicly.
  • Unclear whether this product allows users to 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.
  • Users can report abuse or cyberbullying.
9.5: Internet Safety
  • Unclear whether 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 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
  • 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
  • Unclear whether this product responds 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 not have actual knowledge that personal information from users under 13 years of age is collected.
  • Unclear whether children's privacy is applicable.
  • Account creation is 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
  • Unclear whether this product requires parental consent.
  • Unclear whether this product limits parental consent with respect to third parties.
  • Unclear whether this product allows parents to 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.
  • Unclear whether this product provides parental consent notice and method for submission.
  • Unclear whether 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.
  • 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 any dispute 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 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
  • Unclear whether 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.