Microsoft Cortana is an intelligent assistant that provides smart features and personalized experiences across a variety of devices, apps, and services. The terms of Microsoft state a child can access social communication services, like Outlook and Skype, and can freely communicate and share data with other trusted and untrusted users of all ages. Microsoft's terms state the personal information Cortana collects depends on the choices a user makes (including their privacy settings and whether or not they are signed-in), the data they share with Cortana, and Cortana’s capabilities (which vary depending on a user’s operating system, device, and the services and apps they use). Microsoft's terms state they are committed to protecting the security of users' personal data. Lastly, the terms state if a child tries to register for an account, Microsoft will ask them to provide consent or authorization from a parent or guardian before they can use the service.

Microsoft Cortana can be accessed through its website, and on Microsoft Windows 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 Microsoft’s website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Additionally, other relevant policies used for this evaluation include:

• Microsoft's Privacy Commitment
• Cortana and privacy
• Microsoft Services Agreement
• Microsoft Ad Settings

Safety

The terms of Microsoft state a child can access social communication services, like Outlook and Skype, and can freely communicate and share data with other trusted and untrusted users of all ages. Microsoft's terms also state they provide services that allow users to send group messages to others via voice or SMS, and allow Microsoft and Microsoft-controlled affiliates to send messages to users and one or more other users on a user's behalf. The terms state that when users use social features in Microsoft products, other users in their network may see some of their activity. When users are signed in, some products will display a user's name or username and their profile photo (if a user has added one to their profile) as part of their use of Microsoft products, including in their communications, social interactions, and publicly available posts.

Parents and kids can use Microsoft family features to build trust based on a shared understanding of what behaviors, websites, apps, games, physical locations, and spending is right in their family. The terms state parents can create a family account by going to https://account.microsoft.com/family and inviting kids or other parents to join. There are many features available to family members, and the terms state parents should carefully review the information provided when they agree to create or join a family and when they purchase digital goods for family access.

Privacy

Microsoft's terms state the personal information Cortana collects depends on the choices a user makes (including their privacy settings and whether or not they are signed-in), the data they share with Cortana, and Cortana’s capabilities (which vary depending on a user’s operating system, device, and the services and apps they use). For example, Windows provides supported apps with the ability to respond and take action based on voice keywords that are specific to that app and allows Cortana to listen and respond to “Hey Cortana.” Cortana personalized recommendations work when a user signs in and allows Cortana to collect and use data from a user’s device, their Microsoft account, other Microsoft services, and third-party services to which a user may choose to connect. The terms state users can also choose to let Cortana collect and access their device and cloud-based email and other communications, their calendar, and their contacts to enable additional features and personalization. Also, the data Cortana collects is used to provide, improve, personalize, and develop Cortana and other Microsoft products. The terms state users can manage whether Cortana has access to a user’s search and browsing history, and what data Cortana knows about them in their Cortana Settings.

In addition, the terms state if users choose not to sign into Cortana, they can still chat with Cortana and use Cortana to search, using either their voice, inking, or typing, and can still receive non-personalized suggestions and responses. Cortana allows users to connect to third-party services to enable her to do more and provide additional personalized experiences based upon data collected from the third-party service. However, the terms do not disclose whether Microsoft may sell personal information to third parties, but does disclose that personal information is not used by Cortana to display behavioral advertising. Ads may still accompany search results that Cortana delivers, but are not targeted to the user. The terms also state ads that a user sees may be selected based on data Microsoft Cortana processes about them, such as their interests and favorites, their location, their transactions, how they use Microsoft's products, their search queries, or the content a user views. However, Microsoft's terms state they do not use what a user says in email, chat, video calls, or voice mail, or their documents, photos, or other personal files to target ads to users. Microsoft can use data they collect through their interactions with users, through some of their products, and on third-party web sites, for advertising in Microsoft products and on third-party web sites.

Lastly, the terms state Microsoft may use automated processes to help make advertising more relevant to users. Microsoft may partner with third-party ad companies to help provide some of their advertising services, and Microsoft also allows other third-party ad companies to display advertisements on their sites. These third parties may place cookies on a user's computer or devices and collect data about a user's online activities across websites or online services.

Security

Microsoft's terms state they are committed to protecting the security of users' personal data. They use a variety of security technologies and procedures to help protect a user's personal data from unauthorized access, use, or disclosure. For example, the terms state Microsoft stores the personal data users provide on computer systems that have limited access and are in controlled facilities. In addition, the terms state Microsoft uses collected data to protect the safety of their products and their customers. Microsoft's terms state their security features and products can disrupt the operation of malicious software and notify users if malicious software is found on their devices.

Microsoft's terms also state they use data they collect to develop product updates and security patches. For example, Microsoft may use information about a device’s capabilities, such as available memory, to provide users with a software update or security patch. Updates and patches are intended to maximize users' experience with Microsoft products, help users protect the privacy and security of their data, provide new features, and ensure a user's device is ready to process updates. Microsoft's terms state they use cookies to process information that helps them secure their products, as well as detect fraud and abuse. Moreover, the terms of Microsoft state when they transmit personal information over the internet, they protect it through the use of encryption, and protect the data users store with Microsoft through strong security and encryption.

Parents and educators should be aware the terms state that users can sign into certain Microsoft services with a school email address. The owner of the school domain associated with a user's email address may control and administer that user's account, and access and process their data, including the contents of their communications and files. In addition, the data associated with a school account, and how it will be used, is generally similar to the use and collection of data associated with a personal Microsoft account. If a school uses Azure Active Directory (AAD) to manage the account it provides users, they can use their school account to sign in to Microsoft products, such as Office 365, and third-party products provided to them by the school. Lastly, Microsoft's terms state they comply with data protection laws, including security breach notification laws.

Compliance

The terms state if a child tries to register for an account, Microsoft will ask them to provide consent or authorization from a parent or guardian before they can use the service. If Microsoft obtains a parent or guardian's consent to use their child's personal data, they can withdraw that consent at any time and parents can change or revoke the consent choices they previously made. The terms state that once parental consent or authorization is granted, the child's account is treated much like any other account. The terms also state Microsoft will not knowingly ask children to provide more data than is necessary to provide its services and Microsoft will either block child users from registering, including purchases, whether the minor’s account is now open or created later. The terms require users must be above a certain age to use Cortana. When a user tries to sign in, Cortana checks the age setting for that particular Microsoft account, and users that are identified as being too young cannot sign-in or have a personalized Cortana experience. Cortana on Windows can still help younger users search the web, or perform other tasks that don’t require the collection of any personal in.

In addition, the terms state that Microsoft will provide users the ability to access, review, modify, and delete their personal information at any time. Parents or guardians of children may request the deletion of the personal data of children for whom they provided consent or authorization and the terms state Microsoft will respond to requests to control personal data within 30 days. Many Microsoft products are intended for use by organizations, such as schools and businesses. The terms state parents and educators should direct their privacy inquiries, including any requests to exercise their data protection rights or those of children, to the school or organization’s administrator.