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:


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.


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.


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.


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.

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 Assessment7370


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 information8365
Data Sharing: Protecting data from third parties10095
Data Security: Protecting against unauthorized access10095
Data Rights: Controlling rights to data8895
Data Sold: Preventing sale of data2545
Data Safety: Promoting responsible use6745
Ads & Tracking: Prohibiting the exploitation of users' decision making process5060
Parental Consent: Protecting children’s personal information10075
School Purpose: Following student data privacy laws025
Individual Control: Controlling data useNA75


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)8176
Children's Online Privacy Protection Act (COPPA)6971
Family Educational Rights and Privacy Act (FERPA)7163
Student Online Personal Information Protection Act (SOPIPA)5564
General Data Protection Regulation (GDPR)8779
The California Consumer Privacy Act (CCPA)7376

Privacy Policy Details

1: Transparency

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
  • 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 available in multiple languages.
1.8: Intended Use
  • Intended for children under 13.
  • Unclear whether 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.
  • 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 not shared for research and/or product improvement.
  • Personal information is shared for third-party 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 personal information is 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
  • 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.
  • 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.
  • 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.
  • 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
  • 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.
  • Unclear whether users can request to know what personal information has been shared with third parties.
  • Unclear whether 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.
  • 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.
  • 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 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 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
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.

8: Security

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 not reviewed, screened, or monitored by the company.
  • User-created content is not 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 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.
10.7: Unsubscribe
  • Users can 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.
  • Account creation is restricted or prohibited for users under 13 years of age.
11.2: Students in K–12
  • Product is not primarily used by, designed for, and marketed toward students in grades preK–12.
  • Processes to enter education records into the product are not described.
  • 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.
  • Children's personal information is deleted 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.
  • 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 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.