Overview
Osmo Numbers is a website and a group of games for mobile devices designed for children, students, parents, and teachers. Osmo Numbers is owned by Tangible Play Inc. According to the terms of Osmo Numbers, personally identifiable information is collected from users such as a user's email address, physical address, phone number, and IP address. Additionally, the terms of Osmo Numbers state that some of this personal information is shared with third parties such as service providers. The terms of Osmo Numbers state that they do not sell users data to third parties but they may display personalized advertisements on their product, with some limited restrictions for students.
According to the terms of Osmo Numbers, it is unclear whether or not users can interact with trusted and/or untrusted users while using the product. Additionally, the terms of Osmo Numbers do not specify whether or not data is encrypted in transit or at rest. Further, the terms of Osmo Numbers state that there is a process available to users who wish to access, modify, and/or delete their personal information. Lastly, the terms of Osmo Numbers state that this product is intended to be used by children younger than the age of 13.
Osmo Numbers 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 can be found on Osmo Numbers’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
According to the terms of Osmo Numbers, the company makes sure to delete any persona information in user-generated content before it becomes publicly available. Additionally, the terms of Osmo Numbers state that they do not regularly monitor user-generated content. Lastly, the terms of Osmo Numbers do not specify whether or not users can report bullying or harassment of any kind.
Privacy
According to the terms of Osmo Numbers, geolocation data is collected from users but it is unclear whether or not health or behavioral data is also collected. Additionally, the terms of Osmo Numbers state that personal information is collected by third parties such as tracking partners. The terms of Osmo Numbers also state that personal information is shared with third-party analytic companies. The terms of Osmo Numbers do not specify whether or not third-party login is supported on the product. Further, the terms of Osmo Numbers state that they impose contractual limits on how third parties can use the data the company shares with them. According to the terms of Osmo Numbers, the company sends marketing communications to users. However, the terms of Osmo Numbers state that users can unsubscribe from these communications. Lastly, the terms of Osmo Numbers state that they do not sell K-12 students' information.
Security
According to the terms of Osmo Numbers, users are notified in the event of a data breach. Additionally, the terms of Osmo Numbers state that they take reasonable security measures to protect a user's personal information. The terms of Osmo Numbers do not specify whether or not the company implements physical access restrictions or if they limit employee access to personal information. The terms also do not state whether or not it is required for users to create an account in order to use the services.
Compliance
According to the terms of Osmo Numbers, users can submit content to the product such as reviews or comments. Additionally, the terms of Osmo Numbers state that they might collect personal information from children when they participate in the beta-testing program. The terms of Osmo Numbers state that this product is intended to be used by parents. However, the terms of Osmo Numbers do not specify whether or not they have a retention policy of after how much time personal information is deleted from the company. Lastly, the terms of Osmo Numbers state that they will delete a child's personal information if they learn they collected the information without parental consent.
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 | 59 | 42 |
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 | 67 | 40 |
| Data Sharing: Protecting data from third parties | 100 | 65 |
| Data Security: Protecting against unauthorized access | 33 | 20 |
| Data Rights: Controlling rights to data | 88 | 60 |
| Data Sold: Preventing sale of data | 75 | 25 |
| Data Safety: Promoting responsible use | 33 | 20 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 43 | 50 |
| Parental Consent: Protecting children’s personal information | 50 | 55 |
| School Purpose: Following student data privacy laws | 100 | 50 |
| Individual Control: Controlling data use | NA | 40 |
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) | 64 | 52 |
| Children's Online Privacy Protection Act (COPPA) | 60 | 50 |
| Family Educational Rights and Privacy Act (FERPA) | 63 | 47 |
| Student Online Personal Information Protection Act (SOPIPA) | 71 | 59 |
| General Data Protection Regulation (GDPR) | 70 | 52 |
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 notified if there are any material changes to the policies.
- Privacy policies do not 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.
- 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 collected.
- Unclear whether this product collects biometric or health data.
- Unclear whether this product collects interactions, behaviors, or usage analytics data.
- Sensitive data are 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
- Specific types of personal information are 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 not 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.
- Unclear whether 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
- Unclear whether there are specific categories of information that 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
- Unclear whether personal information about users is obtained 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
- Unclear whether 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
- Unclear whether 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
- Unclear whether 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
- Unclear whether this product supports third-party login.
- Unclear whether personal information from third-party login providers is collected.
- Unclear whether personal Information is shared with third-party login providers.
3.15: De-identified or Anonymized Data
- User information that is shared is not 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.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
4: Respect for Context
4.1: Data Use
- Unclear whether 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
- 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
- Unclear whether 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
- Unclear whether users can control the use of 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.
- 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.
- 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.
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
- Unclear whether 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.
- Unclear whether the time period for the company to modify inaccurate data is indicated.
6.4: Data Retention
- Unclear whether the product provides a data-retention policy.
- Unclear whether exceptions to the data retention policy exist.
6.5: Data Deletion
- Unclear whether this product deletes data 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
- 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 in the event of a merge, acquisition, or bankruptcy.
- Unclear whether notice is provided to users if the company assigns its rights or delegates its duties to another company.
- 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
- Unclear whether a user's identity is verified with additional personal information.
8.2: User Account
- Unclear whether this product requires account creation.
- Unclear whether managed accounts are available.
- Unclear whether multi-factor account protection is available.
8.3: Third-Party Security
- Unclear whether 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.
- 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 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
- Unclear whether this product supports interactions between trusted users.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information must be shared for social interactions.
9.2: Data Visibility
- Personal information can be not displayed publicly.
- Unclear whether this product allows users to 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.
- 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
- Unclear whether the company provides links to resources that support safe and appropriate social interactions.
10: Advertising
10.1: Vendor Communications
- A user can receive service- or administrative-related communications from the company.
10.2: Traditional Advertising
- Unclear whether this product displays traditional or contextual advertisements.
10.3: Behavioral Advertising
- Personalised advertising is displayed.
10.4: Ad Tracking
- Data are collected by third-parties for their own purposes.
- Unclear whether this product uses a user's information 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.
- Unclear whether this company provides 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
- Unclear whether this product responds to "Do Not Track" or other opt-out mechanisms.
- Unclear whether the company provides a method for users to opt-out from third-party tracking.
11: Compliance
11.1: Children Under 13
- Unclear whether company has 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 not described.
- Unclear whether 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
- Unclear whether 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
- 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.