Overview

Students use Pattern Shapes, by the Math Learning Center (MLC) to explore geometry and fractions, create their own designs, or filling in outlines. The terms state the service may contain one or more areas where users can post content that can be publicly viewed by others. The terms state MLC may collect personally identifiable information and non-personal usage information automatically for data analytics. In addition, the terms state MLC uses commercially reasonable physical, electronic, and managerial security measures to assist in protecting against the loss, misuse, and unauthorized alteration of personally identifiable information that is under their control. Lastly, The terms do not disclose whether personal information is collected from students in K-12 or children under 13 years of age, how that information is used, or MLC's disclosure practices of that information without parental consent.

Pattern Shapes 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 Pattern Shape’s website, and the iOS App Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms state the service may contain one or more areas where users can post content that can be publicly viewed by others. When a user voluntarily discloses Personally Identifiable Information on these areas of the service for public viewing, their information may be collected, stored, used, and disclosed by other users. In addition, the service may also provide blogs or web forums which may or may not be pre-screened or monitored by MLC for user-generated content. Therefore, users should use caution when posting information, because it may be publicly visible to others.

Privacy

The terms state MLC may collect personally identifiable information and non-personal usage information automatically for data analytics. A visitor to the service does not need to provide personal information in order to browse or use some of features of the service. In addition, MLC will not sell or otherwise transfer or disclose a user's personally identifiable information to any third party. However, MLC may share a user's de-identified aggregated automatically collected information with third parties without restriction.

Users should be aware that any automatically collected information may be combined with personally identifiable information that a user may have provided. If a user chooses to provide the service with their contact information, they may contact users with offers for products and services that may be of interest to them. Lastly, the terms state MLC does not display any advertising to users on its service or engage in ad tracking.

Security

The terms state MLC uses commercially reasonable physical, electronic, and managerial security measures to assist in protecting against the loss, misuse, and unauthorized alteration of personally identifiable information that is under their control. This includes the use of firewalls, encryption during transmission and at rest, vulnerability scans, and other security measures. However, MLC cannot guarantee the security of their servers, or the means by which personally identifiable information is transmitted between a user's computer and their servers, and does not disclose whether they provide notice to users in the event of a data breach.

Compliance

The terms do not disclose whether personal information is collected from students in K-12 or children under 13 years of age, how that information is used, or MLC's disclosure practices of that information without parental consent. MLC's apps would likely appeal to children under 13 years of age, which takes several factors into consideration such as: the subject matter, visual content, the use of animated characters or child-oriented activities and incentives, music or other audio content, age of models, presence of child celebrities or celebrities who appeal to children, language or other characteristics of the product.

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 Assessment7555

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 information8345
Data Sharing: Protecting data from third parties10065
Data Security: Protecting against unauthorized access8365
Data Rights: Controlling rights to data8895
Data Sold: Preventing sale of data10060
Data Safety: Promoting responsible use8365
Ads & Tracking: Prohibiting the exploitation of users' decision making process6455
Parental Consent: Protecting children’s personal information00
School Purpose: Following student data privacy laws038
Individual Control: Controlling data useNA75

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)8158
Children's Online Privacy Protection Act (COPPA)7453
Family Educational Rights and Privacy Act (FERPA)5752
Student Online Personal Information Protection Act (SOPIPA)7564
General Data Protection Regulation (GDPR)7764
The California Consumer Privacy Act (CCPA)8368

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 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
  • Unclear whether intended for children under 13.
  • Unclear whether intended for teens.
  • Unclear whether intended for adults over 18.
  • Unclear whether intended for parents or guardians.
  • Unclear whether 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.
  • Interactions, behaviors, or usage analytics data are collected.
  • Unclear whether this product collects sensitive data.
  • Data is automatically collected.
2.2: Data Source
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Unclear whether this product collects personal information from children under 13 years of age.
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.
  • 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
  • Specific categories of information 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
  • Links to third-party external websites are not 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
  • Unclear whether 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 not available.
3.13: Third-Party Data Combination
  • Company will not 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 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
  • 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
  • Opt-in consent is 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 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.
  • 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.
  • Any copyright license to a user's data is not 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 does not attempt 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.
  • Unclear whether a user can assign an authorized account manager or legacy contact.

7: Data Transfer

7.1: Data Handling
  • User information cannot be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
  • 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
  • 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.
  • 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.
  • 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 not 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
  • Users can interact with trusted users.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information must be not 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 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
  • 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 not displayed.
10.3: Behavioral Advertising
  • Personalised advertising is not 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
  • 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
  • Unclear whether this product provides users the ability to 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 not 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 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.
  • 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 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.
  • Unclear whether the company has indicated it is a Data Controller or Data Processor.