Overview
Samsung Bixby is the automated voice assistant incorporated in many Samsung electronics. Samsung Bixby does not have its own privacy policy, but instead is referenced in Samsung’s general privacy policy and terms of use. These terms do not clearly state whether users can control how their personal information is shared with other users; whether user generated content is filtered before personal information becomes publicly visible; or whether social interactions of users are logged.The privacy policy indicates that Samsung collects the following types of personal information: (1) contact information such as postal address, email address, payment card information; (2) voice recordings; and (3) location data and precise geolocation. The policy indicates that personal information from these categories and other categories of personal information listed in the terms are shared with third parties. The terms state that information is shared with third party ad networks to deliver customized advertisements on Samsung platforms. The terms do not indicate whether third parties that have access to users’ personal information are required to provide the same security protections as Samsung; whether Samsung limits employee access to user information; whether personal information is encrypted in transit or when stored; or whether Samsung gives notice to the user in the event of data breach. The policies do not clearly state whether Samasung deletes user data when it is no longer necessary; whether user data are deleted upon account termination; or whether there are methods available for users to restrict who has access to their data.
Information about Samsung Bixby can be accessed through its website. The Privacy Policy and Terms of Use. Additionally, other policies used for this evaluation include: Samsung Ads. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The terms provide that some of Samsung's services enable users to communicate with other people and those other users may be able to see information stored or displayed in connection with a user's account on the social networking service with which they connect. However, a user's account privacy settings may allow them to limit the other users who can see the information in their user profile and/or what information in their user profile is visible to others.
Privacy
Samsung's terms state users can control their mobile device, and use many of its features, with voice commands with Bixby. For example, Samsung's customization service can improve a user's experience by offering hints and information customized for that user when they use Samsung’s voice recognition service Bixby. To provide the Bixby voice services, some voice commands may be transmitted (along with information about a use's device and its usage, including device identifiers) to a third-party service provider that converts their voice commands to text. In addition, Samsung's terms state they may collect information a user exchanges with Bixby through their interactions with the services, including recordings of their voice commands (such as their questions, requests and instructions), their pictures, and other inputs, and the information they receive from the services (such as responses, answers and content).
The terms state Samsung may combine information from or about a user, including across different services or devices. For example, the terms state that Samsung may use a user’s account details across all of the services that require a Samsung account. In addition, the terms state the service may use a user's personal information to display customized advertisements about products and services that may be of interest to them. Users may opt-out of targeted advertisements, but may continue to receive traditional advertisements which will be based on other information such as generalized location, and other estimated or inferred information.
The terms state Samsung may use third-party tracking technologies for a variety of purposes, including to analyze the use of their services and (in conjunction with cookies) to provide content and ads that are more relevant to users. Certain third parties may serve advertising or keep track of which advertisements users see, how often they see those advertisements, and what users do in response to them. Lastly, Samsung’s customization service may collect, analyze and share information about a user’s use of the services and online activities, over time and across third-party websites and apps, as well as across devices, to provide them with advertising and direct marketing communications about products and services offered by Samsung and third parties.
Security
Samsung's terms state a number of their services enable users to create accounts or profiles. To use the customization service, a user must first have a Samsung account which requires users to provide certain information about themselves to set up the account or profile. In addition, the terms state Samsung maintains administrative, technical and physical safeguards designed to protect the personal information they obtain through the services and the customization service against unlawful or unauthorized destruction, interference, loss, alteration, access, disclosure or use.
However, the terms do not disclose whether standard industry security protections like encryption are used to protect personal information in transit or while at rest. Lastly, the terms do not disclose whether notification is provided to users in the event of a data breach.
Compliance
Samsung's terms state children under 13 years of age should not attempt to register for its services or send any personal information about themselves to Samsung. In addition, the terms state Samsung does not knowingly collect or solicit personally identifiable information from children under 13 without parental consent. If Samsung learns that a child under the age of 13 has provided Samsung with personal information they will delete it. The terms state users can access, rectify, or delete their personal information through the service at any time. Lastly, Samsung's terms state they take reasonable steps to ensure that information about users is available only for so long as is necessary for the purpose for which it is processed.
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 | 48 | 35 |
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 | 50 | 45 |
| Data Sharing: Protecting data from third parties | 50 | 35 |
| Data Security: Protecting against unauthorized access | 0 | 15 |
| Data Rights: Controlling rights to data | 50 | 30 |
| Data Sold: Preventing sale of data | 50 | 20 |
| Data Safety: Promoting responsible use | 67 | 20 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 43 | 40 |
| Parental Consent: Protecting children’s personal information | 50 | 45 |
| School Purpose: Following student data privacy laws | 0 | 19 |
| Individual Control: Controlling data use | NA | 35 |
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) | 63 | 52 |
| Children's Online Privacy Protection Act (COPPA) | 55 | 39 |
| Family Educational Rights and Privacy Act (FERPA) | 36 | 31 |
| Student Online Personal Information Protection Act (SOPIPA) | 45 | 35 |
| General Data Protection Regulation (GDPR) | 43 | 39 |
| The California Consumer Privacy Act (CCPA) | 43 | 36 |
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 not 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 not effective immediately and continued use of the product requires additional 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
- Not intended for children under 13.
- 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
- 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
- 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
- Unclear whether 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 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
- 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.
- Unclear what the roles of third-party service providers are.
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 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
- Unclear whether 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
- Unclear whether 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
- 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
- Unclear whether accounts may be terminated if users engage in any prohibited activities.
5: Individual Control
5.1: User Content
- Unclear whether 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
- 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.
- Unclear whether methods are available to restrict who has access to data.
- Unclear whether the school, parents, or students can review student data.
6.2: Data Integrity
- Unclear whether the company attempts to maintain the accuracy of data they collect.
6.3: Data Correction
- Unclear whether this product provides processes to modify data for authorized users.
- Unclear whether the school, parents, or students can modify inaccurate student information.
- 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.
- Unclear whether 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.
- Unclear whether the time period for the company 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 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
- 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
- Unclear whether this product provides notice 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.
- Unclear whether profile information must be shared for social interactions.
9.2: Data Visibility
- Personal information can be 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.
- 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.
- 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: 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.
- Unclear whether this product uses a user's information 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
- Users can opt out of contextual, or personalised advertising.
- Unclear whether 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
- 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 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.
- 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.
- 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
- Unclear whether 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.