Overview

The terms of Sutori state that the site is intended for children, students, and teachers in school settings. The terms further state that they do collect personal information, including from children, but only from children with parental consent, which is generally obtained by schools. Sutori's terms state that accounts are needed to use the service, for which social logins are an option. According to the terms, Sutori shares information with third-party service providers to provide various services, and they hold those providers to data protection agreements. The terms state that users can upload content to the service, and that they may use that content, if it was made public, to promote Sutori. The terms also state that they will never sell content to third parties nor use student data for commercial purposes. It isn't clear from the terms whether ads are shown on the service in general, but no ads will be displayed on the Education platform to students. The terms state that they do use third-party tracking technologies to collect information from users, and also that data collected may help third parties show interest-based ads. According to Sutori's terms, they use reasonable security methods to protect data, including using HTTPS encryption, but it is not clear whether all data in transit and at rest is encrypted. The terms do state that they will inform users of a data breach. Sutori's terms state that teachers can create classrooms on the platform and that what they set up there with their students remains private. The terms otherwise state, however, that users' names are made public when they publicly share stories (those under 13 just include first name and last initial), and anything included on user profiles may be made public. Finally, the terms state that users can access, modify, or delete their personal information on the service.

Sutori can be accessed through its website. The Privacy Policy and Terms of Use used for this evaluation can be found on Sutori’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

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 Assessment74NA

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 information50NA
Data Sharing: Protecting data from third parties100NA
Data Security: Protecting against unauthorized access33NA
Data Rights: Controlling rights to data88NA
Data Sold: Preventing sale of data75NA
Data Safety: Promoting responsible use50NA
Ads & Tracking: Prohibiting the exploitation of users' decision making process67NA
Parental Consent: Protecting children’s personal information100NA
School Purpose: Following student data privacy laws100NA
Individual Control: Controlling data useNANA

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)75NA
Children's Online Privacy Protection Act (COPPA)76NA
Family Educational Rights and Privacy Act (FERPA)81NA
Student Online Personal Information Protection Act (SOPIPA)88NA
General Data Protection Regulation (GDPR)79NA

Privacy Policy Details

1: Transparency

1.1: Policy Version
  • Privacy policies do indicate a version or effective date.
  • This evaluation did not assess whether privacy policies indicate a change log or past policy version is available.
1.2: Policy Notice
  • This evaluation did not assess whether users are notified if there are any material changes to the policies.
  • This evaluation did not assess whether privacy policies indicate the method used to notify a user when policies are updated.
1.3: Policy Changes
  • This evaluation did not assess whether users are notified prior to any material changes to the policies.
  • This evaluation did not assess whether changes to the policies are effective immediately and continued use of the product indicates consent.
1.4: Policy Coverage
  • This evaluation did not assess whether privacy policies indicate the products that are covered by the policies.
1.5: Privacy Contact
  • This evaluation did not assess whether users can contact the company about any privacy policy questions, complaints, or material changes to the policies.
1.6: Policy Principles
  • This evaluation did not assess whether privacy policies indicate any privacy principles, layered notices, or a table of contents.
1.7: Policy Language
  • This evaluation did not assess whether privacy policies are available in multiple languages.
1.8: Intended Use
  • Intended for children under 13.
  • This evaluation did not assess whether intended for teens.
  • This evaluation did not assess whether intended for adults over 18.
  • This evaluation did not assess whether intended for parents or guardians.
  • Intended for students.
  • This evaluation did not assess whether intended for teachers.

2: Focused Collection

2.1: Data Collection
  • Personally identifiable information (PII) is collected.
  • This evaluation did not assess whether the categories of collected personally identifiable information are indicated.
  • This evaluation did not assess whether this product collects geolocation data.
  • This evaluation did not assess whether this product collects biometric or health data.
  • This evaluation did not assess whether this product collects behavioral data.
  • This evaluation did not assess whether this product collects sensitive data.
  • This evaluation did not assess whether this product automatically collects any data.
2.2: Data Source
  • This evaluation did not assess whether personal information or education records are collected from preK-12 students.
  • This evaluation did not assess whether this product collects personal information from children under 13 years of age.
2.3: Data Excluded
  • This evaluation did not assess whether specific types of personal information are excluded from collection.
  • This evaluation did not assess 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
  • This evaluation did not assess whether the purpose for sharing a user's personal information with third parties is indicated.
  • This evaluation did not assess whether data are shared for analytics.
  • This evaluation did not assess whether data are shared for research and/or product improvement.
  • Personal information is not shared for third-party marketing.
3.3: Data Not Shared With Third Parties
  • This evaluation did not assess 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
  • This evaluation did not assess whether personal information about users is obtained from third parties.
3.6: Third-Party Links
  • This evaluation did not assess whether third-party external websites are age-appropriate.
3.7: Third-Party Data Access
  • This evaluation did not assess whether third parties are authorized to access a user's information.
3.8: Third-Party Data Collection
  • This evaluation did not assess whether personal information of users is collected by a third party.
3.9: Third-Party Data Misuse
  • This evaluation did not assess whether personal information can be deleted from a third party.
3.10: Third-Party Service Providers
  • This evaluation did not assess whether third-party services are used to support the product.
  • This evaluation did not assess whether the roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
  • This evaluation did not assess whether the categories of third parties that receive data are indicated.
3.12: Third-Party Policies
  • This evaluation did not assess whether links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
  • This evaluation did not assess whether company may combine data with additional data from third-party sources.
  • This evaluation did not assess whether data shared with third parties can be combined with other data.
3.14: Third-Party Authentication
  • Third-party login is supported.
  • This evaluation did not assess whether personal information from third-party login providers is collected.
  • This evaluation did not assess whether personal Information is shared with third-party login providers.
3.15: De-identified or Anonymized Data
  • This evaluation did not assess whether user information is shared in an anonymous or de-identified format.
  • This evaluation did not assess 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.
  • This evaluation did not assess whether contractual limits prohibit third parties from reidentifying or de-identified information.

4: Respect for Context

4.1: Data Use
  • This evaluation did not assess whether use of information is limited to the purpose for which it was collected.
  • This evaluation did not assess whether the conext or purpose for which data are collected is indicated.
4.2: Data Combination
  • This evaluation did not assess whether this product treats combined information as personally identifiable information (PII).
4.3: Data Notice
  • This evaluation did not assess whether notice is provided if the context in which data are collected change.
4.4: Data Changes
  • This evaluation did not assess whether consent is obtained if the practices in which data are collected change.
4.5: Policy Enforcement
  • This evaluation did not assess whether 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
  • This evaluation did not assess whether opt-in consent is requested from users at the time personal information is collected.
5.3: Remedy Process
  • This evaluation did not assess whether a grievance or remedy mechanism is available for users to file a complaint.
5.4: Data Settings
  • This evaluation did not assess whether users can control the use of their information through privacy settings.
5.5: Data Disclosure
  • This evaluation did not assess whether users can opt out from the disclosure or sale of their data to a third party.
  • This evaluation did not assess whether users can request to know what personal information has been shared with third parties.
  • This evaluation did not assess whether notice is provided in the event the company receives a government or legal request for a user's information.
5.6: Intellectual Property
  • This evaluation did not assess whether users retain ownership of their data.
  • This evaluation did not assess whether a copyright license is claimed to data or content collected from a user.
  • This evaluation did not assess 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.
  • This evaluation did not assess whether methods are available to restrict who has access to data.
  • This evaluation did not assess whether the school, parents, or students can review student data.
6.2: Data Integrity
  • This evaluation did not assess 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.
  • This evaluation did not assess whether the school, parents, or students can modify inaccurate student information.
  • This evaluation did not assess whether the time period for the company to modify inaccurate data is indicated.
6.4: Data Retention
  • This evaluation did not assess whether the product provides a data-retention policy.
  • This evaluation did not assess whether exceptions to the data retention policy exist.
6.5: Data Deletion
  • This evaluation did not assess whether this product deletes data when no longer necessary.
  • This evaluation did not assess whether a user's data are deleted upon account cancellation or termination.
  • This evaluation did not assess whether a user can delete all their data.
  • Processes for authorized users to delete data are available.
  • This evaluation did not assess whether the time period for the company to delete data is indicated.
6.6: Data Portability
  • This evaluation did not assess whether this product provides users the ability to download their data.
  • This evaluation did not assess 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.
  • This evaluation did not assess whether notice is provided to users if the company assigns its rights or delegates its duties to another company.
  • This evaluation did not assess whether users are notified if their information is transferred to a third party.
7.2: Transfer Request
  • This evaluation did not assess whether user information can be deleted prior to its transfer to a third party.
7.3: Onward Contractual Obligations
  • This evaluation did not assess whether third-party transfers are contractually required to use the same privacy practices.

8: Security

8.1: User Identity
  • This evaluation did not assess whether a user's identity is verified with additional personal information.
8.2: User Account
  • Account creation is required.
  • Unclear whether managed accounts are available.
  • This evaluation did not assess whether multi-factor account protection is available.
8.3: Third-Party Security
  • This evaluation did not assess 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.
  • This evaluation did not assess 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.
  • This evaluation did not assess 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
  • This evaluation did not assess whether this product performs data-privacy and/or security-compliance audits.

9: Responsible Use

9.1: Social Interactions
  • Users can interact with trusted users.
  • This evaluation did not assess whether users can interact with untrusted users, including strangers and/or adults.
  • This evaluation did not assess whether profile information must be shared for social interactions.
9.2: Data Visibility
  • Personal information can be displayed publicly.
  • This evaluation did not assess whether this product allows users to control how their data are displayed to others.
9.3: Monitor and Review
  • This evaluation did not assess whether user-created content is 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.
  • This evaluation did not assess whether social interactions of users are logged.
9.4: Report Content
  • This evaluation did not assess whether users can filter or block inappropriate content.
  • This evaluation did not assess whether users can report abuse or cyberbullying.
9.5: Internet Safety
  • This evaluation did not assess whether the company provides links to resources that support safe and appropriate social interactions.

10: Advertising

10.1: Vendor Communications
  • This evaluation did not assess whether 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 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 not created and used for personalised advertisements.
10.5: Filtered Advertising
  • This evaluation did not assess whether ads displayed to children are filtered for inappropriate content.
10.6: Marketing Communications
  • This evaluation did not assess whether this company can send marketing messages.
  • This evaluation did not assess whether this company provides promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
  • This evaluation did not assess whether this product provides users the ability to opt-out of contextual, or personalised advertising.
  • This evaluation did not assess whether users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
  • This evaluation did not assess whether this product responds to "Do Not Track" or other opt-out mechanisms.
  • This evaluation did not assess whether the company provides a method for users to opt-out from third-party tracking.

11: Compliance

11.1: Children Under 13
  • This evaluation did not assess whether company has actual knowledge that personal information from users under 13 years of age is collected.
  • This evaluation did not assess if the company provides a section, heading, or separate policy for children in their policies.
  • This evaluation did not assess 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.
  • This evaluation did not assess whether the processes to enter education records into the product are clear.
  • This evaluation did not assess whether additional rights or protections may be provided with an additional school contract.
  • This evaluation did not assess whether the company is designated as a school official.
11.3: Parental Consent
  • Parental consent is required before personal information is collected or disclosed.
  • This evaluation did not assess whether this product limits parental consent with respect to third parties.
  • This evaluation did not assess whether this product allows parents to withdraw consent for the further collection of their child's information.
  • This evaluation did not assess whether this product deletes children's personal information if collected without parental consent.
  • Parental consent notice and method for submission are provided.
  • This evaluation did not assess whether this product transfers parental consent obligations to the school or district.
11.4: Legal Requirements
  • This evaluation did not assess whether the legal jurisdiction that applies to the laws governing the policies is indicated.
  • This evaluation did not assess whether a user is required to waive the right to a jury trial, or settle any disputes by arbitration.
  • This evaluation did not assess whether a user is required to waive the right to join a class action lawsuit.
  • This evaluation did not assess whether a company will disclose personal information to law enforcement.
11.5: Certification
  • This evaluation did not assess whether the company has signed a privacy pledge or received a privacy certification.
11.6: International Laws
  • This evaluation did not assess whether a user's data are subject to International data transfer or jurisdiction laws.
  • This evaluation did not assess whether the company has indicated it is a Data Controller or Data Processor.