Overview

Thrively is a personalized learning platform that uncovers student's strengths and interests and then helps students find their purpose, build skills, and create personal impact to unleash their full potential. The terms state Thrively may filter information to ensure age appropriateness and may also offer users the ability to post user generated content that is visible publicly to other users. Thrively's terms say they do not sell, rent, trade or share any personal information with third parties for their marketing purposes and they do not send marketing communications to children or students. In addition, the terms state any information collected by Thrively is stored using standard security and encryption procedures and practices that they believe are appropriate to the nature of the information. Lastly, the terms state that when a parent or teacher registers with Thrively they are required to provide their name, email, and provide their child or student’s name, age, and gender.

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

Safety

The terms state Thrively may filter information to ensure age appropriateness and may also offer users the ability to post user generated content that is visible publicly to other users. Public content could include any information a user submits to any area of the service open to other users or the general public. In addition, if a user posts user ratings or reviews, comments related to activities, respond to public surveys, or participate in other social media they should be aware that any personally identifiable information they submit there can be read, collected, or used by other users to send them unsolicited messages.

Privacy

The terms state the service collects personal information and automatically generated usage information. In addition, Thrively's terms state if it is informed that an account holder is under thirteen (13) years of age, they will only request a user’s first name and last initial, and not other personally identifying information such as email address or mailing address. The terms say Thrively will retain information collected from a child only so long as reasonably necessary to fulfill an activity request or allow the child to continue to participate in the activity.

Thrively's terms say they do not sell, rent, trade or share any personal information with third parties for their marketing purposes and they do not send marketing communications to children or students. Moreover, the terms state Thrively does not advertise or send promotional messages to students and ads are not be displayed on Thrively for any user. However, Thrively's terms do state they collect personal information for third-party tracking purposes and share student data with third parties in a de-identified format to allow Thrively to market products or services to parents through the service.

Security

The terms state any information collected by Thrively is stored using standard security and encryption procedures and practices that they believe are appropriate to the nature of the information. However, the terms do not provide any additional information about how data is protected and do not disclose whether notice is provided in the event of a data breach.

Compliance

The terms state that when a parent or teacher registers with Thrively they are required to provide their name, email, and provide their child or student’s name, age, and gender. If a user is under 13 years of age, the terms state Thrively will obtain verifiable parental consent in order to collect, use or disclose their personal information. In addition, only a child's teacher or parent may instruct Thrively to activate their account because student accounts must be connected to a teacher or parent account.

Thrively's terms state that at any time, schools and parents can request that to access, modify, and delete any personal information they have collected about a child or student. In addition, the terms state a school or other institution must obtain any necessary permission from each student’s parents. The terms say it is typical for schools to obtain this permission at the beginning of the academic year for all educational software they plan to use.

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 information8355
Data Sharing: Protecting data from third parties5055
Data Security: Protecting against unauthorized access3345
Data Rights: Controlling rights to data8875
Data Sold: Preventing sale of data7535
Data Safety: Promoting responsible use6750
Ads & Tracking: Prohibiting the exploitation of users' decision making process7165
Parental Consent: Protecting children’s personal information10065
School Purpose: Following student data privacy laws10075
Individual Control: Controlling data useNA45

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)8164
Children's Online Privacy Protection Act (COPPA)7661
Family Educational Rights and Privacy Act (FERPA)7159
Student Online Personal Information Protection Act (SOPIPA)7061
General Data Protection Regulation (GDPR)7355
The California Consumer Privacy Act (CCPA)7060

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
  • 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.
  • Not intended for teens.
  • Intended for adults over 18.
  • Unclear whether 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.
  • Biometric or health data are collected.
  • Unclear whether this product collects interactions, behaviors, or usage analytics data.
  • Unclear whether this product collects sensitive data.
  • 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
  • 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 not 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
  • 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 not 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 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.
  • 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
  • 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
  • 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
  • Unclear whether 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.
  • 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.
  • 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
  • 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
  • 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.
  • 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
  • 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.
  • 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
  • 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
  • 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 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 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
  • 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
  • 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
  • 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 primarily used by, designed for, and marketed toward students in grades preK–12.
  • Processes to enter education records into the product are 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.
  • Unclear whether this product allows parents to 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.
  • 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.
  • 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.