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 Score | Full Score | |
|---|---|---|
| Comprehensive Assessment | 75 | 54 |
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 | 75 | 45 |
| Data Sharing: Protecting data from third parties | 50 | 65 |
| Data Security: Protecting against unauthorized access | 67 | 45 |
| Data Rights: Controlling data use | 88 | 85 |
| Data Sold: Preventing sale of data | 75 | 35 |
| Data Safety: Promoting responsible use | 63 | 50 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 75 | 65 |
| Parental Consent: Protecting children’s personal information | 100 | 60 |
| School Purpose: Following student data privacy laws | 100 | 60 |
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) | 75 | 62 |
| Children's Online Privacy Protection Act (COPPA) | 78 | 61 |
| Family Educational Rights and Privacy Act (FERPA) | 78 | 56 |
| Student Online Personal Information Protection Act (SOPIPA) | 77 | 63 |
| General Data Protection Regulation (GDPR) | 71 | 56 |
Privacy Policy Details
1: Transparency
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Privacy policies do not indicate a changelog 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: Policy Contact
- Users cannot contact the vendor about any privacy policy questions, complaints, or material changes to the policies.
1.6: Policy Principles
- Privacy policies do indicate any 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 behavioral data.
- Unclear whether this product collects sensitive data.
- Non-personally identifiable information is collected.
- Unclear whether free or reduced lunch status is 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 online.
2.3: Data Exclusion
- Unclear whether specific types of personal information are not collected.
- 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.
- Data are not shared for third-party advertising and/or 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
- Data are not sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Unclear whether personal information from users is acquired 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 if found to be misused.
3.10: Third-Party Service Providers
- Data are shared with third-party service providers.
- The roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
- Unclear whether the categories of third parties that receive personal information 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 data can be combined with data from third-party sources.
- Unclear whether data shared with third parties can be combined by third parties for their own purposes.
3.14: Third-Party Authentication
- Unclear whether this product supports social or federated login.
- Unclear whether personal information from social or federated login providers is collected.
- Unclear whether personal Information is shared with social or federated login providers.
3.15: De-identified or Anonymized Data
- User information is shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification 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 deidentified information.
4: Respect for Context
4.1: Data Use
- Use of information is limited to the purpose for which it was collected.
- The purpose for which data atr 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 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 for commercial purposes.
- Unclear whether notice is provided in the event the vendor 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.
- Notice is not provided to users when their content is removed or disabled because of an alleged copyright violation.
6: Access and Accuracy
6.1: Data Access
- Processes to access and review user data are available.
- Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
- Unclear whether the school, parents, or students can review data.
6.2: Data Integrity
- Unclear whether the vendor maintains the accuracy of data they collect.
6.3: Data Correction
- Processes to modify inaccurate data are available.
- Processes for the school, parents, or students to modify data are available.
- Unclear whether the time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- The retention time period of a user's data can be changed upon a valid inspection request.
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 the school, parents, or students to delete data are available.
- Unclear whether the time period for the vendor 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.
- Unclear whether notice is provided to users if the vendor 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
- A user's identity is verified with additional personal information.
8.2: User Account
- Account creation is required.
- Parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
8.3: Third-Party Security
- Unclear whether third-party contractual security protections are required.
8.4: Data Confidentiality
- Industry best 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 at rest are encrypted.
- Personal information of users is not stored with a third party.
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 security-compliance audits.
9: Responsible Use
9.1: Social Interactions
- Users can interact with trusted users and/or students.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
9.2: Data Visibility
- Personal information is displayed publicly.
- Users can control how their data are displayed.
9.3: Monitor and Review
- User-created content is not reviewed, screened, or monitored by the vendor.
- 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 vendor provides links to tools or processes that support safe and appropriate social interactions.
10: Advertising
10.1: Vendor Communications
- A user can receive service- or administrative-related communications from the vendor.
10.2: Traditional Advertising
- Traditional or contextual advertisements are not displayed.
10.3: Behavioral Advertising
- Behavioral or targeted advertising is not displayed.
10.4: Ad Tracking
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
- Children do not receive any inappropriate advertisements.
10.6: Marketing Communications
- The vendor can send marketing messages.
- The vendor does provide promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
- Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral 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 vendor provides a method for users to opt-out from third-party tracking.
11: Compliance
11.1: Children Under 13
- Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- Account creation is restricted for users under 13 years of age.
- Unclear whether this product restricts in-app purchases for users under 13 years of age.
- Unclear whether the vendor participates in an FTC-approved COPPA safe harbor program.
11.2: Students in K–12
- Product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Product does create education records.
- Notification of a contract or additional rights is provided.
- Unclear whether this product designates the vendor as a school official.
11.3: Parental Consent
- Parental consent is required.
- 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.
- The vendor can use collected information to support the “internal operations” of the product.
- Unclear whether this product indicates COPPA parental consent exceptions.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.
- Parental consent obligations are transferred to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing any dispute 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 vendor will disclose personal information to law enforcement.
11.5: Certification
- Unclear whether the vendor 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, such as the GDPR.
- Unclear whether the vendor has indicated it is a Data Controller or Data Processor.