Overview
Akindi is a mobile app that allows users to quickly grade assessments with their mobile camera and get immediate results, insights, and analysis. Akindi offers different levels of the service, ranging from free to fee-based that integrates with learning management systems. When using Akindi, teachers upload information about students. Akindi's FAQs describe using school-assigned student IDs, along with student names, to connect grades with students. Akindi's terms state that Akindi will "take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction." Lastly, Akindi's terms do not mention FERPA, school official status under FERPA, or parental consent.
Akindi can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Akindi’s website and 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 of Akindi state it is a grading program, with most activity in the service coming from teachers. The terms of service prohibit offensive or abusive behavior, but do not provide details about if, how, or where this behavior could occur within the system.
Privacy
When using Akindi, teachers upload information about students. Akindi's FAQ describes using school-assigned student IDs, along with student names, to connect grades with students. Akindi's terms do not contain details about any third parties used to support the service. The terms also do not contain details about how data will be handled in case of a sale, merger, or bankruptcy.
The terms also state that Akindi will keep "personal information only as long as we need it for the purposes for which we collected it, or as permitted by law." It is unclear from the terms if or how Akindi tracks various laws and requirements about data deletion, and how these requirements would be applied.
Security
Akindi's terms state that Akindi will "take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction." However, the terms do not contain any details on whether data is encrypted at rest or in transit. In addition, the terms do not contain details about how users will be notified in case of a data breach.
Compliance
Akindi's terms do not mention FERPA, school official status under FERPA, or parental consent. The terms specify that Akindi will "provide ways for you to access your personal information, as required by law, so you can correct inaccuracies" but it is not clear how this would happen, and if this right to review extends to students or parents that have educational information stored in Akindi. If, as suggested in Akindi's FAQ at https://akindi.com/pages/faq, a teacher is using a school assigned student ID number to track students, the teacher should verify that school IDs have been designated as directory information under FERPA.
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 | 37 | 28 |
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 | 15 |
| Data Sharing: Protecting data from third parties | 25 | 20 |
| Data Security: Protecting against unauthorized access | 33 | 25 |
| Data Rights: Controlling data use | 63 | 65 |
| Data Sold: Preventing sale of data | 0 | 10 |
| Data Safety: Promoting responsible use | 0 | 0 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 8 | 10 |
| Parental Consent: Protecting children’s personal information | 67 | 30 |
| School Purpose: Following student data privacy laws | 100 | 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) | 58 | 29 |
| Children's Online Privacy Protection Act (COPPA) | 30 | 21 |
| Family Educational Rights and Privacy Act (FERPA) | 61 | 24 |
| Student Online Personal Information Protection Act (SOPIPA) | 31 | 20 |
| General Data Protection Regulation (GDPR) | 54 | 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 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
- Unclear whether users are notified prior to any material changes to the policies.
- Unclear whether 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
- Not intended for children under 13.
- Unclear whether intended for teens.
- Intended for adults over 18.
- Not intended for parents or guardians.
- Not intended for students.
- Intended for teachers.
2: Focused Collection
2.1: Data Collection
- Personally identifiable information (PII) is collected.
- Unclear if the categories of personally identifiable information collected are indicated.
- Unclear whether this product collects geolocation data.
- Unclear whether this product collects biometric or health data.
- Unclear whether this product collects behavioral data.
- Unclear whether this product collects sensitive data.
- Unclear whether this product collects non-personally identifiable information.
- Unclear whether free or reduced lunch status is collected.
2.2: Data Source
- Personal information or education records are collected from preK-12 students.
- Unclear whether this product collects personal information online from children under 13 years of age.
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.
- Unclear whether 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.
- Unclear whether data are shared for analytics.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether data are shared for third-party advertising and/or marketing.
3.3: Data Not Shared With Third Parties
- Unclear whether there are specific categories of information that are not shared with third parties.
3.4: Data Sold to Third Parties
- Unclear whether data are 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
- Unclear whether links to third-party external websites are 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 if found to be misused.
3.10: Third-Party Service Providers
- Unclear whether data are shared with third-party service providers.
- Unclear whether 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
- Unclear whether links to privacy policies of third-party companies are 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
- Unclear whether 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.
- Unclear whether 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.
- Unclear whether the 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
- Unclear 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
- 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 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 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 not 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 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
- The vendor does maintain the accuracy of data they collect.
6.3: Data Correction
- Processes to modify inaccurate data are available.
- Unclear whether the school, parents, or students can modify data.
- Unclear whether the time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- Unclear whether 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.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Unclear whether a user can delete all their data.
- Unclear whether the school, parents, or students can delete data.
- 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
- Unclear whether user information can be transferred to a third party.
- 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.
- Unclear whether 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
- Unclear whether this product encrypts all data at rest.
- Unclear whether personal information of users is 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
- Data-privacy and security-compliance audits are performed.
9: Responsible Use
9.1: Social Interactions
- Unclear whether this product supports interactions between trusted users and/or students.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information is shared for social interactions.
9.2: Data Visibility
- Unclear whether this product displays personal information publicly.
- Unclear whether this product allows users to control how their data are displayed.
9.3: Monitor and Review
- Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
- 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 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 displayed.
10.3: Behavioral Advertising
- Unclear whether this product displays behavioral or targeted advertising.
10.4: Ad Tracking
- Unclear whether this product allows data collection by third-party advertising or tracking services.
- Unclear whether this product uses data to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
- Unclear whether children may receive inappropriate advertisements.
10.6: Marketing Communications
- The vendor can send marketing messages.
- Unclear whether this vendor provides 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.
- Unclear whether this product provides users the ability to 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
- Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
- Unclear whether children's privacy is applicable.
- Unclear whether this product restricts account creation 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.
- Unclear whether the product creates education records.
- Unclear whether this product provides notification of a contract or additional rights.
- 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.
- 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 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.
- 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 any dispute is indicated.
- Unclear whether a user is required to waive the right to a jury trial, or settle any disputes by arbitration.
- Unclear whether a user is required to waive the right to join a class action lawsuit.
- Unclear whether a vendor will disclose personal information to law enforcement.
11.5: Certification
- The vendor 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, such as the GDPR.
- Unclear whether the vendor has indicated it is a Data Controller or Data Processor.