Common Sense Privacy Program

thumbnail

Standard Privacy Report for BrainRush

Last updated
Applications and services with a Fail rating do not have a privacy policy and/or do not use encryption and should not be used. Applications and services with a Fail rating have issues narrowly focused on whether a detailed privacy policy is available for evaluation and whether collected information is protected with default encryption during login or account creation to protect child and student data.

40%

Fail

Learn how we rate

Overview

The BrainRush platform provides a supply of learning games that teachers can assign to students. We did not complete a privacy evaluation on BrainRush because this product does not enforce encryption on login. For many schools, districts, and parents, the use of encryption on registration and login is a minimum requirement.

BrainRush can be accessed through its website. The Privacy Policy and Terms of Use accessed for this evaluation can be found on BrainRush’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 Assessment4028

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 information2515
Data Sharing: Protecting data from third parties5050
Data Security: Protecting against unauthorized access3325
Data Rights: Controlling data use3830
Data Sold: Preventing sale of data7535
Data Safety: Promoting responsible use5040
Ads & Tracking: Prohibiting the exploitation of users' decision making process3335
Parental Consent: Protecting children’s personal information3310
School Purpose: Following student data privacy laws00

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)5031
Children's Online Privacy Protection Act (COPPA)4332
Family Educational Rights and Privacy Act (FERPA)3919
Student Online Personal Information Protection Act (SOPIPA)5040
General Data Protection Regulation (GDPR)4334

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 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
  • Users are not 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.
  • 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.
  • 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.
  • Behavioral data are collected.
  • 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
  • Unclear whether 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
  • 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.
  • Unclear whether 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 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
  • Data are not sold or rented to third parties.
3.5: Third-Party Data Acquisition
  • 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
  • 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.
  • 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
  • Data can be combined with data from third-party sources.
  • 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 not shared in an anonymous or deidentified format.
  • Unclear whether the vendor describes their deidentification process of user information.
3.16: Third-Party Contractual Obligations
  • 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 not 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
  • Notice is not provided if the context in which data are collected changes.
4.4: Data Changes
  • Consent is not 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 not 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
  • Unclear whether 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.
  • Unclear whether 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
  • Unclear whether 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.
  • Unclear whether 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
  • Unclear whether this product provides processes to access and review user data.
  • 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.
  • 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
  • Unclear whether this product deletes data when no longer necessary.
  • A user's data are not 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
  • 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
  • Third-party transfer is 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
  • 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
  • Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
  • User-created content is not 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
  • Unclear whether a user can receive service- or administrative-related communications from the vendor.
10.2: Traditional Advertising
  • Unclear whether this product displays traditional or contextual advertisements.
10.3: Behavioral Advertising
  • Behavioral or targeted advertising is displayed.
10.4: Ad Tracking
  • Data are collected 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.
  • Data profiles are created and used for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
  • Unclear whether children may receive inappropriate advertisements.
10.6: Marketing Communications
  • Unclear whether this 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
  • 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
  • Unclear whether this 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
  • Unclear whether this product requires parental consent.
  • 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.
  • A user is not 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.
  • 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
  • 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.
Return to Privacy Evaluation
Common Sense Media provides this standard privacy report for use by the general public for research and education purposes only. The accuracy, completeness, or adequacy of the content provided or evaluation results derived from a product’s policies is not warranted or guaranteed.