Overview

Edpuzzle is a platform that helps teachers engage with their students through video learning. The Privacy Policy states that teacher profiles are publicly viewable through Edpuzzle's search engine, however, that student profiles are not visible to the general public. The Privacy Policy provides that Edpuzzle collects personal information including first and last names, email addresses, unique usernames, passwords, a unique code provided by a teacher in order to join a class, and a profile photo. While the Privacy Policy states that personal information is shared with third parties, the terms fail to state what information is shared. The Privacy Policy states that users’ information is encrypted in transit, but states that only users’ passwords are encrypted for information in storage. The terms clearly and unambiguously designate schools as the responsible party for obtaining parental consent, and/or determining whether a FERPA exception exists, before a student under the age of 13 can use Edpuzzle and have their information collected by Edpuzzle.

Edpuzzle can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Edpuzzle’s website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms do not clearly indicate if certain user information is required to be shared or revealed in order to participate in social interactions. However, the Privacy Policy states that teacher profiles may be viewed by other teachers in the same school, or when searching for the teacher’s profile through Edpuzzle’s search engine. The Terms of Service clearly indicate that users may interact with both trusted users and untrusted users because “Edpuzzle cannot guarantee the identity of any other users with whom you may interact.” The terms do not disclose whether Edpuzzle reviews, screens, or monitors user-created content, takes reasonable measures to delete personal information from a user’s posting before they are made publicly available, or whether social interactions may be moderated or logged for review. The terms do not disclose whether users can report inappropriate content, harassment, or cyberbullying.

Privacy

The Privacy Policy clearly discloses that Edpuzzle collects behavioral data in the form of the frequency and duration of site visits, teachers’ precise geolocation information, and usage data including students’ viewing history, quiz responses, browser type, IP addresses, and device information. The Privacy Policy provides that the collection and purpose of personal information is limited to only data that are specifically required for the product and providing the product’s services. The Privacy Policy indicates that third parties are unable to collect users’ personal information, unless the user directly provides a third party with their personal information.

The Privacy Policy clearly indicates that Edpuzzle shares personal information with third parties for analytics, research, marketing, and to support Edpuzzle. Also, the Privacy Policy indicates that third-party log-in is available, including through an educational institution’s learning management system, and that Edpuzzle collects information from third party log-in platforms. Furthermore, the Privacy Policy says that Edpuzzle does not sell users’ personal information. However, the Privacy Policy indicates that teachers and parents may be subject to direct marketing and advertising. The Privacy Policy does not disclose whether users are able to opt-out of any advertising or marketing communications.

Security

The Privacy Policy clearly indicates that users’ personal information is protected with reasonable security, including physical access controls to limit employee access to user information. The Privacy Policy indicates that an account is required to use Edpuzzle and that Edpuzzle provides schools and teachers with managed accounts to control students’ use of Edpuzzle and to control students’ personal information. The Privacy Policy provides that Edpuzzle verifies the user’s identity with additional personal information when the user makes a privacy request. The Privacy Policy does not clearly indicate whether the security of a user’s account is protected by multi-factor authentication. The Privacy Policy states that in the event of a data breach, affected users will be notified “no later than forty-height [sic] (48) hours of such discovery.”

Compliance

The terms clearly indicate that users can create “User Submissions” on Edpuzzle, and that users retain all ownership rights for their content, granting Edpuzzle a limited, narrow license over the content. The terms disclose that authorized individuals, including current employees of an educational institution, are granted access to review, modify, and delete users’ information. The Privacy Policy provides that Edpuzzle automatically deletes inactive accounts and the user’s information after 18 months of inactivity, and that users can receive a copy of their information in a portable format. The Privacy Policy provides that users can control with whom they share information.

The terms fail to state whether Edpuzzle knowingly collects personal information from children under the age of 13 and furthermore fails to include a section designated for children’s privacy. The terms do not clearly indicate whether a parent can consent to the collection and use of their child’s personal information without also consenting to the disclosure of the information to third parties. The Privacy Policy discloses that if Edpuzzle discovers it has “collected information form a child in a manner inconsistent with COPPA, FERPA, GDPR, or any other applicable laws or regulations,” that Edpuzzle will take appropriate steps to delete the information.

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 Assessment8863

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 information8350
Data Sharing: Protecting data from third parties10090
Data Security: Protecting against unauthorized access10080
Data Rights: Controlling rights to data8895
Data Sold: Preventing sale of data7570
Data Safety: Promoting responsible use6730
Ads & Tracking: Prohibiting the exploitation of users' decision making process8660
Parental Consent: Protecting children’s personal information10050
School Purpose: Following student data privacy laws10075
Individual Control: Controlling data useNA55

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)9383
Children's Online Privacy Protection Act (COPPA)8666
Family Educational Rights and Privacy Act (FERPA)9474
Student Online Personal Information Protection Act (SOPIPA)9280
General Data Protection Regulation (GDPR)9775

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.
  • Unclear whether intended for teens.
  • Intended for adults over 18.
  • Not 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.
  • Unclear whether this product collects biometric or health data.
  • Interactions, behaviors, or usage analytics data are collected.
  • 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.
  • 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
  • Personal information about users is obtained 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
  • Third parties are authorized to access a user's information.
3.8: Third-Party Data Collection
  • Personal information of users is not 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
  • The categories of third parties that receive data are indicated.
3.12: Third-Party Policies
  • Links to privacy policies of third-party companies are 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
  • Third-party login is supported.
  • 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 not shared in an anonymous or de-identified format.
  • 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.
  • Unclear whether 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
  • Combined information is treated 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
  • 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
  • Unclear whether 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
  • Unclear whether 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.
  • Unclear whether 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.
  • 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.
  • Methods are available to restrict who has access to data.
  • Processes to review student data are available for the school, parents, or students.
6.2: Data Integrity
  • 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.
  • 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
  • Processes to download user data are available.
  • 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 notice is provided to users if the company assigns its rights or delegates its duties to another company.
  • Users are notified if their information is transferred to a third party.
7.2: Transfer Request
  • 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
  • Unclear whether 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
  • 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.
  • Employee or physical access to user information is limited.
8.5: Data Transmission
  • All data in transit are encrypted.
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
  • Notice is provided 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.
  • Unclear whether 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
  • Unclear whether user-created content is reviewed, screened, or monitored by the company.
  • 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
  • The company provides links to resources that support safe and appropriate social interactions.

10: Advertising

10.1: Vendor Communications
  • A user can receive service- or administrative-related communications from the company.
10.2: Traditional Advertising
  • Traditional or contextual advertisements are displayed.
10.3: Behavioral Advertising
  • Personalised advertising is not displayed.
10.4: Ad Tracking
  • Data are not collected by third-parties for their own purposes.
  • User's information is not 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
  • Unclear whether ads displayed to children are filtered for inappropriate content.
10.6: Marketing Communications
  • The company can send marketing messages.
  • Unclear whether this company provides promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
  • Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
  • Unclear whether users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
  • Company does not respond to "Do Not Track" or other opt-out mechanisms.
  • The company does provide a method for users to opt-out from third-party tracking.

11: Compliance

11.1: Children Under 13
  • Unclear whether company has actual knowledge that personal information from users under 13 years of age is collected.
  • The company does not provide a section, heading, or separate policy for children in their policies.
  • Unclear 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.
  • 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 not 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 not 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
  • 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.
  • The company has indicated it is a Data Controller or Data Processor.