Overview
Educreations is an interactive whiteboard and screencasting tool. The tool is intended for students and teachers, and is used with students under 13 years of age. The terms state that the only users who may view a student's profile are those who belong to that student's Limited-access User Group or class. The terms also specify that aggregate, non-identifiable data may be shared broadly, because the terms state they in no way restrict or limit the collection and use of aggregate information. In addition, the policies do not provide sufficient details on the confidentiality, security, or integrity of a student's personal information. Lastly, Educreations' terms state they require schools, districts, and/or teachers to obtain parental consent from students' parents before collecting any information.
Educreations 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 Educreations' 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
As part of creating an Educreations user profile on the site, students can add their name and photograph. The terms state that the only users who may view a student's profile are those who belong to that student's Limited-access User Group or class. An individual with a teacher's account and a student connected to their classroom via a unique pin number can see that student's first and last name, email, and last time active (e.g. X minutes ago, etc.). In addition, the terms state a student's lessons are stored privately on educreations.com and are only visible to the student and that student's teachers. Any content a student contributes to their Limited-access User Group will only be displayed to other members of that class.
The terms also state that if a User Submission is published using the "public" setting, that the person is "allowing everyone, including people off of Educreations, to access and use that content."
Privacy
Educreations's terms claim broad rights to reuse user data. As defined in the terms, the act of uploading or creating data within the site gives Educreations and its subsidiaries, affiliates, and/or successors a perpetual and transferable license to reuse and access user data. However, the rights claimed by Educreations to use and share data widely with affiliates appear to contradict other parts of their policy, where they state, "Personal Information and Children's Personal Information collected through the Site may be shared with companies and organizations ... that have agreed not to disclose it to others." Possibly, this indicates that PII is treated differently than other submissions uploaded to the site.
The terms also specify that aggregate, non-identifiable data may be shared broadly, because the terms state they in no way restrict or limit the collection and use of aggregate information. Educreations's terms state they may collect personal information from students including name, email address, photo, date of birth, school name, audio recordings, videos, photos, online activity, and persistent identifiers. Lastly, Educreations' terms state they may also collect information the student provides to Facebook, Google, or Dropbox if the student links their Educreations account to those third-party authentication providers.
Security
The policies do not provide details on the confidentiality, security, or integrity of a student's personal information. From a brief examination, SSL encryption is required on the login page. However, schools and districts are encouraged to request a more thorough description of the security practices and protections in place.
Compliance
Educreations' terms state they require schools, districts, and/or teachers to obtain parental consent from students' parents before collecting any information. If a student under 13 years of age attempts to create an account on their own, or enters their birth date, Educreations will not let that student create an account, and will provide notice to the student that they will either have to sign-up with a class code from their teacher or have a parent create an account for them. In addition, it is not clear from the terms if Educreations or third parties can use student data collected from the Service to target advertisements to users on other websites, or on other applications or services.
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 | 56 | 44 |
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 | 35 |
| Data Sharing: Protecting data from third parties | 75 | 70 |
| Data Security: Protecting against unauthorized access | 33 | 20 |
| 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 | 0 | 20 |
| Parental Consent: Protecting children’s personal information | 67 | 50 |
| 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) | 58 | 50 |
| Children's Online Privacy Protection Act (COPPA) | 54 | 46 |
| Family Educational Rights and Privacy Act (FERPA) | 72 | 44 |
| Student Online Personal Information Protection Act (SOPIPA) | 50 | 49 |
| General Data Protection Regulation (GDPR) | 61 | 39 |
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 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.
- Unclear whether intended for teens.
- Unclear whether 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.
- 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.
- 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.
- 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
- 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
- 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
- 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
- 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.
- 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
- 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.
- 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 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.
- 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
- 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.
- 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.
- Processes to review data are available for the school, parents, or students.
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.
- 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 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.
- 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
- Unclear whether a user's identity is verified with additional personal information.
8.2: User Account
- Account creation is not 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
- Unclear whether this product uses industry best practices 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
- 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
- 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
- Unclear whether this product displays traditional or contextual advertisements.
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.
- 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.
- 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.
- 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.
- 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.
- 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.