Overview
EvaluationKit is an online course evaluation and survey service. EvaluationKit's terms do not disclose whether they provide any social interaction services between users or otherwise make a user's personal information visible to the public. The terms require schools to be responsible for all decisions related to the collection of personally identifiable information of students who respond to course evaluations, surveys, or other types of data collection. The terms state EvaluationKit uses physical, electronic, and procedural safeguards to protect users' personal information. Lastly, the terms state EvaluationKit is not available to individuals under the age of 18 and the service does not target children under 13, and educational institutions should not knowingly collect personally identifiable information from children under 13 years of age.
EvaluationKit 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 EvaluationKit’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
EvaluationKit's terms do not disclose whether they provide any social interaction services between users or otherwise make a user's personal information visible to the public.
Privacy
The terms specify that EvaluationKit is committed to protecting the privacy and confidential information of its users. The terms require schools to be responsible for all decisions related to the collection of personally identifiable information of students who respond to course evaluations, surveys, or other types of data collection. EvaluationKit agrees not to disclose any of a user’s confidential information collected from the school to any third parties other than to their employees and consultants. Lastly, the terms state that EvaluationKit does not sell personal information to third parties, but the terms are not clear whether use personal information for third-party marketing or behavioral advertising.
Security
The terms state EvaluationKit uses physical, electronic, and procedural safeguards to protect users' personal information. The terms also state a user account is required to access the service, and then for users to access surveys and content. In addition, in order to access the system, an educational institution must create student accounts in EvaluationKit, which contains student personal information that includes: first and last name, username, e-mail address, and which courses a user is enrolled in. The terms state they use encryption to protect user information, but do not disclose whether users are notified in the event of a data breach.
Compliance
The terms state EvaluationKit is not available to individuals under the age of 18 and the service does not target children under 13, and educational institutions should not knowingly collect personally identifiable information from children under 13 years of age. EvaluationKIT's terms state users have the right to access, modify, and delete their personal information. EvaluationKIT will not make available or distribute any student information in violation of FERPA, and student information is considered to be confidential information in the terms. The terms state EvaluationKit will only share student information with the educational institution which is linked to the student's use of the services.
In addition, the privacy policy does not govern the collection, use, or disclosure of personal information through the service by the educational institution which has given students access to the EvaluationKIT service, or which is providing a course evaluation or survey a student is taking via the services. EvaluationKit recommends students contact their educational institution to better understand its specific privacy practices.
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 | 57 | 49 |
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 | 50 | 30 |
| Data Sharing: Protecting data from third parties | 100 | 70 |
| Data Security: Protecting against unauthorized access | 33 | 50 |
| Data Rights: Controlling rights to data | 75 | 50 |
| Data Sold: Preventing sale of data | 25 | 40 |
| Data Safety: Promoting responsible use | 0 | 0 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 57 | 60 |
| Parental Consent: Protecting children’s personal information | 50 | 30 |
| School Purpose: Following student data privacy laws | 100 | 75 |
| Individual Control: Controlling data use | NA | 40 |
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) | 81 | 64 |
| Children's Online Privacy Protection Act (COPPA) | 52 | 48 |
| Family Educational Rights and Privacy Act (FERPA) | 71 | 47 |
| Student Online Personal Information Protection Act (SOPIPA) | 65 | 55 |
| General Data Protection Regulation (GDPR) | 63 | 57 |
| The California Consumer Privacy Act (CCPA) | 60 | 54 |
Privacy Policy Details
1: Transparency
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Privacy policies 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 not effective immediately and continued use of the product requires additional 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
- Not intended for children under 13.
- Not intended for teens.
- Intended for adults over 18.
- Unclear whether intended for parents or guardians.
- Intended for students.
- Unclear whether 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 interactions, behaviors, or usage analytics data.
- 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 not 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
- 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.
- 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 sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Unclear whether 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
- 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.
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
- Unclear whether the categories of third parties that receive data 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 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
- Unclear whether this product supports third-party login.
- Unclear whether 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 shared in an anonymous or de-identified format.
- Unclear whether 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
- 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
- Unclear whether 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 the use of 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.
- 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.
- Unclear whether 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
- Unclear whether the product provides a data-retention policy.
- Unclear whether exceptions to the data retention policy exist.
6.5: Data Deletion
- Data are deleted when no longer necessary.
- Unclear whether 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
- 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 in the event of a merge, acquisition, or bankruptcy.
- 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 required.
- Managed accounts are available.
- Unclear whether multi-factor account protection is available.
8.3: Third-Party Security
- Unclear whether 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
- Unclear whether 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
- Unclear whether this product provides notice in the event of a data breach.
8.8: Data Oversight
- Data-privacy and/or security-compliance audits are performed.
9: Responsible Use
9.1: Social Interactions
- Unclear whether this product supports interactions between trusted users.
- Unclear whether 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
- Unclear whether personal information can be displayed publicly.
- Unclear whether this product allows users to 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
- Unclear whether the company provides links to resources that support safe and appropriate social interactions.
10: Advertising
10.1: Company 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 displayed.
10.4: Ad Tracking
- Data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Data profiles are 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
- Users can opt out of contextual, or personalised 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 company provides a method for users to opt-out from third-party tracking.
11: Compliance
11.1: Children Under 13
- Company does have 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.
- Company is designated as a school official.
11.3: Parental Consent
- Unclear whether 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.
- 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.
- 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 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 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.