Overview
Flocabulary provides a library of songs, videos and activities for K-12 online learning and research-based activities to teach content knowledge and build literacy skills. The terms of Flocabulary state they do not provide any social interactions between students or make a student's information visible to the public. The terms specify that schools and districts can use Flocabulary without sharing any personal information from students, or they can choose to set up student accounts and use Flocabulary to track their students' progress. Flocabulary's terms state they utilize industry-standard application hosting providers who agree to perform frequent diagnostics, operating system updates, and network security monitoring. Flocabulary's terms state they do not knowingly collect personal information from children under the age of 16, but do collect personal information from students and teachers in K-12.
Flocabulary can be accessed through its website. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Flocabulary’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The terms of Flocabulary state they do not provide any social interactions between students or make a student's information visible to the public. The terms specify when students have accounts, teachers will be able to assign multiple choice quizzes and other assignments to students in their classes. Students' quiz results and work product are stored so that both the student who took the quiz or completed the assignment and the teacher can review the results.
The terms state for certain types of assignments, teachers can enable multiple students to collaborate to share their work with the class. Lastly, the terms state the student’s username, first, and last name will not be shared with any Flocabulary users other than their teacher and the account manager at their school or district.
Privacy
The terms of Flocabulary state they collect personal information from students and teachers and automatically collect and analyze information from their use of the services and activity on the website. The website is provided for potential users, but only school staff and parents or guardians may become users and create accounts for students. The terms state a website visitor may not register for Flocabulary as a user for a trial, or paid plan, unless they represent a class, school, district, or are a parent or guardian of a learner.
Flocabulary's terms state schools and districts can use the service without sharing any personal information from students, or they can choose to set-up student accounts and use Flocabulary to track their students' progress. In addition, Flocabulary's terms sate they may use aggregated, anonymized and de-identified data to make improvements to Flocabulary, and they may maintain anonymized, aggregated data, including usage data, for analytics purposes. Flocabulary's terms state they do not share any personal information with third parties for advertising, marketing or other purposes, and they do not sell or rent any students' information to any third party for any purpose. Lastly, the terms state there is no third-party advertising on Flocabulary and they do not track users across third party websites, or use targeted advertising.
Security
The terms of Flocabulary state they utilize industry-standard application hosting providers who agree to perform frequent diagnostics, operating system updates, and network security monitoring. Flocabulary's terms state they have industry-standard security policies and procedures in place, and take reasonable measures to protect the confidentiality, security and integrity of personal information collected on their website. This includes the use of encryption to protect sensitive information transmitted online, firewalls and other security technologies to prevent access to the data from unauthorized parties. The terms specify all connections between users and Flocabulary are secured via encryption communication technology (SSL). In addition, the terms state all Flocabulary passwords are salted and hashed using the practices recommended by NIST (National Institute of Standards and Technology).
Flocabulary's terms state their engineering team is committed to creating and maintaining systems to protect a user's personal information. Their terms state only employees who need to access user information in order to perform a specific job (for example, billing or customer service) are granted access to that information. Flocabulary's terms state that partners, including their outside shipping company and their credit card processing company may only use user information to provide specific services. The terms state these companies do not retain, share, store or use personally identifiable information for any secondary purposes beyond filling a user's order. Lastly, the terms state if Flocabulary believes that the security of a user's personal information may have been compromised, they will seek to notify a user as soon as possible.
Compliance
The terms of Flocabulary state they do not knowingly collect personal information from children under the age of 16, but do collect personal information from students and teachers in K-12. The terms state when a school or district purchases Flocabulary, the first step is for teachers or administrators to create classes. Students can only sign up for Flocabulary after the school or district imports student roster information into Flocabulary, or their teacher enters class information and instruct students to create an account with a provided code. Additionally, the terms state students cannot sign-up and create a Flocabulary account unaffiliated with a class or a school-wide district.
When students create a student account on Flocabulary, the terms state they need to enter a code which will associate them with their school and teacher. The terms specify if a student is a child under the age of 16, they must get permission from a parent or legal guardian to use the website. If a child under 16 wishes to sign up for a free trial or subscribe to Flocabulary, the terms state they must obtain parent or legal guardian consent beforehand. The terms specify if Flocabulary learns they have inadvertently collected personal information from a child under 16 without parental consent, they will take the necessary steps to delete it.
Lastly, the terms state a parent, guardian, or student can access, edit, and delete their information or the results of their quizzes at any time if the data has been provided to Flocabulary by their school or district. The terms also state that after a school or district has requested their account termination and subsequent removal of student data, Flocabulary may retain securely stored backups in accordance with their agreements with the school or district, and their data retention policy, after which point all data will be deleted.
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 | 93 | 73 |
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 | 83 | 55 |
| Data Sharing: Protecting data from third parties | 100 | 85 |
| Data Security: Protecting against unauthorized access | 100 | 85 |
| Data Rights: Controlling rights to data | 88 | 85 |
| Data Sold: Preventing sale of data | 75 | 85 |
| Data Safety: Promoting responsible use | 100 | 55 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 93 | 75 |
| Parental Consent: Protecting children’s personal information | 100 | 85 |
| School Purpose: Following student data privacy laws | 100 | 75 |
| Individual Control: Controlling data use | NA | 55 |
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) | 93 | 81 |
| Children's Online Privacy Protection Act (COPPA) | 93 | 79 |
| Family Educational Rights and Privacy Act (FERPA) | 94 | 74 |
| Student Online Personal Information Protection Act (SOPIPA) | 92 | 80 |
| General Data Protection Regulation (GDPR) | 97 | 80 |
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 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.
- Intended for teens.
- Intended for adults over 18.
- 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.
- Unclear whether 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
- Links to third-party external websites are not 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 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 not available.
3.13: Third-Party Data Combination
- Company may combine data with additional data from third-party sources.
- 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.
- 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.
- 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.
- 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
- 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 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.
- Unclear whether 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
- Unclear whether 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.
- Unclear whether 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
- 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 authorized users to delete data are available.
- 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.
- 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
- 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
- Data-privacy and/or security-compliance audits are performed.
9: Responsible Use
9.1: Social Interactions
- Users can interact with trusted users.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
9.2: Data Visibility
- Personal information can be not 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.
- 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: Vendor Communications
- A user can receive service- or administrative-related communications from the company.
10.2: Traditional Advertising
- Traditional or contextual advertisements are not 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.
- Users'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
- 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.
- 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
- Company does not have actual knowledge that personal information from users under 13 years of age is collected.
- The company does provide a section, heading, or separate policy for children in their policies.
- Account creation is restricted or prohibited 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.
- Parents can 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 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 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.