Overview
With more than 1,500 exercises, iTooch Prep for the TOEFL is a new and fun way of practicing and preparing the TOEFL exam. It covers the speaking, listening, reading and writing sections. The terms of iTooch Prep for the TOEFL Exam do not disclose whether social interactions are available between users or whether users can make personal information publicly visible. The terms of iTooch Prep for the TOEFL Exam state they may collect personal information through use of the service and non-personal information automatically. The terms of iTooch Prep for the TOEFL Exam state they take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Lastly, the terms of iTooch Prep for the TOEFL Exam state they respect COPPA and do not collect information such as name, address, telephone number, photographs, video or audio from children under 13 years old.
iTooch Prep for the TOEFL Exam can be accessed through its website, and is available for download at the iOS App Store and the Google Play Store. The Privacy Policy used for this evaluation can be found on iTooch Prep for the TOEFL Exam’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 of iTooch Prep for the TOEFL Exam do not disclose whether social interactions are available between users or whether users can make personal information publicly visible.
Privacy
The terms of iTooch Prep for the TOEFL Exam state they may collect personal information through use of the service and non-personal information automatically. In addition, the terms state children under 13 have no access to social network features and are not allowed to share their scores or accomplishments with others. If the service shares information with third parties, the terms specify they require third parties to process user information under the same terms as their privacy practices. Lastly, the terms state the service also requires opt-in consent for the sharing of any sensitive personal information, and the service does not display any behavioral ads or contextual ads to users. However, there are additional details provided in the app-store that the application is 100% free and may be ad supported. If users prefer an ad-free experience, they can remove ads at any time through an optional in-app purchase in the app’s parameters.
Security
The terms of iTooch Prep for the TOEFL Exam state they take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. In addition, the terms specify that third parties that handle personal information are required to use appropriate confidentiality and security measures.
The terms specify that the service uses storage, processing practices, and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems that store personal data. In addition, the terms specify that the service restricts access to personal information to only employees and contractors who need to know that information in order to process user information. However, the homepage does not use encryption, but it also does not collect any personal information and the service does not disclose whether users are notified in the event of a data breach.
Compliance
The terms of iTooch Prep for the TOEFL Exam state they respect COPPA and do not collect information such as name, address, telephone number, photographs, video or audio from children under 13 years old. However, the terms do not disclose whether parental consent is required or the method to obtain parental consent if personal information from children under 13 is collected and used by the service. In addition, the terms state the service can collect only the first name but this information is collected in the app, and the service has no access to it. Lastly, the terms specify that they allow users to access, modify, and delete information provided to the service. However, the terms do not disclose any information about use of the service by students that would create education records under FERPA.
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 | 35 | 29 |
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 | 35 |
| Data Sharing: Protecting data from third parties | 100 | 40 |
| Data Security: Protecting against unauthorized access | 0 | 35 |
| Data Rights: Controlling rights to data | 50 | 20 |
| Data Sold: Preventing sale of data | 0 | 10 |
| Data Safety: Promoting responsible use | 0 | 0 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 14 | 10 |
| Parental Consent: Protecting children’s personal information | 50 | 40 |
| School Purpose: Following student data privacy laws | 0 | 0 |
| 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) | 69 | 42 |
| Children's Online Privacy Protection Act (COPPA) | 31 | 28 |
| Family Educational Rights and Privacy Act (FERPA) | 36 | 22 |
| Student Online Personal Information Protection Act (SOPIPA) | 30 | 27 |
| General Data Protection Regulation (GDPR) | 50 | 44 |
| The California Consumer Privacy Act (CCPA) | 33 | 36 |
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
- Unclear whether users are 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
- Unclear whether 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 not indicate any privacy principles, layered notices, or a table of contents.
1.7: Policy Language
- Privacy policies are 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.
- Unclear whether 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
- Unclear whether 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.
- 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.
- Unclear whether data are shared for analytics.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether personal information are shared for third-party 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
- Unclear whether 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
- 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
- Unclear whether third-party services are used to support the product.
- Unclear what the roles of third-party service providers are.
3.11: Third-Party Affiliates
- 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
- 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.
- Personal Information is not shared with third-party login providers.
3.15: De-identified or Anonymized Data
- Unclear whether 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
- 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
- Unclear whether 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
- Unclear whether 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
- Unclear whether users retain ownership of their data.
- Unclear whether 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.
- Unclear whether methods are available to restrict who has access to data.
- Unclear whether the school, parents, or students can review student data.
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.
- Unclear whether the school, parents, or students can modify inaccurate student information.
- 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.
- Exceptions to the data retention policy exist.
6.5: Data Deletion
- Unclear whether this product deletes data when no longer necessary.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Unclear whether authorzied users can delete data.
- 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
- Unclear whether third-party transfers are 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
- Unclear whether this product requires account creation.
- Unclear whether 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
- Unclear whether this product encrypts all data in transit.
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
- Unclear whether this product displays traditional or contextual advertisements.
10.3: Behavioral Advertising
- Personalised advertising is not displayed.
10.4: Ad Tracking
- Unclear whether data are collected by third-parties for their own purposes.
- Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
10.5: Filtered Advertising
- Unclear whether ads displayed to children are filtered for inappropriate content.
10.6: Marketing Communications
- Unclear whether this 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
- 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 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
- Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Processes to enter education records into the product are not described.
- Unclear whether 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
- 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.
- 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 the policies is not 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 company will disclose personal information to law enforcement.
11.5: Certification
- Unclear whether 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.