Overview
ReadTheory provides texts matched to Lexile Levels, and tracks student progress and comprehension through reading exercises. The terms of ReadTheory state they do not allow users to interact with other users in the same classroom, or school. ReadTheory's terms state they may collect a user's personal information and non-personal usage information automatically from data analytics. ReadTheory's terms state they take reasonable steps to release a student's personal information only to third parties who are capable of maintaining the confidentiality, security and integrity of the information. Lastly, ReadTheory's terms state they are compliant with COPPA and obtain parental consent for all users under 13 years of age.
ReadTheory can be accessed through its website. The Privacy Policy and Terms of Use accessed for this evaluation can be found on ReadTheory’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 ReadTheory state they do not allow users to interact with other users in the same classroom, or school. However, ReadTheory's terms state they may share a student's personal information with new teachers who use the Services in their classrooms when a student enrolls in that teachers' class. In addition, ReadTheory terms state they may share a teacher's personal information with other teachers within a school using the same Services. The terms state Student progress reports are accessible only to the students themselves by logging in their Student Account. However, progress reports may also be visible to any Teacher Accounts to whom each student's account is linked.
Privacy
The terms of ReadTheory state they may collect a user's personal information and non-personal usage information automatically from data analytics. However, ReadTheory's terms state they do not require users to provide personal information to use the Service and do not allow users to upload any photographs. ReadTheory’s terms state they will not sell student personal information or disclose a student's personal information to any third party for that third party's own marketing purposes.
However, ReadTheory's terms states they may display non-targeted advertisements to users of the Service, because it is the means by which the Service generates revenue necessary to sustain the site as a completely free resource. In addition, ReadTheory's terms state they may advertise third-party linked websites from which users may purchase or otherwise obtain certain sample goods, freebie offerings or free trial services. The terms specify that they will not use or disclose student information, whether personal information or otherwise, for behavioral targeting of advertisements to students. Advertisements on the Site are non-targeted, which means targeted advertising has been disabled for all ads shown on this Site.
Security
ReadTheory's terms state they take reasonable steps to release a student's personal information only to third parties who are capable of maintaining the confidentiality, security and integrity of the information. ReadTheory's terms state they encrypt the transmission of all teachers' and students' personal information using security measures designed to protect the security, privacy, confidentiality, and integrity of personal information against risks through the use of administrative, technological, and physical safeguards. However, ReadTheory's terms state they do not also disclose whether teacher and student data are encrypted at rest. In the event of a data breach, ReadTheory's terms state they will notify users within 72 hours and the notification may be delivered in the form of email or in general message posting in a prominent location on the Service.
Compliance
ReadTheory's terms state they are compliant with COPPA and obtain parental consent for all users under 13 years of age. ReadTheory requires all users signing up for new Student Accounts, as well as all Teacher Accounts that create Student Accounts on behalf of their students, to review their parental consent information form. ReadTheory's terms state that any users under 13 years of age who continue to use the Site following their parents' or guardians' review of their Parental Information Form are considered to constitute parental consent.
ReadTheory's terms state they do not receive funding from the United States Department of Education, and therefore are not subject to the Family Educational Rights and Privacy Act, or qualify as a "school official" for any purposes. However, although ReadTheory is not an educational institution, they provide services to educational institutions under FERPA and collect statistics on student progress reports that are used in classrooms and by teachers that could, in some situations, constitute "education records" under FERPA. Teachers should consult with administrative staff to get a clear understanding of whether or not their use of this service triggers additional obligations 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 | 68 | 50 |
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 | 40 |
| Data Sharing: Protecting data from third parties | 100 | 90 |
| Data Security: Protecting against unauthorized access | 83 | 60 |
| Data Rights: Controlling data use | 0 | 15 |
| Data Sold: Preventing sale of data | 50 | 25 |
| Data Safety: Promoting responsible use | 50 | 55 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 58 | 50 |
| Parental Consent: Protecting children’s personal information | 100 | 85 |
| School Purpose: Following student data privacy laws | 100 | 70 |
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) | 42 | 50 |
| Children's Online Privacy Protection Act (COPPA) | 65 | 57 |
| Family Educational Rights and Privacy Act (FERPA) | 72 | 46 |
| Student Online Personal Information Protection Act (SOPIPA) | 69 | 54 |
| General Data Protection Regulation (GDPR) | 61 | 48 |
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.
- 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.
- 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
- 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.
- Data are shared for analytics.
- Data are shared for research and/or product improvement.
- Data are not shared for third-party advertising and/or 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
- Data are not sold or rented to third parties.
3.5: Third-Party Data Acquisition
- 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
- Unclear whether 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
- Social or federated login is supported.
- 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
- Combined information is not 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
- 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
- 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 available for users to file a complaint.
5.4: Data Settings
- Unclear whether 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 do not 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.
- Unclear whether 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
- Unclear whether this product provides processes to access and review user data.
- 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
- The vendor does maintain the accuracy of data they collect.
6.3: Data Correction
- Unclear whether this product provides processes to modify inaccurate data.
- Unclear whether the school, parents, or students can modify data.
- 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
- Data are deleted when no longer necessary.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Unclear whether a user can delete all their data.
- Unclear whether the school, parents, or students can delete data.
- 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
- Unclear whether user information can be transferred to a third party.
- Unclear whether 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
- Unclear whether third-party transfers are 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.
- Parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
8.3: Third-Party Security
- Third-party contractual security protections are required.
8.4: Data Confidentiality
- Industry best practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
8.5: Data Transmission
- All data in transit are encrypted.
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
- Notice is provided 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 cannot interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
9.2: Data Visibility
- Personal information is not displayed publicly.
- Users can control how their data are displayed.
9.3: Monitor and Review
- User-created content is reviewed, screened, or monitored by the vendor.
- 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 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
- Traditional or contextual advertisements are displayed.
10.3: Behavioral Advertising
- Behavioral or targeted advertising is not displayed.
10.4: Ad Tracking
- Data are not collected 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
- Children do not receive any inappropriate advertisements.
10.6: Marketing Communications
- Unclear whether this vendor can send marketing messages.
- The vendor does provide promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
- Users can opt out of traditional, contextual, or behavioral advertising.
- Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Vendor does not respond 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.
- Vendor does restrict 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 not provided.
- Vendor is not designated as a school official.
11.3: Parental Consent
- Parental consent is required.
- Parental consent is not limited 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.
- 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.
- FERPA parental consent exceptions are not indicated.
- 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
- The vendor 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, such as the GDPR.
- Unclear whether the vendor has indicated it is a Data Controller or Data Processor.