Overview
Scholly helps users find and apply to scholarships. The Privacy Policy states that Scholly uses automated social measures to screen content to prevent abuse, although, the Terms of Service state that Scholly has no obligation to monitor the use of its services. The Privacy Policy clearly outlines that the categories of personal information collected from users include names, addresses, online identifiers, telephone numbers, bank account numbers, credit card and debit card numbers, and even age, gender, race, citizenship status, and national origin. However, the terms do not clearly state whether users are subject to advertising on Scholly’s services. In addition, the terms fail to state whether users’ information is encrypted either when stored or in transit. Lastly, the terms state that individuals under the age of 13 are prohibited from using Scholly’s Services.
Scholly 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 Scholly’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 Privacy Policy warns users that information posted in messages, chat rooms, forums, and other public posting areas is available to anyone, and cautions posting certain types of information. The terms do not clearly indicate whether social interactions are moderated, and fail to disclose whether or not inappropriate content, harassment, or cyberbullying can be reported. The terms do not state whether users have control over how their personal information is displayed to others.
Privacy
The Privacy Policy discloses that Scholly collects personal information, geolocation data, behavioral data, sensitive data, usage data, and educational records. The terms are not transparent on whether the personal information collected is limited to only data that are specifically required for the product. The terms do not indicate whether Scholly obtains opt-in consent from a user at the time any information is collected, or whether Scholly provides notice or obtains consent from a user if the purpose that the personal information was collected has changed. The Privacy Policy clearly states that service providers “use cookies and web beacons to collect information, and to serve advertisements to you across the Internet based on that information.” The Privacy Policy discloses that personal information is shared with third parties, and outlines what categories of information is shared.
The Privacy Policy outlines the purposes for sharing personal information, including for the purposes of analytics, researching, marketing, processing payments, and to help facilitate advertisements. The terms are unclear on whether advertisements are only directed to individuals on other sites, or whether users on Scholly’s services are also subject to advertisements. The Privacy Policy discloses that Facebook Analytics connects users’ personal information with users’ Facebook accounts to use it for Facebook Analytics’ own advertising purposes. The Privacy Policy provides links for opting out of certain third party advertising. The Privacy Policy states that Scholly does not "sell your personal information at this time." The Privacy Policy indicates that any third-party successor of a data transfer is contractually required to provide the same privacy compliance required of Scholly, however, the Privacy Policy does not clearly state whether users will be notified or given the opportunity to delete their data in connection with Scholly’s transfer of user data in the event of a merger, acquisition, or bankruptcy. The Privacy Policy does not state whether users can opt out of any of Scholly’s promotional communications.
Security
The Privacy Policy indicates that Scholly uses reasonable security standards to protect the confidentiality of users’ personal information. However, the terms fail to state whether Scholly utilizes any encryption of users’ personal information, or whether Scholly has physical access controls for limiting employee access to user information. The Privacy Policy states that Scholly “may attempt to notify” users via email or on Scholly’s websites in the event of a data security systems breach. The Privacy Policy indicates that Scholly may use additional information to verify a users’ identity.
Compliance
The Privacy Policy provides a clear section for Children’s Privacy, and clearly states that Scholly is not intended for persons under the age of 13, and that “if you are under 13, you are not allowed to use the Services or submit any personal information to us." The Privacy Policy provides that Scholly does not knowingly collection information from visitors under the age of 13, and if Scholly learns that a person under the age of 13 has provided it with personal information, that Scholly will delete such personal information. The Privacy Policy clearly indicates that users can create or upload content to the product. However, the Privacy Policy dictates that “any information that is not personal information, such as any suggestions or ideas you provide to us, becomes our property for any use we may determine, without any notice or compensation to the author.”
The Privacy Policy provides a method for users and authorized individuals to access, review, modify, delete, and download the user’s personal information, and the categories of information shared with third parties. However, the Privacy Policy discloses that “Even after you remove information from your profile or delete your account, copies of that information may remain viewable on the Sites and elsewhere,” and that “we may retain certain information to prevent identity theft and other misconduct even if deletion has been requested.”
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 | 52 | 40 |
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 | 40 |
| Data Sharing: Protecting data from third parties | 100 | 70 |
| Data Security: Protecting against unauthorized access | 33 | 25 |
| Data Rights: Controlling rights to data | 63 | 45 |
| Data Sold: Preventing sale of data | 75 | 40 |
| Data Safety: Promoting responsible use | 17 | 20 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 36 | 35 |
| Parental Consent: Protecting children’s personal information | 50 | 50 |
| School Purpose: Following student data privacy laws | 0 | 19 |
| Individual Control: Controlling data use | NA | 30 |
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 | 62 |
| Children's Online Privacy Protection Act (COPPA) | 48 | 44 |
| Family Educational Rights and Privacy Act (FERPA) | 43 | 34 |
| Student Online Personal Information Protection Act (SOPIPA) | 50 | 48 |
| General Data Protection Regulation (GDPR) | 67 | 42 |
| The California Consumer Privacy Act (CCPA) | 53 | 45 |
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
- 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
- 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 not available in multiple languages.
1.8: Intended Use
- Not intended for children under 13.
- Intended for teens.
- 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.
- Geolocation data are collected.
- Unclear whether this product collects biometric or health data.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are collected.
- 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 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
- 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
- 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
- Unclear whether the categories of third parties that receive data are indicated.
3.12: Third-Party Policies
- 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.
- 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
- 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
- Unclear whether 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
- 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 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.
- 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 do not retain ownership of their data.
- A copyright license is not claimed to data or content collected from a user.
- Any copyright license to a user's data is not 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.
- Unclear whether 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
- Unclear whether this product deletes data when no longer necessary.
- A user's data are not deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Unclear whether authorzied users can delete data.
- Unclear whether the time period for the company to delete data is indicated.
6.6: Data Portability
- Processes to download user data are available.
- 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.
- 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
- 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
- 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.
- 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 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
- Unclear whether this product performs data-privacy and/or security-compliance audits.
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
- 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
- User-created content is reviewed, screened, or monitored by the company.
- User-created content is not 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
- Unclear whether this product displays personalised advertising.
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.
- Unclear whether 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
- 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 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.
- 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 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 indicated.
- A user is required to waive the right to a jury trial, or settle any disputes by arbitration.
- 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
- Unclear whether a user's data are subject to International data transfer or jurisdiction laws.
- Unclear whether the company has indicated it is a Data Controller or Data Processor.