Overview
Sushi Monster is a game to practice, reinforce, and extend math fact fluency. The terms say that the service may allow users to create their own profile, which may be displayed publicly or semi-publicly. The terms also say that the service may collect personal information and demographic Information from users. The terms say the service does not sell users' data to third parties. However, the terms also say a user's data is used to display targeted advertisements, send third-party marketing communications, and track users on other apps and services across the internet. The terms say the service has implemented and maintains reasonable organizational, technical, administrative and physical security controls that are designed to protect the security, confidentiality and integrity of personal information collected through the service. Lastly, teachers are strongly encouraged to review the parental consent procedures within their school or district before sharing student information.
Sushi Monster is available for download at the iOS App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Sushi Monster’s iOS App Store. Additionally, other policies used for this evaluation include: Privacy Policy for HMH PreK–12 Products and Privacy Policy (GDPR). This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
Sushi Monster's terms say that the service may allow users to create their own profile, which may be displayed publicly or semi-publicly. The terms also say that a user's profile page may be set up to display information such as the user's display name, images, location, groups that the user has joined, and optional information added by the user including -- for example -- the user's tagline, photographs and educational materials.
The terms say that the user can post to chat rooms, message boards, other user's profiles, bulletin boards, or similar forums. The terms describe that these interactions may be public or semi-public, and could potentially be accessible via search. The terms say that the service may also publish a user's name, voice, likeness and other personal information that is part of their user content, and they may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.
Lastly, the terms say that a user may send messages or invitations from the service, and that people sending messages from the service should be aware that their e-mail address, mobile number, name and/or user name may be included along with any message.
Privacy
The terms of Sushi Monster say that the service may collect personal information and demographic information from users. In addition, the service may automatically collect non-personal usage information when a user visits or interacts with the service. The terms say that on mobile devices, the service might track a device's location. The service may also combine a user’s non-personally identifiable demographic information or usage nformation with the personal information they collect directly on the service, but will treat the combined data as personal information.
The terms say that the service may share a user’s non-personal information, such as aggregated user statistics or data related to a user and their activities, with third parties. However, the terms also say that personal information will not be shared with third parties for direct marketing purposes unless the user provides consent. Users should be aware that the terms say that a person's name, voice, likeness and other personal information that is part of their user content could be used for advertising, marketing, publicity and promotional activities.
Additionally, the service may supplement the information they collect directly from users on the service with external information from third parties. The terms say that third parties, including advertisers and advertising service providers, may collect information about users. These third parties may use their own tracking technologies on a user’s device, or collect a user’s personal Information. While the terms say that the service will not use personally identifiable information to target ads, the terms also say that a user may be served with targeted and contextual advertising, including location-based advertising.
Security
The terms say the service has implemented and maintains reasonable organizational, technical, administrative and physical security controls that are designed to protect the security, confidentiality and integrity of personal information collected through the service. The terms also say that all data sent to and from the service is protected with encryption. The terms also say that data that are covered under COPPA or FERPA are encrypted at rest whenever possible. The terms say that if the service is not able to encrypt data, the service will use other means to protect that data.
In the terms, the service describes that privacy and information security training is provided to employees. They also describe how access to personal information is limited to specific employees. The servcice uses third-party cloud service providers in the delivery and operation of their learning platform, and data is stored on the servers of their cloud service providers. The terms describe contractual requirements are in place with these cloud service providers and are designed to protect user data.
Compliance
The terms say that the tools and services covered under the policies are designed for teachers and schools working with K-12 students. The terms highlight that, under COPPA, schools can provide consent for parents for online tools used for an educational purpose. The terms also say that the service meets the criteria for a "school official" under FERPA. The terms say that the service does not knowingly collect personal information from children under the age of 13 without verified parental consent - and for applications used within schools, the terms say that this consent can be provided by the school. In addition, if personal information or education records are collected, the service allows users to access, update, or correct their data.
The terms say the service meet FERPA's requirements for qualifying as a school official because they give the school direct control over the use and maintenance of the education records. The terms also say that the service does not re-disclose or use this personal information except for the purposes of providing the learning platform to the school. The terms say that the service may post additional information or a separate children's Privacy Policy on any website or app store page for a service directed to children under 13 years of age. These additional policies explain what types of personal information may be collected, and what options parents have to approve or limit collection from children. However, this means that users will need to navigate five different sets of policies to determine the privacy and data security practices of the service. Educators are strongly encouraged to review the parental consent procedures within their school or district before sharing student information.
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 | 76 | 62 |
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 | 55 |
| Data Sharing: Protecting data from third parties | 100 | 85 |
| Data Security: Protecting against unauthorized access | 100 | 80 |
| Data Rights: Controlling rights to data | 88 | 75 |
| Data Sold: Preventing sale of data | 75 | 55 |
| Data Safety: Promoting responsible use | 38 | 45 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 50 | 60 |
| Parental Consent: Protecting children’s personal information | 67 | 65 |
| School Purpose: Following student data privacy laws | 100 | 60 |
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) | 75 | 71 |
| Children's Online Privacy Protection Act (COPPA) | 67 | 61 |
| Family Educational Rights and Privacy Act (FERPA) | 89 | 58 |
| Student Online Personal Information Protection Act (SOPIPA) | 77 | 71 |
| General Data Protection Regulation (GDPR) | 93 | 74 |
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 not 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: Policy Contact
- Users can 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.
- Geolocation data are collected.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- 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.
- 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.
- Data are 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
- 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 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
- The categories of third parties that receive personal information are indicated.
3.12: Third-Party Policies
- Links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
- 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.
- Personal information from social or federated login providers is collected.
- 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.
- 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 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
- 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 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 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
- Unclear whether 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.
- 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
- Processes to access and review user data are available.
- 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
- Processes to modify inaccurate data are available.
- Unclear whether the school, parents, or students can modify data.
- The time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- 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.
- A user's data are deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Processes for the school, parents, or students to delete data are available.
- Unclear whether the time period for the vendor 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.
- 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
- 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.
- 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.
- 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 at rest are encrypted.
- 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
- Data-privacy and security-compliance audits are performed.
9: Responsible Use
9.1: Social Interactions
- Users can interact with trusted users and/or students.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
9.2: Data Visibility
- Personal information is 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
- 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 displayed.
10.4: Ad Tracking
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
- Children do not receive any inappropriate advertisements.
10.6: Marketing Communications
- The 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.
- Users can 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.
- The vendor does provide 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.
- Unclear whether this product restricts account creation for users under 13 years of age.
- Unclear whether this product restricts 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.
- Unclear whether this product provides notification of a contract or additional rights.
- Vendor is designated as a school official.
11.3: Parental Consent
- Parental consent is required.
- 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 the vendor can use collected information to support the “internal operations” of the product.
- Unclear whether this product indicates COPPA parental consent exceptions.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- 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.
- The vendor has indicated it is a Data Controller or Data Processor.