Overview
ThingLink provides an easy way to save and share notes and observations about real-world spaces, situations and artifacts. The terms state certain features let uses make additional information available to the public, and users have the option to share their ThingLink activities with their friends, or through email, SMS text, or various social media sites. In addition, users can browse ThingLink without providing personal information, but they must register in order to access most of the features of the service. ThingLink's terms state they use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all the information they collect and that they share with third-party service providers. The terms state that ThingLink recognizes that children under 13 may use the service under the supervision of a parent or an educational institution acting as an agent of their parent.
ThingLink 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 ThingLink’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Acceptable Use Policy, Cookie Policy, and Privacy Architecture. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The terms state users may choose to provide additional information which may be shared with others on the service or through their public profile, such as their name, email address, nickname or online alias, other ThingLink accounts they choose to follow, and Immersive Images. In addition, if a user registers a ThingLink account with an email address on a domain owned by their employer, educational institution, or organization, ThingLink may help collaborators and administrators find that user and their team by making some of their basic information—like their name, team name, profile picture, and email address—visible to other users on the same domain.
The terms state certain features let uses make additional information available to the public, and users have the option to share their ThingLink activities with their friends, or through email, SMS text, or various social media sites. Lastly, all ThingLink profiles are typically made available to the public, however a user may elect to make their content private. If a user makes all of the content on their profile private, then their profile will not appear in a directory search of the service, but a user may still be able to access their profile if they know the URL for their profile.
Privacy
The terms state the services allow for the collection, use, and disclosure of a user's personally identifiable information and aggregate data with third parties. In addition, users can browse ThingLink without providing personal information, but they must register in order to access most of the features of the service. ThingLink's terms state they do not collect data for collection’s sake, and access is limited and appropriate. ThingLink requires third-party vendors to agree to privacy commitments in order to share information with them. Some areas of the service allow users to post or provide content such as profile information, videos, images, music, comments, questions, and other content.
The terms also state ThingLink will not sell information or transfer information about users to third parties. The terms state that in order to personalize a user's experience using the service, ThingLink may use personal information to target their marketing messages to groups of users. The terms also state they allow third-party tracking of users to analyze and track usage, determine the popularity of certain content, and deliver content that may be more targeted to a user's interests. However, for users under 13 years of age ThingLink does not permit behavioral advertising on the service.
Security
ThingLinks's terms state they use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information they collect and that they share with third-party service providers. In addition, the terms state personal data and backups are stored in protected databases located behind a firewall and with both physical and software-based access controls. All personal information is encrypted while in transit and at rest. In the event that any personal information is compromised as a result of a breach of security, ThingLink's terms state they will take reasonable steps to investigate the situation and where appropriate, notify individuals whose information may have been compromised.
Compliance
The terms state that ThingLink recognizes that children under 13 may use the service under the supervision of a parent or an educational institution acting as an agent of their parent. When that happens, ThinkLink's terms state they take additional precautions to protect the privacy of children under 13. The terms state that if ThingLink determines the child is under 13 years of age, they will ask for a parent's name and email address so that we can notify the parent that the kid has created an account and seek the parent's consent to allow the kid's participation. If the parent provides consent, ThingLink may collect additional information from the kid, including a profile avatar, which could include a photograph, or other content uploaded by the child to the service. However, a child under 13 will not be permitted to engage in the core functionality of the service unless ThingLink receives verifiable parental consent.
In addition, children may only access the services at the direction of their teacher or school district by using an invitation code provided to them by their teacher or educational institution. ThingLink's terms state that it is authorized by schools and districts under the FERPA “school official” exception to receive and use educational data to provide educational services. Parents and teachers may access, modify, delete, and consent to the collection and use of the child's personal information. However, ThingLink's privacy policy does not govern the collection, use, or disclosure of personal information through the service by the educational institution or organization which has given a child or student access to the service. Parents are advised by ThingLink to contact their educational organization to better understand their privacy practices as well.
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 | 60 |
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 | 83 | 65 |
| Data Rights: Controlling rights to data | 88 | 85 |
| Data Sold: Preventing sale of data | 75 | 55 |
| Data Safety: Promoting responsible use | 63 | 65 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 33 | 35 |
| Parental Consent: Protecting children’s personal information | 100 | 65 |
| 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) | 67 | 62 |
| Children's Online Privacy Protection Act (COPPA) | 72 | 56 |
| Family Educational Rights and Privacy Act (FERPA) | 83 | 58 |
| Student Online Personal Information Protection Act (SOPIPA) | 73 | 63 |
| General Data Protection Regulation (GDPR) | 82 | 67 |
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 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: 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.
- Unclear whether intended for adults over 18.
- Unclear whether 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
- Unclear whether 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 not 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.
- 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.
- 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
- 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
- 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 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
- 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.
- Notice is not 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 not maintain the accuracy of data they collect.
6.3: Data Correction
- Processes to modify inaccurate data are available.
- Processes for the school, parents, or students to modify data are available.
- 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.
- 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.
- Notice is provided to users if the vendor 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
- 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
- Account creation is required.
- Parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
8.3: Third-Party Security
- Unclear whether 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
- Unclear whether this product encrypts all data in transit.
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.
- Social interactions between users are moderated.
- 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
- Unclear whether this product displays traditional or contextual advertisements.
10.3: Behavioral Advertising
- Behavioral or targeted advertising is not displayed.
10.4: Ad Tracking
- Data are 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
- The vendor can send marketing messages.
- Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
- Unclear whether this product provides users the ability to 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.
- 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.
- 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.
- Notification of a contract or additional rights is provided.
- 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.
- 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.
- 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.
- 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 vendor will disclose personal information to law enforcement.
11.5: Certification
- Unclear whether 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.