Overview

Waggle describes its service as an online learning platform that combines trusted Coach content to create a safe and engaging environment for students to accelerate learning and build resilience and confidence in ELA and Math. Waggle's policy notes that it does not make a user's information visible to the public, but does provide private messaging services between users and information provided in these forums will be received by the specified user’s account. Waggle's policy indicates that does not share non-personal information automatically collected with third parties, or a user’s personally identifiable information with any other third party besides its third party service providers.

Waggle can be accessed through its website. The Privacy Policy and Terms of Use used for this evaluation can be found on Waggle’s website. Additionally, other policies used for this evaluation include: GDPR. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Waggle does not make a user's information visible to the public, but does provide private messaging services between users, and information provided in these forums will be received by the specified user’s account. However, Waggle's terms state they have no obligation to monitor the private messaging system.

Privacy

Waggle's terms state they do not share personal and non-personal automatically collected usage information with third parties, or a user’s personally identifiable information with any other third party besides its third party service providers. In addition, the terms state Waggle does not sell or use personally identifiable information collected from students at K-12 schools to engage in behavioral targeting of advertisements. Lastly, Waggle shares anonymized information about individual students with third party service providers so they can analyze data about individual students’ use of Waggle and provide personalized content, support, reports and other adaptive learning products to improve the efficacy of the service.

Security

Waggle's policy indicates that it takes security seriously and to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, In addition, Waggle's policy explains that it has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure personal information, including appropriate data breach response. Lastly, Waggle notes that it attempts to comply with all the requirements of COPPA and does not collect personal information directly from children, but directly from school administrators or teachers when they create an account for a child with a classroom code.

Compliance

The terms of Waggle state they attempt to comply with all the requirements of COPPA and does not collect personal information directly from children, but only from school administrators or teachers when they create an account for a child with a classroom code. Waggle's terms state they are under the direct control of the educational institution it works with in respect to the use and maintenance of educational records and student education records will be kept confidential and will not be disclosed to third parties. A parent or guardian can contact their child’s school to review any personal information regarding their children that the school administrator or teacher provided to Waggle. However, Waggle's terms do not disclose how verifiable parental consent should be obtained.

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 ScoreFull Score
Comprehensive Assessment8865

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.

ConcernBasic ScoreFull Score
Data Collection: Protecting personal information8345
Data Sharing: Protecting data from third parties10080
Data Security: Protecting against unauthorized access10085
Data Rights: Controlling rights to data8865
Data Sold: Preventing sale of data7555
Data Safety: Promoting responsible use6760
Ads & Tracking: Prohibiting the exploitation of users' decision making process8685
Parental Consent: Protecting children’s personal information10085
School Purpose: Following student data privacy laws10075
Individual Control: Controlling data useNA65

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.

StatuteBasic ScoreFull Score
California Online Privacy Protection Act (CalOPPA)9476
Children's Online Privacy Protection Act (COPPA)8673
Family Educational Rights and Privacy Act (FERPA)9377
Student Online Personal Information Protection Act (SOPIPA)9574
General Data Protection Regulation (GDPR)9773
The California Consumer Privacy Act (CCPA)9072

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 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
  • 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: 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 indicate 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.
  • Intended for teens.
  • Intended for adults over 18.
  • Not 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.
  • Interactions, behaviors, or usage analytics data are collected.
  • Unclear whether this product collects sensitive data.
  • 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 collected.
2.3: Data Excluded
  • Specific types of personal information are excluded from collection.
  • 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.
  • Personal information is not 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
  • 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
  • Third-party services are used to support the product.
  • The roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
  • 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
  • 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.
  • Unclear whether personal Information is shared with third-party login providers.
3.15: De-identified or Anonymized Data
  • 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 not 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
  • 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.
  • Users can request to know what personal information has been shared with third parties.
  • Notice is not 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.
  • Methods are available to restrict who has access to data.
  • Processes to review student data are available for the school, parents, or students.
6.2: Data Integrity
  • The company does not attempt to maintain the accuracy of data they collect.
6.3: Data Correction
  • Processes to modify data are available for authorized users.
  • Processes for the school, parents, or students to modify inaccurate student information are available.
  • 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.
  • Exceptions to the data retention policy exist.
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 authorized users to delete data are available.
  • Unclear whether 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
  • 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
  • User information can not 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.
  • 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
  • All data in transit are encrypted.
8.6: Data Storage
  • 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
  • Data-privacy and/or security-compliance audits are performed.

9: Responsible Use

9.1: Social Interactions
  • Users can interact with trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information must be shared for social interactions.
9.2: Data Visibility
  • Personal information can be displayed publicly.
  • Users can control how their data are displayed to others.
9.3: Monitor and Review
  • User-created content is not reviewed, screened, or monitored by the company.
  • User-created content is not filtered for personal information before being made publicly visible.
  • Social interactions between users are not 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
  • 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
  • Traditional or contextual advertisements are displayed.
10.3: Behavioral Advertising
  • Personalised advertising is not displayed.
10.4: Ad Tracking
  • Data are not collected by third-parties for their own purposes.
  • User's information is not used to track and target advertisements on other third-party websites or services.
  • Data profiles are not 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.
  • The company does provide promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
  • Users can opt out of contextual, or personalised advertising.
  • 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.
  • 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 not restricted or prohibited for users under 13 years of age.
11.2: Students in K–12
  • 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.
  • Company is designated as a school official.
11.3: Parental Consent
  • Parental consent is required before personal information is collected or disclosed.
  • Unclear whether this product limits parental consent 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.
  • Parental consent obligations are transferred to the school or district.
11.4: Legal Requirements
  • The legal jurisdiction that applies to the laws governing the policies 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 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.