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Privacy Evaluation for Coolmath

Last updated

Overview

Coolmath is an online tool for middle and high school age users and teachers to review math topics through interactive games. The policy does not indicate if users are able to interact with one another while using the site. The policy states Coolmath collects information directly from users and user devices, from third parties, and by automated means.

In addition, the policy confirms Coolmath and third parties use tracking tools to observe user behaviors over time and across other sites. The policy states data may be shared to companies who perform services on Coolmath's behalf, to serve interest-based ads that support the business, for analytics and tracking, and for legal compliance. The policy also states aggregated data may be shared with third parties for research, compliance, or any other reason. The policy confirms the services are supported by tailored advertising; ad servers use information collected from users to serve interest-based advertisements on the website and apps. The policy confirms Cool math and third parties use cookies and other tracking technologies to better understand user interests and behaviors and browsing activities over time across websites and platforms.

Coolmath 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 Coolmath’s website, at the iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: About our Ads. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The policy does not indicate if users are able to interact or if interactions are monitored by Coolmath. In addition, it is not clear if personal information is publicly visible in any way.

Privacy

The privacy policy for Coolmath is up to date, but the terms of use does not list an effective date. The policy confirms Coolmath may share data such as name, address, username, Google Analytics User ID, IP address, internet activity information, and cookie information with service providers, advertising partners, and through business transfers. The policy specifies third party services such as payment processors and advertising partners are used to support Coolmath. The policy does not indicate if third party or social logins are supported by Coolmath. According to the policy, Coolmath may disclose information in the event of a business acquisition, merger, sale, transfer, or bankruptcy; the policy does not indicate if users will be notified.

Security

The policy does not indicate if user accounts are protected by multi-factor authentication. Furthermore, the policy does not indicate if data encryption is used or if users will be notified in the event of a data security breach.

Compliance

The policy does not indicate if Coolmath has a retention policy. The policy states, if a user is under 18 and wants to purchase a subscription, the parent or guardian must register and agree to the terms on behalf of the user, however it is unclear if verifiable consent is collected.

Rating

This product received a Warning rating based on the following details:
  • Unclear whether personal information is sold or rented to third parties.
  • Personal information is shared for third-party marketing.
  • Personalised advertising is displayed.
  • 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.
Data Collection
SCORE: 40%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Unclear whether the collection or use of data is limited to product requirements.
  • 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.
  • Unclear whether opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is collected by a third party.
Data Sharing
SCORE: 80%

What data does it share?

  • Collected information is shared with third parties.
  • The categories of information shared with third parties are indicated.
  • The purpose for sharing a user's personal information with third parties is indicated.
  • The categories of third parties that receive data are indicated.
  • Data are shared for analytics.
  • Data are shared for research and/or product improvement.
  • Third-party services are used to support the product.
  • The roles of third-party service providers are indicated.
  • Unclear whether this product supports third-party login.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 20%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Account creation is not required.
  • Unclear whether managed accounts are available.
  • Unclear whether multi-factor account protection is available.
  • Unclear whether third-parties with access to information are required to provide the same security protections as the company.
  • Reasonable security practices are used to protect data.
  • Unclear whether this product limits employee or physical access to user information.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether all data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 10%

What rights do I have to the data?

  • Unclear whether users can create or upload content.
  • Unclear whether users retain ownership of their data.
  • Unclear whether this product provides processes to access and review user data.
  • Processes to modify data are available for authorized users.
  • Unclear whether the product provides a data-retention policy.
  • Unclear whether authorzied users can delete data.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Unclear whether this product deletes data when no longer necessary.
  • Unclear whether methods are available to restrict who has access to data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 20%

Is the data sold?

  • Unclear whether personal information is sold or rented to third parties.
  • Unclear whether users can opt out from the disclosure or sale of their data to a third party.
  • 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.
  • Unclear whether user information can be deleted prior to its transfer to a third party.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • User information that is shared is not shared in an anonymous or de-identified format.
  • Unclear whether the company describes their de-identification process of user information.
  • Data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 0%

How safe is this product?

  • 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.
  • Unclear whether personal information can be displayed publicly.
  • Unclear whether this product allows users to control how their data are displayed to others.
  • Unclear whether user-created content is reviewed, screened, or monitored by the company.
  • 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.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 35%

Are there advertisements or tracking?

  • Personal information is shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Personalised advertising is displayed.
  • 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.
  • Unclear whether this company can send marketing messages.
  • Unclear whether this company provides promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised advertising.
  • Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 40%

Can I provide parental consent?

  • Unclear whether intended for children under 13.
  • Personal information from children under 13 years of age is not collected.
  • Intended for parents or guardians.
  • Unclear whether company has 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.
  • 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.
School Purpose
SCORE: 25%

Is the product intended for school?

  • Intended for students.
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Intended for teachers.
  • 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 not 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.
  • Unclear whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: 15%

Can I control the use of my data?

  • Unclear whether users can control the use of their information through privacy settings.
  • 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.
  • Company may combine data with additional data from third-party sources.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Unclear whether notice is provided if the context in which data are collected changes.
  • Unclear whether consent is obtained if the practices in which data are collected change.
  • Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
  • Unclear whether 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.

Common Sense Standard Privacy Report (SPR)

The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.

About Privacy Evaluations

The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.

Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.