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Privacy Evaluation for Glose Education

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Overview

Glose Education is a website and mobile app. It is an ereader and audiobook platform that is marketed for schools. The terms do not clearly indicate whether user content may be publicly displayed nor whether this content is monitored or filtered. The terms state the service collects personal information such as billing information, IP addresses, names, audio recordings, and basic information about the classes that the user is part of. The terms state the service does not sell personal information and that such information is not used to display advertisements on the first party product nor advertisements on third party services. The notices indicate that the company takes reasonable security measures regarding the protection of personal information and will give notice to consumers in the event of a data breach. The terms state the user can access, modify, and delete personal information that the company maintains.

Glose Education can be accessed at the following locations: website, Apple App Store, and Google Play Store. The following 2 policies were used to evaluate Glose Education: 1 and 2. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Rating

This product received a Warning rating based on the following details:
  • Personal information is not sold or rented to third parties.
  • Unclear whether personal information are shared for third-party marketing.
  • Personalised advertising is not displayed.
  • Unclear whether data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
Data Collection
SCORE: 25%

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.
  • Unclear whether this product collects geolocation data.
  • 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.
  • Unclear whether opt-in consent is requested from users at the time personal information is collected.
  • Unclear whether personal information of users is collected by a third party.
Data Sharing
SCORE: 40%

What data does it share?

  • Collected information is shared with third parties.
  • Unclear whether the categories of information shared with third parties are indicated.
  • The purpose for sharing a user's personal information with third parties is indicated.
  • Unclear whether the categories of third parties that receive data are indicated.
  • Unclear whether data are shared for analytics.
  • Unclear whether data are shared for research and/or product improvement.
  • Third-party services are used to support the product.
  • Unclear what the roles of third-party service providers are.
  • Unclear whether this product supports third-party login.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 55%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is required.
  • Managed accounts are available.
  • Unclear whether multi-factor account protection is available.
  • 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.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 65%

What rights do I have to the data?

  • Users can create or upload content.
  • Users retain ownership of their data.
  • Processes to access or review user data are available.
  • Processes to modify data are available for authorized users.
  • Unclear whether the product provides a data-retention policy.
  • Processes for authorized users to delete data are available.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Unclear whether this product deletes data when no longer necessary.
  • Methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 25%

Is the data sold?

  • Personal information is not 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.
  • 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.
  • Unclear whether data are shared for research and/or product improvement.
  • Contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 45%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users.
  • 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.
  • Users can control how their data are displayed to others.
  • User-created content is not reviewed, screened, or monitored by the company.
  • User-created content is filtered for personal information before being made publicly visible.
  • Social interactions between users are not moderated.
  • Social interactions of users are not logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 20%

Are there advertisements or tracking?

  • Unclear whether personal information are shared for third-party marketing.
  • Traditional or contextual advertisements are not displayed.
  • Personalised advertising is not displayed.
  • Unclear whether data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
  • Unclear whether this company can send marketing messages.
  • Unclear whether this company provides promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
  • Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 0%

Can I provide parental consent?

  • Unclear whether intended for children under 13.
  • Unclear whether this product collects personal information from children under 13 years of age.
  • Unclear whether 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 not 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.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 31%

Is the product intended for school?

  • Intended for students.
  • 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: 70%

Can I control the use of my data?

  • Users can control the use of their information through privacy settings.
  • Use of information is limited to the purpose for which it was collected.
  • The context or purpose for which data are collected is indicated.
  • Unclear whether company may combine data with additional data from third-party sources.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Notice is provided if the context in which data are collected changes.
  • Consent is obtained if the practices in which data are collected change.
  • A grievance or remedy mechanism is available for users to file a complaint.
  • 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.