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Privacy Evaluation for GoBubble

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Overview

The GoBubble policies state it is a safe social network that allows kids under 13 to create and share text, film, photos, and emoji bubbles with anyone at their school, or with children of the same year, group, or age at other schools around the world. The terms state GoBubble will remove people from the service if they become aware of people trying to use it to upset others. In addition, the terms state GoBubble does not sell user information and they do not display any advertising and there is no tracking of users for behavioral or third party advertising in GoBubble or elsewhere on the Internet. The terms state that GoBubble uses reasonable security practices to protect a user's personal information and only team members with appropriate security clearance and training on GoBubble's internal data handling procedures have access to personal user data. Lastly, the terms state that GoBubble offer users a number of activities, some of which are directed at children under the age of 13, and other activities that are targeted for users of all ages.

GoBubble can be accessed from its website and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use accessed for this evaluation can be found on GoBubble’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: GDPR Policy, FERPA Policy, and COPPA Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms state GoBubble will remove people from the service if they become aware of people trying to use it to upset others. In addition, the terms state users can connect with their classmates and make new friends from lists of verified child users (only those of a similar age as you). In addition, users can see the profile overview (name and county/country) of users a similar age to support the social aspect of GoBubble. Users can also anonymously report abuse by users and it will be flagged to GoBubble's team to resolve the matter with 1 day. Lastly, the terms state GoBubble will notify users on the outcome, which can include suspending the other user or removing them from the site altogether.

Privacy

The terms state GoBubble collects only limited personal information such as a child’s first name, child’s last name, gender, username, account name, password, and parent or legal guardian’s email address, and other information collected automatically when users visit the service. In addition, the terms state GoBubble does not sell user information and they do not display any advertising and there is no tracking of users for behavioral or third party advertising in GoBubble or elsewhere on the Internet.

Security

The terms state that GoBubble uses reasonable security practices to protect a user's personal information and only team members with appropriate security clearance and training on GoBubble's internal data handling procedures have access to personal user data. In addition, the terms state the service encrypts all personal information and in the event of a data breach will provide notification to all users.

Compliance

The terms state that GoBubble offer users a number of activities, some of which are directed at children under the age of 13, and other activities that are targeted for users of all ages. However, the terms state no adults are allowed. GoBubble requires parental consent before the collection or use of any personal information from users under the age of 13 and obtains consent by an email (or other approved method) sent to the parent or legal guardian where they describe what information they would like to collect, how they propose to use it, and how the parent can offer and cancel consent. In addition, a parent or guardian can review, access, modify, or delete a child or student's information at any time by contacting GoBubble.

Rating

This product received a Pass rating based on the following details:
  • Personal information is not sold or rented to third parties.
  • Personal information is not shared for third-party marketing.
  • Personalised advertising is not displayed.
  • 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.
Data Collection
SCORE: 75%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Collection or use of data is limited to product requirements.
  • Geolocation data are not collected.
  • Biometric or health data are collected.
  • Interactions, behaviors, or usage analytics data are not collected.
  • Sensitive data are not collected.
  • Data is automatically collected.
  • 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: 75%

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.
  • Unclear whether the categories of third parties that receive data are indicated.
  • Data are shared for analytics.
  • Data are not 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: 85%

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.
  • Employee or physical access to user information is limited.
  • All data in transit are encrypted.
  • All data are stored in an encrypted format.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 90%

What rights do I have to the data?

  • Unclear whether 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.
  • A data-retention policy is available.
  • Processes for authorized users to delete data are available.
  • A user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 35%

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.
  • Third-party transfer is 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.
  • Data are not shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 85%

How safe is this product?

  • Users can interact with trusted users.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information must be shared for social interactions.
  • Personal information can be not displayed publicly.
  • Users can control how their data are displayed to others.
  • User-created content is 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 moderated.
  • Unclear whether social interactions of users are logged.
  • Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 60%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Traditional or contextual advertisements are not displayed.
  • Personalised advertising is not displayed.
  • 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.
  • 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: 95%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Not intended for parents or guardians.
  • 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.
  • Parental consent is required before personal information is collected or disclosed.
  • Parental consent is limited 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.
School Purpose
SCORE: 63%

Is the product intended for school?

  • Intended for students.
  • Personal information or education records are collected from preK-12 students.
  • Intended for teachers.
  • 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.
  • Unclear whether the company is designated as a school official.
  • Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 30%

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).
  • 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.