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Privacy Evaluation for KialoEDU

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Overview

Kialo EDU is an argument mapping site designed to assist teachers with the instruction of critical thinking and debate skills. The terms for Kialo EDU are clear that students may be able to interact with other users on the service and those users may be anonymous. Additionally, the terms are clear that Kialo EDU does not use any personal information from users to advertise nor will any tracking technologies be used for any purpose other than operating the service. The terms are also clear that the service uses industry best practices to protect the the personal information that is collected by Kialo EDU. Finally, the terms are clear that Kialo EDU may be used with students in K-12 and that the service expects schools to obtain any required consents for children.

Safety

Kialo EDU's terms are clear that the service allows users to interact with one another on the platform. They also indicate that it may be possible for users to interact with one another anonymously through instant access discussions. Additionally, the terms are clear that Kialo EDU does not filter or moderate posts before they are added by users. However, each discussion has an owner that is able to moderate posts from other users. Further, Kialo EDU's terms clearly state that users have the ability to use account settings to determine what personal information may be displayed to other users or publicly.

Privacy

Kialo EDU's terms clearly state that the service collect's personal information from users of the service. That personal information may be collected either by manually entering it when creating an account or when users register using a third party service like Google, Clever, or Microsoft. Those third party services may also be used to sign into Kialo EDU. Additionally, the terms are clear that the personal information collected by Kialo EDU is shared with service providers that facilitate the operation of Kialo EDU. The terms also are clear that the service will not use any personal information for advertising purposes, going as far as to state that there is no advertising on Kialo EDU. Further, the terms state that Kialo EDU does not make use of any third party tracking services and that the only cookies used by Kialo EDU are those that are strictly necessary to operate the service. Finally, the terms clearly state that if Kialo EDU merges or is sold to another company, users will be notified of the impending transfer of data and given the opportunity to delete their personal information prior to the transfer.

Security

Kialo EDU's terms clearly state that the company uses industry best practices to protect user data. They go into further detail and specify that data are encrypted in transit and at rest. Additionally, the terms state that the company follows the Zero Trust Security model which means that staff and other users are given access to the least amount of data and privileges needed. The terms also state that users may participate in the Kialo EDU service without providing any personal information and that managed accounts are available for educational institution users. Finally, the terms are clear that in the event of a data breach, impacted users would be notified within 3 days of Kialo EDU becoming aware of the breach.

Compliance

Kialo EDU's terms are clear that the service is aimed at children in K-12 schools. They are also clear that the company is willing to sign data protection agreements with schools and districts to ensure compliance with data privacy laws in various jurisdictions. Additionally, Kialo EDU's terms state that the company expects educational institutions to provide or obtain any required consents prior to using the service with children. Further, the terms make it clear that any content loaded into the service by users will remain the property of the user and the company only receives a limited license to use the content to operate the service. Finally, the terms make it clear that users may update and delete all personal information held by Kialo EDU wherever possible.

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: 65%

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.
  • Unclear whether this product collects biometric or health data.
  • Interactions, behaviors, or usage analytics data are collected.
  • Sensitive data are not 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 not collected by a third party.
Data Sharing
SCORE: 90%

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 not shared for analytics.
  • Unclear whether 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.
  • Third-party login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 100%

How does it secure data?

  • A user's identity is not verified with additional personal information.
  • Account creation is not required.
  • Managed accounts are available.
  • 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?

  • 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 not 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.
  • Users are notified if their information is transferred to a third party.
  • 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.
  • Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 80%

How safe is this product?

  • Users can interact with trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information must be not shared for social interactions.
  • 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 not filtered for personal information before being made publicly visible.
  • Social interactions between users are moderated.
  • Social interactions of users are logged.
  • Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 100%

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.
  • The company cannot send marketing messages.
  • The company does not provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 65%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • 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.
  • 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.
  • Parents can 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: 88%

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.
  • Additional rights or protections may be provided with an additional school contract.
  • Company is designated as a school official.
  • Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 55%

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.
  • 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.
  • 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.