Common Sense Privacy Program

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Privacy Evaluation for Sown to Grow

Last updated
Applications and services with a Warning rating do not meet our recommendations for privacy and security practices. Applications and services with a Warning rating have issues narrowly focused around data use related to creating profiles that are not associated with any educational purpose, selling data, and/or using data to target advertisements.

65%

Warning

Learn how we rate

Overview

Sown to Grow is an online tool designed to provide regular emotional and academic check-ins with students, along with an accompanying curriculum. The terms for Sown to Grow are clear that the service may collect personal information about students. The terms are also clear that the information collected will be used to operate the service and will not be sold or shared with third parties for marketing purposes. The terms also indicate that users may be able to upload or create user content on the platform, but are unclear whether the service takes any measures to monitor or filter user content. Further, the terms indicate that Sown to Grow is intended to be used by schools and that those schools are expected to obtain the proper consents for any child who uses Sown to Grow. Finally, the terms state that reasonable security measures are in place to protect the information collected by the service but are unclear what those measures may include.

Safety

Sown to Grow's terms state that the service may allow users to send messages through the platform, but are not clear which users may send each other messages. Additionally, they do not address whether the service will take any measures to moderate potential interactions through those messages. Further, the terms are not clear whether the service allows information about users to be displayed publicly in any way, nor whether any public information could be filtered by the user or Sown to Grow.

Privacy

Sown to Grow's terms are clear that the service collects personal information from users to operate the service. They are also clear that the service limits the information collected to what is required to operate the service. Sown to Grow's term also indicate that personal information may be shared with third party service providers but that those providers may only use the information to provide their services to Sown to Grow. Additionally, the terms are clear that Sown to Grow does not sell information to third parties nor will information collected from students be used for any advertising purposes. However, the terms are not clear whether any contextual ads may be displayed or whether the service may market to other users. Further, the terms for Sown to Grow are clear that automated tracking technology may be used to operate the service effectively, but that the information collected will not be used for marketing purposes nor will the service track users on third party sites.

Security

Sown to Grow's terms are clear that users log in to access the service using accounts. They are also clear that there are different levels of accounts for students, teachers, and administrators that have varying rights to access information on the service. Additionally, Sown to Grow's terms indicate that if the service receives a request from a third party to access user information, they will work with the school to verify the third party's identity before providing information. Further, the terms state that Sown to Grow uses reasonable security measures to protect user information. However, they do not address what those measures entail, included whether encryption will be used. The terms also indicate that a unauthorized disclosure of personal information is possible, but do not indicate whether or how users would be notified of any such disclosure.

Compliance

Sown to Grow's terms are clear that the service is intended to be used by students in K-12 schools. They also indicate that the service may enter into agreements with schools and that the service may be declared a "School Official" under the guidelines found in FERPA. The terms are also clear that the service expects schools to obtain or grant any necessary consents for the collection of personal information from children under the age of 13. Further, Sown to Grow's terms are clear that those consents need to be in place before any student information is entered into the platform. Finally, the terms are clear that authorized users are able to review and modify the their personal information in the Sown to Grow system and provide information for parents to do the same for their children.

Rating

This product received a Warning 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: 45%

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.
  • Unclear whether this product collects geolocation data.
  • Biometric or health data are collected.
  • 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.
  • Unclear whether personal information of users is collected by a third party.
Data Sharing
SCORE: 85%

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.
  • Unclear whether 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.
  • Third-party login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 45%

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.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 60%

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.
  • A user's data are not 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.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 40%

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.
  • 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: 50%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • 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: 75%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Unclear whether 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.
  • 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.
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: 45%

Can I control the use of my data?

  • Unclear whether 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.
  • Combined information is treated 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.
  • 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.

Learn more about the SPR Read the report

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.