FreshGrade Privacy

One of the biggest concerns with any kind of social media platform, especially when it comes to children, is privacy. FreshGrade isn’t exactly the same as the most common social media platforms such as Facebook or Instagram, but I understand a cause for concern when information is being posted onto FreshGrade about a child, including their name, grade, school, and what they are doing from day to day. Because of this concern, I have looked into the privacy policy, and will try to summarize what I believe to be the most important points.

If you look at the privacy policy on the FreshGrade website (here), there is quite a bit of information you can read through, and it has emails you can use to ask questions about any concerns or questions. This post will mostly be a summary of what I thought was most important or interesting in this policy, but I encourage you to look through it yourself if you are interested in knowing all of the details. At the end of the privacy policy, it states that it was last updated in 2015, however this is what I was able to find on the FreshGrade website.

The policy starts with a few core beliefs, including not selling or using information for advertising, and not owning any user content (it is all owned by the users themselves). There is also an option to withdraw consent to the privacy policy at any time for any users who wish to. One of the most important considerations in this privacy policy is that
“personally identifiable information will be stored and processed in Canada, in full compliance with the British Columbia Personal Information Protection Act (PIPA), the Canada Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, the British Columbia Freedom of Information and Protection of Privacy Act (FOIPPA) and the U.S. Family Educational Rights and Privacy Act (FERPA).”

The page next defines what “personal information” includes. Personal information basically covers everything about a user (name, address, geographic location, date of birth, etc.) besides “aggregate” information which is data that helps them understand users without any identity attached to it.

Children under 13 are not allowed to use FreshGrade without parent consent. In addition to this, if FreshGrade ever discovers that a child under the age of 13 has been using FreshGrade without parental consent, they will delete any information of that student “as quickly as possible.” It does not clarify how long this may take.

Next, it goes through all of the information it can collect from users besides the obvious personal information. For example, they collect the IP address of the computer used to access FreshGrade, “your mobile device id, your computer’s operating system, the browser type, the address of a referring website, and the time and date of your visit and purchases.” Although these aren’t things would first come to mind as personal information, they treat this as personal information as well. Mostly, this information is collected through cookies, which you don’t have to accept, but your experience using FreshGrade will not be as complete as if you accept the cookies.

So far, most of the privacy policy has been focused on what information is being used, and next they explain how that information is being used. They break it down into four parts.

  1. General Services: This includes sharing information with other users as necessary, for example when a teacher shares information about students with their parents.
  2. Children’s Personal Information: This is used to create student account and send notifications to the parent or teacher about the student. The child’s personal information will be visible to the parent/guardian, the teacher, and possibly an administrator of the school.
  3. Aggregate Data: As mentioned before, aggregate data is not included in the definition of “personal information,” as it is not attached to any identity. This information is used for statistical data that can be shared, and to guide the updating of FreshGrade.
  4. Improve our Services: This one is fairly self-explanatory. They will use information to make their services better or to “detect, investigate and prevent activities that may violate our policies or be illegal.

The policy also says that they may share your information in other circumstances, such as in legal situations, to protect FreshGrade, users, or the public. It also says that information may be shared in the case that there is a business merger or the company is sold or acquired. This whole section “sharing of your information in other circumstances” is the first section where I feel there could be concern about the privacy of users. Recently in the news, there has been a story about “Turnitin,” a popular plagiarism checker. Turnitin is being acquired by Advance Publications (AP) for $1.75 billion. Now, all of the student work that has been put into Turnitin will also be available to this publication company. When users originally agreed to the terms of use, they were not agreeing to AP’s terms, but now AP will have access to all of their information anyways. Something like this could happen with FreshGrade as well, and there isn’t really a good way to predict if it will.

There is also a mention of third party websites, such as Google Drive or YouTube that could share information with FreshGrade about users where applicable. In these cases, it is important users understand the policies of any third parties that they may be using in conjunction with FreshGrade.

FreshGrade briefly summarizes their security practices, including encryption and confidentiality agreements for their employees. They also make it clear that users should choose a secure password, as they are not responsible for anyone unauthorized accessing users’ accounts through their own computers or devices. Parents of children under 13 also have the right at any time to access any information about their child, or to direct FreshGrade to delete it.

As with any technology, bugs and other glitches could happen, which they mention could potentially cause a problem with privacy. There could also be problems with slow updating in the event that you change or delete an account, however these changes are typically immediately updated. Finally they state that this policy could change at any time and users will have to accept any changes to continue using their services.

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