Overview

Kami allows users to view and annotate documents and PDF files in class. The terms state that students can share their profiles, which include user names and email addresses, within their school, along with sharing user content. The terms state that the service collects personal information only for the purposes of offering the service and for the educational purposes originally intended. In addition, the terms state the service does not sell personal information to advertisers or other third parties and no information is used for advertising or tracking purposes. The terms state that both data at rest and in transit is encrypted, and the service takes reasonable security precautions to keep user information safe. Lastly, the terms state that verifiable parental consent is required for students to use the product, users retain ownership of their user submissions, and users can access, modify, or delete their personal information. Kami can be accessed through its website, and is also available as a Google Chrome Extension. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Kami’s website. Additionally, other policies used for this evaluation include: COPPA Privacy Policy, and Acceptable Use Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Compliance

Privacy Policy

Terms of Service

Review Comments from Region 16 Vetting :

• Paid version only

• Permissions for adding extension to Chrome and adding app to G-Suite Administrator Console should be carefully examined PRIOR to adopting and using with students.

  • Read, compose, send and permanently delete all your email from Gmail

  • View domains related to your customers

  • View groups on your domain

  • View organization units on your domain

  • View and manage the provisioning of users on your domain

  • Manage data access permissions for users on your domain

  • View audit reports for your G Suite domain

  • View usage reports for your G Suite domain

  • See, edit, create, and delete all of your Google Drive files

  • View your email address

  • See your personal info, including any personal info you've made publicly available

The below review below was written by commonsense.org

Safety

• The terms state that students can only share their profiles within their classroom or school. Teachers and students can both annotate documents and share them with each other, as well as attach audio or video to the content. User profiles can display user names and email addresses to other users. The vendor reserves the right to review conduct and content, but they have no obligation to do so, and do not claim responsibility for the content shared in the service.

Privacy

• The terms state the service collects personal information such as name and email address, and depending on the type of account, also collects physical address, payment information, and name of school. Users are notified if there are any material changes to the policies, but there is no review period; continued use of the product means acceptance of the new terms. The terms state the service only uses personal information for the purpose of providing the service to users and for the use and benefit of the learning environment. In addition, the product automatically collects information such as IP address, browser, internet provider, referring web pages, operating system, location information (depending on user settings), and more, but the vendor doesn't link that data to other information they collect.

• The terms state the service shares personal information with third parties only to perform tasks on the vendor's behalf, and the third parties must adhere to the same privacy policy. Any personal information collected from a child may be disclosed to the parent or teacher who originally registered the child. The terms state the service uses third parties to provide their services, and describe the roles of third party service providers. The terms also state the service does not sell personal information to advertisers or other third parties and no information is used for advertising or tracking purposes. Third parties with whom information is shared are contractually obligated to not share information with other parties. Lastly, users can upload content to the product, including documents, audio, and video, and may comment on or annotate documents shared with them.

Security

• The terms state that accounts are required in order to use the product. The vendor uses reasonable security, including having a team that works to keep information secure and avoid unauthorized access. Information is encrypted, both at rest and in transit. Data is stored on the Google Cloud Platform, outside the control of the vendor, but have obtained security certifications. However, the terms do not mention what action the vendor takes in the event of a data breach. Third parties with whom the vendor shares information are required to use at least the same level of security as the vendor. Lastly, the vendor takes steps to verify any teacher or parent identity before allowing access to a child's personal information.

Compliance

• The terms state the service is only intended for use by people over the age of 13; except for educational use, which comes with an additional COPPA & FERPA student data privacy policy. The terms also state that by using the services, users must be over 13 years of age, or have been granted approved access to the service by their school or parents. Other intended users of the product include teachers, K-12 students, and parents. Teachers and parents are able to create accounts for children. Information is collected from students when their school or teacher has an agreement with the vendor, and the information is used for learning purposes. In addition, information is only collected from children or students when verifiable parental consent has been obtained, which the terms state is the school's responsibility to obtain; proof of consent must be shown to the vendor if requested. The terms clearly state that user submissions are the property of the user, and the vendor doesn't claim any rights except those that allow them to offer their services. The vendor allows authorized individuals access to user information to review student data, modify information, or delete information or user accounts. User information is also deleted when users delete their accounts, unless the vendor is required to comply with legal obligations. Lastly, parents may also refuse to allow the vendor to collect further information from their child.