A majority of applications and services are non-transparent or explicitly allow Traditional Advertising.

Among the applications and services we evaluated for our 2018 State of EdTech Privacy Report, approximately 17% disclosed a qualitatively better response that they do not display any traditional advertisements to children or students. In contrast, approximately 40% of applications and services disclosed they may display traditional advertisements to users as a means to monetize otherwise free to use edtech tools. This evaluation question only examined whether or not the vendor discussed qualitatively better or worse practices for contextual advertising, but not targeted, or behavioral advertising.

Traditional advertisements (otherwise referred to as contextual advertisements), display products and services to users based only on the relevant content or webpage in which the user is currently viewing, but contextual ads do not collect any specific information about the user in order to display these ads. However, targeted advertisements do collect generalized information about users from various sources that include: demographic, location, gender, age, school, or interests. This information is collected in order to display products and services to a more specific targeted audience that may be more directed to users than simply contextual advertisements. Behavioral advertisements take targeted advertisements one step further, and collect specific information about users typically through the use of cookies, beacons, tracking pixels, persistent identifiers, or other tracking technologies that provide more specific information about the user. This information is then shared with advertisers, who display even more targeted products and services than targeted advertisements to the user based on the information they received from the user’s activities on the application or service. Parents and teachers assume that most free to use applications and services may display advertisements, and often use these services with a lower expectation of privacy, but our analysis observed both free and paid services displaying advertisements. However, among the applications and services that required parent, teacher, or district paid subscriptions, or student in-App-Purchases, the overwhelming majority did not display any form of advertising. Therefore, we observed a strong correlation of advertising use among the free applications and services evaluated, as compared to paid services. This likely results in an increased exposure to advertisements for children and students using only free versus paid applications and services, which can serve to normalize otherwise qualitatively worse advertising practices and lead to lower expectations of privacy for children and students.

In contrast, approximately 43% of applications and services were non- transparent on this issue. Although observationally, we determined among applications and services that clearly displayed traditional advertisements, many did not disclose those practices in their policies. This behavior is likely because these applications and services believed the practice of displaying advertisements to be self-evident. Moreover, among applications and services that were non-transparent but did not display any advertisements, it is assumed their lack of transparency is because they do not believe they need to disclose otherwise qualitatively worse practices they do not engage in. However, when these practices are not transparently disclosed, there is no future expectation or trust on behalf of parents, teachers, schools, or districts about how collected information from children and students will be handled in order to meet their expectations of privacy.

Compared to our analysis in Behavioral Advertising, more applications and services appeared to be non-transparent in their policies about contextual ads than behavioral ads. Similarly, we observed a percentage increase in qualitatively better disclosures from vendors that do not display behavioral ads, but a decrease in the percentage of qualitatively worse practices relative to behavioral ads. Therefore, it appears applications and services are more likely to be non-transparent and disclose qualitatively worse practices about Traditional Ads, rather than Behavioral Ads. However, this increase in the percentage of qualitatively worse disclosures is expected, as compliance obligations for applications and services intended for children provide an exception for vendors to display contextual advertising.[1] Lastly, the percentage increase of non- transparency on this issue as compared to Behavioral Advertising, should also take into account conflicting Federal and State laws that provide an important distinction between contextual advertising directed to students.[2]


Figure 1: This chart illustrates the percentage of question responses for Traditional Advertising. Qualitatively better question responses indicate the application or service does not display any traditional advertisements to children and students. Qualitatively worse question responses indicate the application or service does display traditional advertisements to children and students. Non-Transparent responses indicate the terms are unclear about whether or not the application or service displays traditional advertisements to children and students.

For more information about our key findings download the full 2018 State of EdTech Privacy Report.
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[1] Children’s Online Privacy Protection Act (COPPA), 16 C.F.R. Part 312.2 (an operator may display contextual advertisements to a child under the age of 13 without verifiable parental consent, under the ’internal operations’ exception).

[2] Student Online Personal Information Protection Act (SOPIPA), Cal. B.&P. Code §22584(b)(1)(A) (an operator is prohibited from using student data for targeted, behavioral, or contextual advertising).

Girard K.

Girard Kelly is an attorney focused on Internet, privacy, cybersecurity, and Intellectual Property law who thrives on cutting-edge legal issues and has a strong background in public policy, information technology, entrepreneurship, and emerging technologies.

Jeff G.

Prior to joining Common Sense Media, Jeff Graham worked with Bill Fitzgerald at FunnyMonkey for nearly 8 years. While at FunnyMonkey Jeff worked to provide targeted and appropriate open source solutions for various educational and social justice focused organizations. At Humboldt State University he studied Theoretical Mathematics and Computer Science. Outside of work Jeff is a fan of the outdoors appreciated via backpacking, camping, and cycling.