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.
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. 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.
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.
 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).
 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).