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Privacy by Default

Criteria: The default settings in this product prioritize my privacy; to give up privacy, I actually need to change the settings.

See the test in action:

Indicators

  1. Targeted advertising is off by default.
  2. User interface settings which are optimal for privacy are set by default.

Methodology for Assessing Each Indicator

1) Targeted advertising is off by default.

  • Determine whether the product or service hosts advertising or sends ads to users.
  • If the product or service hosts or sends ads, look for places where a user might be able to control privacy settings.
    • If a product has multiple interfaces, such as a mobile app, a web app, or an in-device interface, make sure to investigate all of them.
    • Privacy settings may be in a 鈥減rofile鈥 section of an app, or under the app鈥檚 鈥渟ettings.鈥
    • If the manufacturer has a website that users may visit, look at the website鈥檚 privacy policy for information about targeted advertising.
  • If there is a privacy setting for 鈥渢argeted advertising鈥 (which may also be called 鈥渋nterest-based鈥 or 鈥渂ehavioral鈥 advertising), note whether the setting is on or off for a new user.
  • Look in the manufacturer鈥檚 legal documents for a list of how it uses user data.
    • Note whether 鈥渢argeted advertising鈥 or a similar term is listed as a possible use of user data.
  • If the manufacturer does not host or display ads or if it only hosts or displays ads that are not targeted (e.g. contextual), mark PASS.
  • If the manufacturer lists targeted advertising as a way it uses user data in its legal documents, and there is a user setting for controlling it that is set to 鈥渙ff鈥 for a new user, mark PASS.
  • If the manufacturer lists targeted advertising as a way it uses user data in its legal documents, and there is no setting for controlling it, or if there is a user setting for controlling it but it is set to 鈥渙n鈥 for a new user, mark FAIL.

2) User interface settings which are optimal for privacy are set by default.

  • Look for places where a user might be able to control their privacy settings.
    • If a product has multiple interfaces, such as a mobile app, a web app, or an in-device interface, make sure to investigate all of them.
    • Privacy settings may be in a 鈥減rofile鈥 section of an app, or under the app鈥檚 鈥渟ettings.鈥
  • Identify all of the settings that could have an effect on the privacy of a user鈥檚 personal information, (e.g., collection of location, sharing with third parties, or usage analytics) and note how those settings are configured for a brand new user.
  • If all privacy settings identified are set by default to the choice that limits the amount of personal information shared and maximizes the user鈥檚 privacy, mark PASS.
  • If some or all of the settings identified are set by default to choices that do not maximize the user鈥檚 privacy, mark FAIL.
  • If there are no visible settings that would enable the user to control data collection or use that may affect the user鈥檚 privacy, mark FAIL.
Privacy by Default

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