Pokémon GO is an augmented reality (AR) game that involves capturing imaginary "Pocket Monsters" in real world locations. Playing the game involves moving in the real world, and navigating to locations on a map. Within the game, current game play is focused on single users. However, because the game requires players to move about in the real world, game play potentially will involve interacting with other players, and other people who are not playing. Pokémon GO collects a range of personal and sensitive information including geolocation data, contact information, first and last name, email address, telephone number, and postal address, as well as content users share or upload, such as photos (including any metadata included in your photos and content). Lastly, the terms state that once the service obtains parental consent, a kid can use the services much like any other user.
Pokémon GO can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Pokémon GO’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Cookie Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
Within the game, current game play is focused on single users. However, because the game requires players to move about in the real world, game play potentially will involve interacting with other players, and other people who are not playing. While the majority of people play the game in relative safety, there have been instances of players getting mugged, being shot at, falling off cliffs, and driving into parked police cars. While these instances are not the necessarily the fault of the vendor (and recent safety improvements include warnings that get triggered when a player is in a moving car), they are noteworthy. Players are encouraged to always be aware of their surroundings, to avoid trespassing, and never to play while driving.
Privacy
Pokémon GO collects a range of personal and sensitive information including geolocation data, contact information, first and last name, email address, telephone number, and postal address, as well as content users share or upload, such as photos (including any metadata included in your photos and content). Data can be shared broadly with third parties, but the terms do specify that personal information is sold to third parties. In addition, the terms state personal information may be used for behavioral advertising and tracking users' online activities over time and across different websites and online services.
The terms also specify an additional Kids' Privacy Notice that puts additional protections in place for children under 13 years of age. However, with parental consent, the service may also use a kid's contact information to send the kid emails and messages with promotional information about new products and features, special offers, contests, and sweepstakes, as well as other information concerning new products, events, and updates about Pokémon.
Security
The terms state that in order to access some features of the service, users will need to create a Pokémon Trainer Club account ("PTC Account"). The terms also state the service takes appropriate administrative, physical, and electronic measures to protect user data, and they also reference third party security monitoring services. However, it is not clear if the"appropriate measures include industry standard practices like encrypting data at rest, or other commonly used measures to protect user data. The terms also omit details about security standards or audits performed on third parties who receive and process user data. Additionally, the terms do not contain details on any breach notification processes.
Compliance
Pokémon GO is a consumer application designed for a mixed audience use of children, teens, and adults. The terms state the service does not condition participation for kids on the collection of more personal information than is reasonably necessary. If this application is going to be used within an educational setting, teachers and schools should evaluate how the application is used, and should make sure to have parental notification and consent in place before the application is used. Additionally, teachers should be aware that certain types of uses of the application could potentially create an educational record that would be subject to FERPA regulation. The terms state parents can request to access, review, modify, delete and export personal information.
The terms state that once the service obtains parental consent, a kid can use the services much like any other user. The service may collect from a kid the same types of personal information as collected from other users, and use and share that information with third parties for the same purposes. Pokémon's terms state they do not allow third parties to collect kids' personal data (including persistent identifiers) for behavioral advertising, amassing a profile, or any purpose other than to support its internal operations unless they have obtained explicit prior parental consent.
