Last posted on July 17, 2019

Welcome to Xooloo Parent, Xooloo Digital Coach, Xooloo App Kids and Xooloo Internet.

The privacy of our visitors and users is important to us. You trust us to make available to you Xooloo applications to make your family’s digital experience more enjoyable and of better quality. This privacy policy (“Privacy Policy“) covers Xooloo Parent, Xooloo Digital Coach, Xooloo App Kids and Xooloo Internet (in each case, the “Application”) and the website at www.xooloo.com and related websites like the Parent section: https://parents.xooloo.com (collectively, the “Site”) owned and operated by Xooloo SAS (“Xooloo”). Please read it carefully so you understand what, how, and why we collect information about our users, how we protect personal information about our users and in which limited circumstances Xooloo may have to share such information with other parties. In this Privacy Policy, “we”, “us”, “our” and other similar references mean Xooloo and “you” and “your” and other similar references mean a specific user of the Application. By visiting and using the Application and the Site, you agree to and accept the practices described in this Privacy Policy.

If you do not agree with this Privacy Policy or revised Privacy Policy terms, as they may be updated from time to time do not use or purchase the Application.

If you have questions or concerns about our privacy policy or practices, please contact us at info@xooloo.com.

We may update this Privacy Policy from time to time to reflect changes to our information practices. If we make any material changes, we will notify you by displaying a notice on this Site or the Application about those changes and their effective dates. We encourage you to periodically review this page for the latest information on our privacy practices.

If you do not agree with the Privacy Policy or revised Privacy Policy terms, do not use or purchase these Applications.

This Privacy Policy is in addition to your rights and obligations under the Terms of Use posted on this Application. For the avoidance of doubt, in the event of a conflict between the Terms of Use and this Privacy Policy or other terms and conditions related the Application, the Terms of Use will control. If you are unsure of your rights under this Privacy Policy, please contact us at info@xooloo.com.

The Xooloo App Kids Application can only be installed by a parent or a legal guardian for use by children. If you are under 13 or between 13 and 18 years of age (or such older age as required by the laws of your state of residency), you must have a parent or a legal guardian approve all information, and ensure that the parent or legal guardian’s email address and contact information is used at all times.

If we make material changes to how we collect and use Personal Information (as defined below) of children under the age of 18, including children under the age of 13, we will first notify parents by email in order to obtain verifiable parental consent for the new uses of the child’s Personal Information.

Children’s Privacy. We do not knowingly collect information about children under 13 years old through the Site. If we learn that we have collected personally identifiable information from a child under 13 other than in a manner authorized by law, we will delete that information from our database.

What Personal Information Does Xooloo Collect through the Application?

The information we collect through our Applications helps us provide you with services specific to your needs and interests.

Personal Information Collected. For the purposes of this Privacy Policy, “Personal Information” is any information that identifies a user, would enable someone to contact a user, or describes the relationship of a user with Xooloo.

We collect and store Personal Information from any user who creates a Xooloo account and/or installs the Application. We may collect additional information during the use of the Application.

We collect the following Personal Information from you as a parent or legal guardian, to create and manage your account: your email address, your child’s first name, birthdate and gender. On Xooloo Parents we will also collect the type of device used (Android or iOS) and the device language. Additional information may be collected passively from your child device. For the Xooloo Digital Coach Application, we may collect the following Personal Information from your children device to provide our service: consulted websites addresses if web protection is enabled, messages sent by the children within Xooloo Digital Coach to ask their parents for extra time, the brand and model of the device, the device language, the OS version, the list of applications installed on the device, the time and duration of applications usage as well as the time zone set on the device when the application was setup. If the application is used on a device with a SIM card, the following information may also be collected: the time and duration of incoming and outgoing calls as well as the related numbers, the ICCID number of the SIM card and its phone number, the contact lists (name and number) after authorization is provided. Finally the application also lets children send text messages to the Xooloo support using a form available from the application. Messages are received by Xooloo support staff who can only reply to the parents to help them resolve an issue raised by the child.

We use this information to administer your account and provide our services generally, including without limitation: choosing a protection mode, select applications a child user can have access to, select contacts you authorize a child user to receive call from and to make call to, to set a daily time usage and also a time schedule for the different app categories, access categories-based reporting. The information collected is used to provide detailed information to parents only, who have installed the Application on their children’s devices and who use the Application Xooloo Parents or the Parents Web interface.

We sometimes use non-personally identifiable or “aggregate information” that we collect to improve our services. Your child’s application usage will also be used as aggregate data to offer average usage data to all users. This is how you will also get the average for children of the same age and gender as yours. Aggregate data is not information that could be used to identify you or your child or to contact you or your child. If as a parent, you do not want your children app usage to be used anonymously you have the option to go to the Xooloo Parent Application under Family setting / Family stats. In that case, you and your children will not be able to be informed of the average use of others children of the same age and gender which is part of the service.

For the Xooloo App Kids Application, that was created to allow a parent or legal guardian to share their devices with their children and can only be installed by a parent or legal guardian for use by their child, we may collect the following Personal Information from the device that use the Application: the parent email address, the password chosen by the parents, the OS version, the device language, the brand and model of the device and the list of applications selected by your children to create a wish list. This will then prompt an email to the parents allowing you to set permissions to allow your child to use the selected applications.

Tell-A-Friend: Parents if you choose to use our referral service to tell a friend about our Application you will get 1 month free of use for each friend you tell about the Application and up to a maximum of 12 months free. Your friends will each get 1 month free of use of the Application after their 30-days trial period. You will be able to choose among different modes of communication to contact your friend. You will then send your friend a message inviting them to use the Application. We do not store this information for any reason. This section of the application or the web site is password protected so that only parents are allowed to use this section.

For Xooloo Internet, we do not collect Personal Information when Xooloo Internet is used on its own. When Xooloo Internet is used with Xooloo Digital Coach and Web protection enabled, Xooloo Internet automatically protects the Web navigation. As a result, the following Personal information may be collected passively from your child device: consulted websites addresses if web protection is enabled.

Cookies and Anonymous identifiers. Cookies are pieces of data assigned by a web server that uniquely identify the browser on your computer. We use cookies for a variety of purposes in order to enhance the quality of our Site. We use “session cookies” to provide continuity from page to page. A session ID cookie expires when you close your browser. We also use persistent cookies. Persistent cookies allow parts of our Site to recognize your browser when you return after your first visit to that part of our Site. Cookies allow us to personalize your return visits to our Site and to save you time during certain activities.

An anonymous identifier is a random string of characters that is used for the same purposes as a cookie on platforms, including certain mobile devices, where cookie technology is not available. We do not link the information we store in cookies or anonymous identifiers to any Personal Information. Viewers have the option to accept or disable cookies at any time through their browsers. Please remember that if you delete your cookies, or use a different browser or computer, you will need to set your cookie preferences again.

Most web browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.aboutcookies.org or www.allaboutcookies.org. Please note, however, that without cookies you may not be able to take full advantage of all our Site features.

The use of cookies by our partners, affiliates, tracking utility company, and service providers is not covered by this Privacy Policy. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, service providers use session ID cookies to make it easier for you to navigate our Site and Application related services.

Server Statistics. These statistics include hits to the servers serving the Application. The servers are operated by us. The information that is collected in this manner does NOT provide us with any Personal Information about our users. This allows us to pinpoint high traffic areas and make sure the service is properly operated.

Mobile Analytics

To improve our service and allow us to better understand the functioning of the Application on the device and analyze what people are doing on the Service, we use mobile analytics software Matomo (https://matomo.org/matomo-on-premise/). This software may record information such as how often you use the Application, the events that occur within the Application, aggregated usage, performance data, and where the Application was downloaded from. In this context, we collect the pages displayed within the service, an approximate IP address, the brand and the model of the device, the OS version, the date and time of use. We do not link the information we store within the analytics software to any personally identifiable information you submit within the Application.

We also use Crashlytics (https://firebase.google.com/terms/crashlytics/), a Google company, to help us identify any crash within the service so we can fix it when it occurs. As a result, Crashlytics may collect the following anonymous information from the user device: the anonymous identification number of the device, the brand and model of the device, the device language, the orientation of device when the problem occurred, the available RAM and storage, the OS Version, the date and time when the problem occurred, the Application version, and the logs trace. Crashlytics has no access to your child personal information actively collected by Xooloo.

We do not link the information we store within the analytics software to any personally identifiable information you submit within the Application.

How Does Xooloo Use the Information it Collects about its Users?

Our users’ information and privacy is important to us, and we do not share, sell or lease it to any third party, except as expressly indicated in this Privacy Policy.

Xooloo uses Personal Information collected from users to deliver the requested services, respond to requests such as retrieving user’s password, to inform users of amendment of the Privacy Policy, contact a customer with respect to a violation or alleged violation of the Terms of Use of the Application, and notify promotions, updates, or special offers that we think may interest our users and otherwise for the specific purpose for which it was volunteered.

Promotional Announcements. Our users may receive periodic communication from us with information regarding new activities and services or upcoming promotional offers or events. If you do not wish to receive such communication, you may opt out of these emails or modify your device settings at any time when you receive marketing and advertising e-mails or notifications from us.

Service-related Announcements. We will send you strictly service-related announcements on occasions when it is necessary to do so. For instance, we might send you an email to send you your account activation information or to advise you if our service is temporarily suspended for maintenance. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account and uninstall the Application.

Wishlist: the Xooloo App Kids Application allows your child to create a wish list among a list of third party applications curated by Xooloo and select the ones they would like to use. This will then prompt an email to the parents in order for the parents to set permissions to allow their child to use the selected applications.

When Does Xooloo Share Information It Collects with Third Parties?

We may disclose Personal Information we collect from users if required by law, or in the good-faith belief that disclosure is necessary (a) to cooperate with any law enforcement authorities and comply with any judicial order requesting or directing us or any affiliate to disclose the identity of anyone accessing, transacting, registering, and/or otherwise using the Application in violation of any applicable federal, state, or local laws; (b) to enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of the Application, our users, or others; or (c) to act in an emergency to protect the personal safety of users of our Application or the public. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

We may provide your Personal Information to companies that provide services to help us with our business activities such as processing payments or offering customer service. These companies are authorized to use your Personal Information only as necessary to provide these services to us.

In case Xooloo, or substantially all of its assets, are acquired by one or more third parties as a result of a merger, sale, consolidation or liquidation, customer information may be one of the transferred assets. If Xooloo is involved in such a transaction, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Parent users have the option to consent to our collection and use of their child’s Personal Information without also consenting to the disclosure of such information to third parties as we will not share this information with any third parties.

Links to Third Party Websites/Applications

Links provided on the Application or the Site to third party websites or applications are provided as a convenience to you, and we do not control those websites or applications or their privacy practices, which may differ from ours. We do not endorse or make any representations about any third party websites or applications that may be accessible through the Application. We encourage you to review the privacy policy of any website or application before submitting your personal information. The personal data you choose to give to unrelated third parties is covered by their privacy policies, not this Privacy Policy. Some third parties may choose to share their personal data with us; in which case that sharing is governed by that third party’s privacy policy.

How Secure Is Your Personal Information?

The security of your Personal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during its transmission and storage. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. It is important that you take individual precaution against unauthorized access to your password and to your device. Be sure to sign off when finished using a shared device. Except as specified in this Privacy Policy, we use commercially reasonable efforts to limit access to your Personal Information to only the employees, agents, and officers of Xooloo who require the information in the performance of their work-related duties.

Access to Your Personal Information

If your Personal Information changes, or if you no longer desire our service, you may correct, update, delete/remove it by emailing our customer support at info@xooloo.com.

We will retain your Personal Information for as long as an account is active or as needed to provide services. We will retain and use the Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel the account or request that we no longer use the Personal Information to provide services contact us at the email address specified above.

If your Personal Information changes or you wish to have your Personal Information deleted or refuse further collect on and use of your Personal Information, you may do so by contacting us at info@xooloo.com.

Consent To Processing Outside The United States

By providing any Personal Information to Xooloo, all users fully understand and unambiguously consent to this Privacy Policy and to the transfer of their Personal Information across international borders in accordance with Xooloo’s standard operations, including the collection, storage, and processing of such information in France and waive any rights that they may have under their local laws which would conflict with Xooloo’s Privacy Policy.

Your California Privacy Rights.

As provided by California Civil Code Section 1798.83, a California resident who has provided Personal Information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California user“) is entitled to request information about whether the business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes.

As stated in this Privacy Policy, we do not share information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by opting in to receive information from a third party that is participating in some activity described on our Applications. If you do ask us to share your information with a third party for its marketing purposes, we will only share information in connection with that specific activity, as we do not share information with any third party on a continual basis. To prevent disclosure of your Personal Information for use in direct marketing by a third party, do not opt in to such use when you provide Personal Information on our Application. Please note that whenever you opt in to receive future communications from a third party, your information will be subject to the third party’s privacy policy. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as we have no control over how third parties use information. You should always review the privacy policy of any party that collects your information to determine how that entity will handle your information.

California users may request further information about our compliance with this law by contacting us at info@xooloo.com. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through our Site.

Information to Parents

Xooloo takes commercially reasonable measures to provide its products and services in an environment as secure as possible. However, the use of this Application does not substitute for the parents’ or legal guardian’s own guidance and monitoring of their children’s activities on the Internet.

Contact details

If you have questions or suggestions regarding this Privacy Policy or our privacy practices please contact us by email at info@xooloo.com or by postal mail at Xooloo SAS, 20 rue Danielle Casanova, 75002 Paris, France.