CHILDREN'S ONLINE PROTECTION AND PRIVACY ACT NOTICE

Dear Parent,

In case your child is under 13 years of age, we need to inform you of the personal information that will be collected directly from your child’s mobile device when using our services if you decide to create an account to use the Applications of the Xooloo’s family pack (the “Application” or the “Service”). It is Xooloo's intention to adhere to the Children's Online Privacy and Protection Act (COPPA). This notice describes our practices of collecting, using, and disclosing personal information from children under 13 years of age. We also suggest that you review our Privacy Policy.

If you have any questions about this notice or the Privacy Policy, you may contact us by e-mail at info@xooloo.com.

When offering our services to your family, Xooloo will actively collect personal information from you as a parent or legal guardian to create your account, and passively collect personal information from your child’s device as part as the services we offer within Xooloo’s family pack.

We collect limited personal information from children users and have designed our Applications so that children can use it without giving out unnecessary personal information. We also allow you as a parent or legal guardian to review your child's personal information, ask to have it deleted, and refuse to allow any further collection or use of his or her child's information (see below for further instructions).

Your consent is required for the collection, use and disclosure of your child’s personal information during the use of our services as we will passively collect information from your child’s device. We will not collect personal information from your child until we have received your consent. You will find instructions on how to give your consent below. You may revoke your consent at any time by contacting us at info@xooloo.com. In certain cases, we may ask you to uninstall our Application before we close your account.

Information Collected. We collect the following personal information from you as a parent or legal guardian to create and manage your account: your email address, the name of your child or children, their dates of birth and their genders. On Xooloo Parents, we will also collect the type of device used (Android or iOS) and the device language.

If you are using the Xooloo Digital Coach Application, we may collect the following personal information from your child’s device to provide them with our services: consulted web sites 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, and 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.

If you are using the Xooloo App Kids Application, this application 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. When your child uses the Xooloo App Kids application, we may collect 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 them prompt an email to the parents allowing you to set permissions to allow your child to use the selected applications.

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.

Collection of Information by Third Parties. We do not allow third parties to collect personal information from our applications.

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.

Collection Additional Information in the Future. As we expand the services we provide, we may collect additional types of personal information. We will ask you for your permission before collecting any of this additional information from your child.

Use of Information. Your child’s information collected from your child’s device will be disclosed to you as part of our service within the Xooloo Parents Application or the web Interface dedicated to Parents. You will be able to log in to view information about your child's use of the Service, including their performance on certain tasks, assignments and other activities. All this information will only be used to deliver the requested services.

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 you do not want your children app usage to be used anonymously you have the possibility to go to the Xooloo Parent Application under Family settings / 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.

Disclosure of the Information. We do not share, sell or lease this information to any third party, except as expressly indicated in this notice and our Privacy Policy.

Xooloo will not disclose your child's personal information to any third party without your express prior authorization, except in aggregate, non-personally identifiable form or in the following cases: (i) to third party vendors, service providers, contractors or agents who perform functions on our behalf, who are subject to confidentiality and security obligations; (ii) if we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected to the other company, (iii) to comply with the law, a judicial proceeding, court order, subpoena or other legal process or (iv) where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, activities not permitted by Xooloo or as evidence in litigation in which Xooloo is involved.

You have the option to agree to our collecting and using your child's personal information without agreeing to the disclosure of the information to third parties, and your child will be able to use the Xooloo applications even if you do not consent to our disclosing your child’s personal information to third parties.

Your Rights to Review, Delete and Control Our Use of Your Child's Personal Information. As a parent, you have a right to review the information we have collected about your child, to delete it, and to tell us to no longer use your child's personal information. You can review most of the information we collect about your child by logging in to your account and reviewing your account information and updating the information we maintain about your child.

At any time, you may revoke your consent, refuse to allow us to further use or collect your child's personal information, and direct us to delete the information. If you no longer want us to collect and use your child's information, then you may cancel your account and your child's use of the Service. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Parents web interface.

If we change the way we collect, use or disclosure your child's personal information we will send you a new notice and request for another consent.

Parental Consent. Your consent is required for the collection, use and disclosure of your child personal information to use our services as we will passively collect information from your child device.

To give your approval, you are requested to tick the box. If you do not tick the box, you will not be able to create a parent account to use our services provided within the Xooloo’s family pack, so your children will not be able to use our Applications.

You can revoke your consent any time, you may do so by contacting us at info@xooloo.com. In that case we will ask you to uninstall our Applications before we close your account.

If you have questions or suggestions regarding our 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.

Sincerely,

Team Xooloo