DIRECT NOTICE TO PARENTS

Dear Parent,

This notice is provided to you because your child has been identified as under 13 years of age and wants to register to use the Xooloo Messenger mobile application made available by Xooloo SAS (“Xooloo,” “we,” “us,” or “our”) and related websites, including www.xooloo-messenger.com and www.xooloo-messenger.com/parent, (collectively referred to as the “Service”). As part of the Service, we will collect, use and disclose personal information we collect from you and your child, their mobile device and your mobile device if you have created an account as a parent or legal guardian.

We require parents to provide their consent to our data practices as they relate the collection, use and disclosure of your child’s personal information, as further described in the notice below. We will not collect, use, or disclose any personal information from your child if you do not provide such consent. To learn more, please review our Children’s Privacy Policy and our Privacy Policy.

If you have any questions about this notice, the Privacy Policy, or the Children’s Privacy Policy, you may contact us by e-mail at dpo@xooloo.com or by postal mail at Xooloo SAS, 20 rue Danielle Casanova, 75002 Paris, France.

Information We Collect from Your Child

  • • Your Child’s Account Information Before Parental Consent.
    During initial registration, your child provided us with their first name, date of birth, selected animated avatar, and their parent or legal guardian’s phone number for us to obtain parental consent and provide the child access to their limited account on the Service. Your child was also asked to opt-in to receive push notifications from the Service. We do this to send limited notifications to your child about their access to the Service before we obtain parental consent, such as reminders to request consent. The push token will not be used for any other purpose or disclosed or combined with any other information collected from the child. If your child no longer wishes to receive notifications, she/he may modify the desired preference within the device settings.

  • • Your Child’s Account Information During and After Parental Consent. During the parent validation process, we collect from parents or legal guardians the following information: your child’s last name; and parent or legal guardian role (mother, father, other), first and last name, and email address. After such validation has been successfully completed, we may also collect any additional information from or about your child that they or their parent or legal guardian may provide, such as phone number, contact list (discussed below), school/class name, grade and school address, mailing address to receive goods, and wishlist items. We use this information to provide the Service to your child, to provide parents or legal guardians with appropriate controls for your child’s use of the Service, to communicate with parents or legal guardians about their child’s account and activities, such as account alerts and your child’s wishlist, and for other purposes as described below.

  • • Information Collected Through Use of the Service. As part of the Service, we collect the following types of information about your child’s use of the Service:

    • • We collect any content and communications that your child shares or receives through the Service, including contacts (as described below), wishlist items, and the text and content of any messages with contacts or our automated chatbot, including text, audio recordings, photos, videos, links, and communications’ metadata (e.g., IP address, date and time stamps).

    • • We collect information about your child’s activities and engagement with the Service, such as games/activities played, tools and features they use, including the time, frequency, and duration of activities on the Service. We may also collect additional information when accounts or messages are reported to Xooloo.

    • • We collect information from your child if they contact Xooloo Support or fill out a survey/contact form on the Service.

  • • Information about Friends/Contacts & Device Contacts. We collect information from your child about their friends and contacts through the Service, such as their first and last name, selected avatar (Xavatar), Xooloo ID, phone number, email address, duration of Xooloo membership, date of birth, and other information your child may provide. We also collect metadata and other information about how they interact, such as friendship duration, account creation date, who invites whom, the feature used to invite (e.g., contact page, suggestion from Xooloo or from parent), and friendship status (e.g., blocked).

    With their permission, we also collect your child’s or parent or legal guardian’s device contacts, so they may invite friends and contacts to the Service. You may control the Services’ access to your device information at any time through the “Settings” (or similar) application on your mobile device. Your child can invite friends to the Service using a friend’s Xooloo ID, mobile phone number, or email address and can view friends who belong to the same group or school as them, or friends who are already Xooloo users or not when they share their device contacts. Xooloo can also suggest contacts to invite based upon child device contact list when shared, child phone number when provided by the child, and parents contact lists when shared.

    We may inform parents or legal guardians who have a Xooloo account and have shared their contact list if another parent who belongs to their contact list has a Xooloo account and a child registered on Xooloo (we will not disclose the name of the child). Parents or legal guardians can also select contacts from their device contact list to invite to the Service or to suggest the Child User to invite. In addition, Xooloo may suggest to parents or guardians who have shared their contact list potential contacts that the parent or guardian may wish to suggest to your child. Parents or legal guardians may control the Services’ access to their device information through the “Settings” (or similar) application on their device.

  • • Location Information. When you search for a school on the Service, we may collect geolocation data such as latitude and longitude via mobile device sensors. We collect this type of data if you grant us access to your location through your device. You can remove our access at any time through your mobile device settings. We may also derive your approximate location from your IP address.

  • • Device Information. We automatically collect usage information as well as information about the device and network used to access the Service. For example, we may collect an IP address or a partial IP address, location when shared, browser type, language preferences, VOIP token, device name, OS Version, screen resolution, time zone, device local, build model and build manufacturer, device messaging availability, available camera, device authentication token, random install ID, IP address, crash report and other information about the device used to access the Service, such as the device type, model and manufacturer. We also collect usage information such as the day/time stamp, pages viewed, and similar information. This information may be typically collected through cookies or mobile SDKS or similar technologies. We use this information to operate, maintain and provide the features and functionality of the Service, and to develop and improve our Service.

    • Disclosure of Your Child’s Information

    We may disclose your child's personal information to third-parties in the following instances:

    • • With contacts with whom your child chooses to communicate on the Service and their parents or legal guardians. Your child’s first and last name, animated avatar (Xavatar), Xooloo ID, date of birth, date of account creation, membership duration, school/class name, grade, games/activities ranking are visible to and shared by default with your child’s approved contacts on the Service. Your child’s approved contacts on the Service also see any content the Child User shares with them (e.g., via messages/chat). This includes audio, photos, videos, links, wishlist items, status, and any content shared or visible during the communication. The following information is shared with/visible to parents or legal guardians of your child’s approved contacts: first and last name, animated avatar (Xavatar), age, parent or legal guardian first and last name.

    • • With other Xooloo users (in limited instances). When your child provides Xooloo access to their device contacts, your child may see who among their device contacts list are Xooloo users (in order to invite them as an approved contact). In this case, Xooloo will only share whether or not your child’s contact is a Xooloo user. Further, certain of your child’s information (first and last name, animated avatar (Xavatar), age and date of birth) may be visible to the parents or legal guardians for non-approved contacts in groups chats to which they belong.

    • • With your child’s parents or legal guardians. We share your child’s information and activities (such as contacts list, wishlists, and profile information) with the parent account associated with your child. Parents are informed by email of your child’s new contacts once an invitation sent by your child or received by your child has been accepted. Parents or legal guardians are also informed of people who belong to the same group chat of your child but are not approved contacts of your child. We inform parents that have shared their contact list if a parent in their contact list has a Xooloo account or has a child registered on Xooloo.

    We may also share your child’s personal information if we have a good faith belief that access to or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, judicial proceeding, or enforceable governmental request; (b) enforce applicable Terms of Use, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; (d) protect the rights, property, or personal safety of Xooloo, its users, or the public; or (e) as required or permitted by law. If Xooloo is involved in a merger, acquisition, bankruptcy, change of control, or any form of sale of some or all of its assets. In this case, personal information may be transferred or disclosed in connection with the business transaction, subject to any applicable laws.

    We may also use and share de-identified information in a manner that cannot be reasonably used to identify an individual. For more information on our data practices, please review our Children’s Privacy Policy.

    Request for Your Parental Consent

    For your child to complete account registration and use the Service, we require that you review the statements below, provide your consent, and verify your identity (as discussed on the next page) in compliance with applicable law. If you do not provide your verifiable parental consent within a reasonable time frame in our discretion, we will delete your and your child’s personal information from our records. If you or your child did not sign up for the Service, or if you do not consent our collection and processing of this information, please contact us at dpo@xooloo.com.