CHILDREN'S ONLINE PROTECTION AND PRIVACY ACT NOTICE

Dear Parent,

This notice is provided to you because your child is under 13 years of age and wants to register to use Xooloo Messenger (the “Application” or the “Service »). The Application made available by Xooloo SAS at www.xooloo-messenger.com and related websites, including https://xooloo-messenger.com/parent  (collectively, the “Site”) are referred herein as the "Service". As a result, we need to inform you of the personal information that has been collected from your child and will be collected from your child’s mobile device when using the Service if you decide to provide your consent to the creation of your child’s Xooloo account. 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 child, Xooloo will actively collect personal information from your child to create an account, passively collect personal information from your child’s device as part of the services we offer and actively collect personal information from you as a parent or legal guardian.

We collect limited personal information from children users and have designed our Application 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 your 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 actively collect information from your child for the registration to the Application and passively collect information from your child’s device. We will not collect additional 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 logging in to your parent section (https://xooloo-messenger.com/parent). In certain cases, we may ask you to uninstall our Application before we close your child’s account. For security reason, it is forbidden to provide inaccurate or untrue information.

Information Collected. We collect the following Personal Information from your child in order to contact you and get your approval for your child’s registration and use of the Service: your child’s first name, your child’s birthdate (to confirm your approval is required for your child registration and use of the Service) and your phone number (to obtain the parent’s consent if your child is under 13). If a user is older than 13, after collecting her/his first name and birthdate, we collect her/his mobile number when she/he wants to register to the service.

If your child has accepted to receive notifications from the Service when installing the Application, a push token generated for the use of the Service is collected. It allows for multiple online communications with your child relating to the Service. The push token will not be used for any other purpose or disclosed or combined with any other information collected from the user. Notifications will be used to inform the user in the context of the service only and no information will be revealed, shared or combined with other information regarding the user. If your child no longer wishes to receive notifications, she/he may modify the desired preference within the device settings.

When your child registers for the Service, the Application generates and collects a friend code. The friend code allows your child to invite friends within the Service. A friend code can only be used within the Application. It allows creating a friendship link between two friends. When a child is under 13, communication between two friends will not be possible until a parent’s consent is provided. However, even a child under 13 will be able to invite friends using their friend code, their friend’s phone number or their friend’s email address. Messages to send invitation are prewritten. Your child may receive an invitation from one of her/his friends who also use the Service who have used your child’s email address or mobile number in the past.

Once you have given your consent, if your child allows the Service to have access to her/his contacts list, the user would be able to invite friends using her/his contacts list and would also be able to identify her/his friends who already use the Service. Your child will also have the option to introduce his/her friends to each other’s.

Once one of your child’s friends has accepted your child’s invitation, you will be notified within your parent section and the identity of your child’s friend will be disclosed to you as a parent. Your child last name, that is mandatory for validating your child’s account and that is collected, will only be visible to your child’s friends and their parents. Your child birthdate will only be visible to your child’s contacts.

Once you have given your consent, your child under 13 will be able to create a password so that the Service will remain securely accessible from all chosen devices, your child phone number or friend code will be used to login to the Service. The features of the Service within the profile section of the Application will provide your child the option to enter the name of his/her school, class and telephone number if she/he has one, this information is not mandatory and will be collected only if provided. To help a child under 13 to identify her/her school, after parental consent has been obtained, the child has the option to use the school geolocation feature available within the Service. As a parent or legal guardian, you will also have the ability to add information regarding your child in your parent section. This is not mandatory but if you do so, the information provided will be collected. Your child’s contact information will not be used for any other purpose and will not be given or shared with anyone else.

Users over 13 will also be able to create a password and add information within their profile section of the Application including the name of their school, their class and telephone number. This information is not mandatory and will be collected if provided. For security reason, a user over 13 will be asked to provide her/his last name in the profile section of the service, this information is not mandatory and will be collected if provided.

Your child under 13, after parental consent has been provided, will have the opportunity to receive rewards when they invite friends to the Service and for other activities within the Service. In order to send rewards through postal mail, your child physical address may be collected. Once parental consent is provided, if your child chooses to send photos, videos, and voice recordings, these elements will be collected in the process of being transferred to your child’s contact.

Messages exchanged during conversation are stored for technical reason and not exploited for any reason whatsoever.

The Application also allows your child to give a mark to the Service and lets children send messages to Xooloo support using a form available from the Application. Messages are received by Xooloo support staff who can reply to the child to help resolve the issue raised. This is part of the support we provide to our users even when parent consent has not yet taken place.

For security reasons, a user will have the opportunity to report a contact or an inappropriate message to the Xooloo team. In addition, when possible, each link exchange within a discussion will be analyzed in real time, using our Artificial Intelligence tool before being delivered. Logs may be stored for a period of one year.

In order to improve the quality of the service we provide, we use our own analysis tool and collect and analyze information about the way the Application is used. This information is anonymous and only used for our own purpose. In this context, we collect the pages displayed within the service, the brand and the model of the device, the OS version, the Application version, the date and time of the use and an approximate IP address. In certain circumstances, we may ask your child to answer a survey.

In the process of obtaining your parental consent, we will collect directly from you your mobile phone number in order to confirm your consent. Within your Parent section you may review, and add information related to your child that will be collected. You will also have the option to delete your child’s account. You will be able to access your parent section with your email address or your mobile number and a password. We may use your mobile number to contact you directly.

Registration to the Service and the use of the Application is free. We may add paid value-added services in the future. If you do not provide consent for your child to register to the Service within 14 days of your child’s registration, you and your child’s personal information will be deleted. During this period, you and your child will receive reminders if you haven’t yet provided your consent.

We use this information to administer each user’s account including your child’s account, your parent section and provide our services generally.

Collection of Information by Third Parties. We do not allow third parties to collect personal information from our application. In order to improve our service, we 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 your child’s device: the anonymous identification number of the device, the brand and model of the device, the device language, the orientation of the 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.

Collection of 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 (as defined in the section “Information collected” and excluding information collected passively on your child device when using the Application) will be disclosed to you as part of our Service within the parent section. You will need to log in to view information about your child. 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 or to set up statistics. Aggregate data is not information that could be used to identify you or your child or to contact you or your child.

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 Service even if you do not consent to our disclosing your child’s personal information to third parties as we will not share your child’s personal information with any 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 (as defined in the section “Information collected” and excluding information collected passively on your child device when using the Application) we collect about your child by logging in to your parent section 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 child’s account and your child will no longer be able to use the Service. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of your parent section.

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

Parent’s Consent. Your consent is required for the collection, use and disclosure of your child’s personal information to use the Service, as we will actively collect information from your child and passively collect information from your child device.

To give your approval, you are required to tick the box below. If you do not tick this box, your child will not be able to create an account and use the Application.

You can revoke your consent at any time, by logging in to your parent section and changing your preference. In that case we will ask you to uninstall our Application before we close your child’s 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