Privacy Policy and Personal Data protection with Edoki Academy

Last modified: October 4th, 2021

Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification

Edoki Academy is a member of the PRIVO Kids Privacy Assured COPPA Safe Harbor Certification Program (“the Program”). The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online. The PRIVO COPPA certification Seal posted on this page indicates Edoki Academy has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at +33(0)661573792 or [email protected]. If you have further concerns after you have contacted us, you can contact PRIVO directly at [email protected].

This document explains the principles of and our commitments to the protection of your Personal Data. It aims to inform you about:

• The Personal Data that EDOKI ACADEMY collects and the reasons for this collection,
• How your Personal Data is used, and
• Your rights as a person concerned by our data processing practices.

This Policy applies to all EDOKI ACADEMY services regardless of their nature (website, applications, services...)

The Data Controller

EDOKI ACADEMY is responsible for processing your Personal Data. Its contact details are:

• Address: 18 rue Barbès 92120 Montrouge (France).
• Telephone +33 (0)6 61 57 37 92
• Email: [email protected]

How EDOKI ACADEMY protects Personal Data

EDOKI ACADEMY takes the protection of your Personal Data and your privacy into account when designing its services (Privacy by design). To ensure the security of this data and respect of your rights, EDOKI ACADEMY implements measures to protect your Personal Data (Privacy by default).

What Personal Data does EDOKI ACADEMY use?

EDOKI ACADEMY only collects the data necessary to operate our services.

In the case where optional data is requested, EDOKI ACADEMY will clearly inform you about the Personal Data required to perform the service.

Personal Data is used to provide you with other services, only if you have agreed to receive commercial communications.

We encourage parents to use the parent dashboard in the apps and that children play with parental supervision.

We collect the following personal information:

• For each parental account: an email address, and a password. All parent accounts are transferable across our apps i.e.you can use the same login credentials in all the apps and on the website. In Edoki Sight Words Adventure, parents can record a word for the child to learn. These recordings and your child’s drawings are saved to our servers so that they may be accessed wherever you log in.
• For each teacher account: an email address, first and last name, phone number, district name, school name, school country, city and post code/zip code. For each child (optionally): a first name, a nickname, or any string of characters that the user chooses to identify the child with. We also collect the following non-personal information: the devices used to play, your country and language chosen the first time the app was opened.
• We also collect the following non-personal information: For each use of an application: the information related to the use.

Like most websites, we also automatically collect information about your computer such as the IP address, browser type, operating system and pages visited.

We use this information to:

• Improve the mechanics of our games and adapt the interface to the user’s needs,
• Track the user’s progress,
• Conduct research and analysis on our own behalf,
• Answer questions and concerns, and
• View content based on your use of the service (for example, progress).
• To send you information and offers on our services, via our partners.

Social networks

We allow parents to create a profile and share information such as messages, photos and videos with others. We cannot control the actions of others with whom you decide to share your pages and information. We also cannot guarantee that the content you post from our site will not be seen by anyone outside your network.

What is the basis for the legitimacy of our treatment of your Personal Data?

EDOKI ACADEMY relies on the following legitimate bases to process personal data:

Execution of contract

The legal basis for the processing and collection of the user’s Personal Data is the execution of the contract of sale. In this respect, the user is obliged to provide the data necessary for the sale’s execution. If they do not provide this data to the online payment provider, it will not be possible to make the sale.

Consent

The legal basis for processing the user's Personal Data is their consent. In the event that they have given it, EDOKI ACADEMY reserves the right to use it for the following purposes:

• Managing the subscription on the website and to the applications.
• Managing the sending of information about exclusive promotions, the latest news and personalized information tailored to the user’s profile.
• Answer to the user’s request to exercise their rights to access, modify, cancel or oppose, as well as address any questions or claims.
• Managing the availability alert service for new applications.
• Managing and issuing of documents certifying the sale, such as a digital ticket.

The withdrawal of consent to these treatments by the user will not condition the execution of the contract of sale concluded by the person concerned with EDOKI ACADEMY.

Personal data of minors

Our services are intended to be used by minors only with the consent and under the control of their parents or legal representatives.

Who can your Personal Data be sent to?

Your data may be transmitted:

• To our internal departments which are in charge of the execution of the subscribed services, in particular Customer Service and Sales Administration.
• To external providers who provide us with services for the operation of our services, mainly technical service providers, including subcontractors.
• if Edoki Academy is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information
• Our partners to send you information and announcements related to our services.

Can your Personal Data be transferred outside the European Union?

Edoki Academy stores your data on servers located in the United States that are managed by MongoDB Atlas. MongoDB Atlas participates in the EU-US Data Protection Shield in accordance with the decision made by the European Commission on July 12, 2016 concerning the collection, use, and retention of personal data from EU Member States, and also signed contractual clauses approved by the European Commission for the transfer of personal data outside the EU.

However, for certain specific services, EDOKI ACADEMY may use subcontractors established outside the EU. Certain Personal Data can then be communicated to them for the strict needs of their missions. In accordance with the regulations reinforced by the EU, EDOKI ACADEMY requires its subcontractors to provide the guarantees necessary to supervise and secure these transfers, in particular by signing the European Commission’s standard contractual clauses.

How long does EDOKI ACADEMY keep your Personal Data?

How long we keep your Personal Data depends on the service you have subscribed to. EDOKI ACADEMY does not keep your Personal Data beyond the time necessary to provide our services. It does, therefore, use your Personal data while you use the service and during the retention period imposed by the applicable rules on legal provision.

We will retain your personal information as long as your account is active. If you wish to cancel your account, or ask us to stop using your information to provide you with our services, please contact us at [email protected].

Is your Personal Data protected?

EDOKI ACADEMY takes all measures necessary to ensure the security and confidentiality of your Personal Data and, in particular, to prevent it from being damaged, erased or shared with unauthorized third parties.

The security of your personal information is important to us, so we encrypt the transmission of such information using Secure Socket Layer (SSL) technology.

We follow generally accepted industry standards to protect the personal information that has been provided to us. However no method of transmission or electronic storage is 100% reliable. We cannot guarantee absolute security.

If you have questions about security on our website, contact us: [email protected]

Moreover, in the event of a Personal Data Violation affecting your Personal Data (destruction, loss, alteration or disclosure), EDOKI ACADEMY will respect our obligation to notify you of such violations, in accordance with the CNIL (registration number 1627782).

What are your rights with regard to your Personal Data?

You have the right to exercise the rights provided by the regulations applicable to Personal Data at any time, provided that you meet certain conditions:

• Right of access: you can a copy of your Personal Data subject to treatment by EDOKI ACADEMY. To do so, login to the website montessori.edokiacademy.com/en/login/ with your email and password> montessori.edokiacademy.com/en/account/ "Personal Data" section
• You can "download" your Personal Data
• You can "delete" your Personal Data
• Right of rectification: you can update your Personal Data or have your Personal Data processed by EDOKI ACADEMY;
• Right of opposition, in particular to receive commercial communications: you can express your wish to no longer receive commercial communications from EDOKI ACADEMY or request that your Personal Data no longer be subject to processing;
• Right to erasure: you can request the deletion of your Personal Data;
• Right to limitation: you can request the suspension of the processing of your Personal Data;
• Right to portability: you can ask EDOKI ACADEMY to recover your Personal Data in order to dispose of it.

When subscribing to a service or providing your Personal Data, you are given the address (postal and / or electronic) to which to send your request to exercise your rights.

All requests must be accompanied by a proof of identity. EDOKI ACADEMY will respond to your request to exercise your rights as soon as possible and, if applicable, in compliance with legal deadlines.

To request the deletion of your Personal Data from our blog or forum, contact us at: [email protected]. In some circumstances, we may not be able to delete your personal information. We will let you know if this is the case.

Changes to the Privacy Policy and Protection of Personal Data

We may update this privacy statement to reflect changes in our information handling practices. If we make any material changes, we will notify you by email (at the email address provided in your account) or by notice on this site, before the change becomes effective. We encourage you to check this page regularly for the latest information on our privacy policies.

POLICY ON COOKIES

The EDOKI ACADEMY website and all its web pages use cookies to distinguish you from other users of the site. This allows us to improve services and optimize your user experience.

A cookie is a string of text information transferred from a website to your computer's hard drive so that the website can remember you. Cookies can help a website adapt content more quickly to your interests. Most importantly websites use cookies. In general, a cookie contains the name of the domain of origin of the cookie; the "lifetime" of the cookie and a value, namely a unique number created randomly.

There are two types of cookies on the EDOKI ACADEMY website:

• Temporary cookies, which remain in your browser's cookie file until you leave the site, and
• Persistent cookies, which stay in your browser’s cookie file for much longer (the duration depends on the lifetime of the cookie in question).

Temporary cookies are used:

• To allow you to transfer information from one page of our site to another without having to enter it again, and
• To allow you to access saved registration information.

Persistent cookies are used:

• To help us identify you as a visitor (using a number, not personally) when you return to our website;
• To allow us to tailor content or ads to your interests, or to avoid showing you the same ads multiple times; and
• To compile anonymous global statistics that allow us to understand how visitors use our site and to help us improve the structure of our website. We cannot personally identify you this way.

You have the option to accept or decline cookies by changing your browser settings. However, you may lose some interactive features of the service, if cookies are disabled.

You will find a list of the main cookies we use and their functions below.

You can delete and block all cookies from the EDOKI ACADEMY site. To do this, adjust the settings on your browser to refuse some or all cookies. Please note that if you decide to block cookies, some elements of our website may not work properly.

Third Party Service Providers

We use analytics tools, like Google Analytics and Appsflyer, on the EDOKI ACADEMY apps. These tools are used to compile anonymous global statistics that allow us to understand how our customers use our applications and to help us improve them. This data does not identify you personally.

In our Montessori Preschool app we use Countly as an analytics provider to help monitor performance and your usage of the app. Countly uses anonymous data and does not share any data collected about you. For more information on Countly, please see their privacy policy: https://count.ly/legal/privacy-policy. We use Unity in our Montessori Preschool and Sight Words apps. Unity is a game engine. This third party is restricted from sharing your user data. For more information on Unity, please visit the privacy policy https://unity3d.com/fr/legal/privacy-policy . We use the following third party service providers in relation to adults and parents on our website:•Facebook•DoubleClick•Google Analytics•Stripe.For more information related to our privacy practices in relation to children, or if you have any questions related to the third party service providers listed above, please contact us at [email protected].

DEFINITIONS

Each term beginning with a capital letter has the meaning given to it below:

• "Privacy Policy and Privacy Policy" and "Policy" means this Policy describing the measures taken for the processing, operation and management of your Personal Data and your rights as a data subject.
• "Personal Data": Refers to any information relating to you that identifies you directly or indirectly.
• "Processing": Refers to any transaction or set of transactions applied to your Personal Data.
• “Data Controller”: Designates EDOKI ACADEMY, who processes your Personal Data.
• "Personal Data Violation" means a breach of security that inadvertently or unlawfully causes the destruction, loss, alteration, disclosure or unauthorized access to your Personal Data.
• "Recipient": Refers to the service or company that receives the communication and can access your Personal Data.