Skoul Cookie Policy

Last Updated: November 7, 2025

Introduction

This Cookie Policy explains how HIGHTHEM ("we," "us," or "our") uses cookies and similar tracking technologies in the Skoul mobile application ("App"). This policy is designed to help you understand what these technologies are, why we use them, and your choices regarding their use.

Company Information:
HIGHTHEM
SIREN: 848274338
France

Contact: privacy@skoul.fr

Important Note: Skoul is a Native iOS App

Skoul does not use traditional web cookies because it is a native iOS mobile application, not a web-based service. However, this policy explains similar tracking technologies and data collection mechanisms that may be used within the app or by third-party services integrated into the app.

What Are Cookies and Similar Technologies?

Traditional Web Cookies

Cookies are small text files that websites store on your browser to remember information about you. Skoul does not use web cookies because it is not a website or web app.

Mobile Tracking Technologies

Instead of cookies, mobile apps like Skoul may use:

Local Storage (SwiftData/UserDefaults):
- Stores app preferences and user data locally on your device
- Not transmitted to servers
- Used for app functionality only
Device Identifiers:
- IDFV (Identifier for Vendor): A unique ID assigned by iOS to apps from the same developer on your device
- NOT IDFA (Identifier for Advertisers): We do not collect IDFA for tracking across apps
SDKs (Software Development Kits):
- Third-party code libraries integrated into the app
- May collect limited data (e.g., Google AdMob for advertising)
Session Storage:
- Temporary data stored while the app is running
- Cleared when you close the app

Technologies We Use

1. Essential Local Storage (Always Active)

Purpose: These are necessary for the app to function properly. They cannot be disabled.

What We Store Locally:

User Profile:
- First name
- Age (6-12)
- Grade level
- Country
- Optional avatar photo
Practice Session Data:
- Session history
- Scores and accuracy
- Time spent on activities
- Difficulty progression
App Settings:
- Sound preferences
- Notification preferences
- Theme settings (if applicable)

Storage Method: SwiftData (iOS persistent storage)
Location: Your iOS device only
Transmission: NEVER transmitted to servers
Deletion: Removed when you uninstall the app
Control: Cannot be disabled (required for app functionality)

2. Analytics and Advertising Technologies (Third-Party)

Google AdMob SDK:

Purpose: Display age-appropriate advertisements to support the free availability of Skoul

What AdMob May Collect:

Device identifiers (IDFV, not IDFA)
Ad interaction data (views, clicks)
Device type and OS version
App version
General location (country-level, derived from IP address)
Ad performance metrics

What AdMob Does NOT Receive from Skoul:

Child's first name
Child's age
Practice session data or scores
Avatar photo
Any personally identifiable information (PII)

Storage Method: AdMob SDK internal storage
Location: Your device and Google servers (United States)
Purpose: Serve contextual (not behavioral) ads
Privacy Policy: https://policies.google.com/privacy
Control: Limit ad tracking in iOS Settings > Privacy & Security > Tracking

Important for Parents:

We do NOT show behavioral advertising to children
Ads are contextual only (based on app content, not user behavior)
You can limit ad tracking through iOS settings
AdMob is subject to Google's privacy policies, not controlled by Skoul

Technologies We Do NOT Use

To protect children's privacy, Skoul does NOT use:

❌ Third-Party Analytics Cookies: No Firebase Analytics, Mixpanel, Amplitude, etc.
❌ Social Media Trackers: No Facebook Pixel, Twitter, Instagram, TikTok tracking
❌ Cross-App Tracking: No IDFA or advertising identifiers for tracking across apps
❌ Behavioral Targeting: No user profiling or behavioral advertising to children
❌ Web Cookies: Not applicable (native app, not web-based)
❌ Third-Party Marketing Pixels: No pixels or beacons from marketing platforms
❌ Session Replay Tools: No recording of user interactions
❌ Heatmaps or Click Tracking: No detailed interaction tracking
❌ Affiliate Tracking: No affiliate cookies or referral tracking
❌ Retargeting Pixels: No retargeting or remarketing technologies

Data Sent to External Services (Not Cookies, But Similar Effect)

While Skoul doesn't use cookies, we do send limited data to external services for specific purposes:

Exercise Generation Requests

HIGHTHEM Backend API (Primary - France):

Data Sent: Age, grade level, country code, exercise difficulty, subject, question count
Purpose: Generate educational exercises
Frequency: Only when user requests new exercises
Storage: Not stored on backend; requests processed and discarded
Identifier: No persistent user identifier sent

Google Firebase AI - Gemini (Secondary - USA):

Data Sent: Age, grade level, country code, language, exercise difficulty, subject, question count
Purpose: Fallback exercise generation
Frequency: Only when backend unavailable
Storage: Subject to Google's Gemini API Terms
Privacy: https://firebase.google.com/support/privacy

Apple Intelligence (Tertiary - On-Device):

Data Sent: None (all processing on-device)
Purpose: Text recognition and exercise generation
Privacy: Complete on-device processing

Important: No personally identifiable information (name, avatar, practice history) is ever transmitted to any external service.

COPPA and GDPR Compliance

COPPA (Children Under 13 - United States)

Compliance Measures:

No persistent identifiers used for behavioral advertising
No third-party tracking of children across websites or apps
Parental consent obtained before any data collection
AdMob serves contextual ads only (not behavioral)
Parents can limit ad tracking in iOS settings

GDPR (European Union)

Compliance Measures:

No cookies requiring consent (native app, not web-based)
Local-first data storage (no server-side cookies)
Parental consent for children under applicable age thresholds (13-16)
Right to access, rectify, and delete data
Transparency about third-party data collection (AdMob)

Cookie Consent Banner: Not required for Skoul because:

We're a native iOS app (not a website)
We don't use web cookies
Essential local storage is necessary for app functionality
Third-party advertising (AdMob) is disclosed in Privacy Policy and consent flow

Your Choices and Controls

Managing Local Storage

View Data:

Go to Settings > Profile to view stored information

Edit Data:

Settings > Profile > Edit Profile to update information

Delete Practice Data:

Settings > Learning Data > Clear All Practice Data
Removes session history, scores, and progress
Preserves profile information

Delete All Data:

Uninstall the app from your device
Permanently removes all local storage immediately
Cannot be recovered

Managing Third-Party Tracking (AdMob)

Limit Ad Tracking (iOS):

Open iOS Settings
Go to Privacy & Security > Tracking
Toggle off "Allow Apps to Request to Track"
Alternatively, deny tracking when Skoul requests permission

Effect of Limiting Tracking:

Ads will still be shown (app remains free)
Ads become less relevant (still age-appropriate)
AdMob cannot use your data for personalized ads
Does not affect core app functionality

Request Account Deletion (Google):

AdMob data is controlled by Google
To delete AdMob data: https://myaccount.google.com/data-and-privacy
Note: This affects all Google services, not just Skoul

Children's Privacy Protection

Special Protections for Children:

No Behavioral Profiling:
- We never build behavioral profiles of children
- No tracking of interests or habits for advertising
No Cross-App Tracking:
- We don't track children across other apps or websites
- No IDFA collection
Minimal Data Collection:
- Only necessary data for app functionality
- No email, phone, or precise location
Local-First Architecture:
- Personal data stays on device
- No cloud synchronization of private information
Parental Consent:
- Required for children under applicable age thresholds
- Clear disclosure of all data practices
Easy Deletion:
- Uninstall to permanently remove all data
- No retention on servers

Third-Party Privacy Policies

Since Skoul integrates third-party services, we encourage you to review their privacy policies:

Google AdMob:

Privacy Policy: https://policies.google.com/privacy
Ad Settings: https://adssettings.google.com
Opt-Out: Limit tracking in iOS Settings > Privacy & Security > Tracking

Google Firebase AI (Gemini):

Privacy Policy: https://firebase.google.com/support/privacy
Gemini API Terms: https://ai.google.dev/gemini-api/terms

Apple Intelligence:

Privacy Policy: https://www.apple.com/legal/privacy/
On-device processing (no data sent to Apple servers)

Note: We do not control these third parties' practices. Their data collection is governed by their own policies.

Updates to This Policy

We may update this Cookie Policy from time to time to reflect:

Changes in tracking technologies
New features or services
Changes in applicable laws
Updates to third-party integrations

How We Notify You:

The "Last Updated" date at the top will change
Material changes will be communicated through the app
Continued use after changes constitutes acceptance

Reviewing Changes:

Access current policy: Settings > Cookie Policy (if implemented)
Contact us for clarification: privacy@skoul.fr

Contact Us

If you have questions or concerns about this Cookie Policy or our use of tracking technologies:

Email: privacy@skoul.fr

Data Controller:
HIGHTHEM
SIREN: 848274338
France

Response Time: We will respond to legitimate inquiries within 30 days.

Regulatory Authorities:

France: Commission Nationale de l'Informatique et des Libertés (CNIL) - https://www.cnil.fr
EU: Your national data protection authority
US (COPPA): Federal Trade Commission - https://www.ftc.gov

Summary

Quick Reference:

✅ No traditional web cookies (native iOS app)
✅ Local storage only for personal data (stays on your device)
✅ Essential storage cannot be disabled (required for app functionality)
✅ Limited third-party tracking (Google AdMob for ads only)
✅ No behavioral advertising to children (contextual ads only)
✅ No cross-app tracking (no IDFA collection)
✅ Parental controls available (limit ad tracking in iOS Settings)
✅ COPPA and GDPR compliant (child-specific protections)
✅ Easy data deletion (uninstall app to remove all data)
✅ Transparent practices (clear disclosure of all data collection)

For Parents:

All personal data (name, avatar, practice history) stays on your device
Only non-personal data (age, grade, country, difficulty) sent for exercise generation
AdMob serves age-appropriate ads but doesn't receive your child's personal information
You can limit ad tracking in iOS Settings > Privacy & Security > Tracking
Uninstalling Skoul permanently deletes all local data

Version History

Version 1.0 - November 7, 2025 - Initial publication

HIGHTHEM is committed to protecting children's privacy and maintaining transparency about data collection practices. We use minimal tracking technologies and prioritize local-first data storage to keep your child's information secure.