Skoul Privacy Policy

Last Updated: November 7, 2025

Introduction

Welcome to Skoul, an educational app designed specifically for children aged 6-12. This privacy policy explains how we collect, use, store, and protect your child's information.

Your child's privacy and safety are our top priorities. Skoul is designed to comply with:

Children's Online Privacy Protection Act (COPPA) in the United States
General Data Protection Regulation (GDPR) in France and the European Union
Best practices for children's privacy and data protection

We believe in transparency and minimal data collection. This policy will help you understand:

What information we collect and why
How we use and protect that information
Your rights and how to exercise them
How to contact us with questions or concerns

By using Skoul, you agree to the practices described in this privacy policy.

Data Controller

The data controller responsible for your personal information is:

HIGHTHEM
SIREN: 848274338
France

For all privacy-related inquiries, please contact us at:
Email: privacy@skoul.fr

Information We Collect

Skoul collects minimal personal information necessary to provide a personalized learning experience:

Profile Information

First name: Used to personalize the app experience and greet the child
Age (6-12 years): Used to provide age-appropriate educational content
Grade/Class: Used to align exercises with the child's educational level
Country: Used to determine applicable privacy laws and educational standards
Avatar photo (optional): Used for profile personalization, stored locally only

Practice Data (Stored Locally Only)

Exercise completion records
Accuracy scores and performance metrics
Time spent on activities
Difficulty progression
Session history

Technical Information

Device type (iPad, iPhone) for UI optimization
App version for support and debugging
Settings preferences (sound, notifications)

Information We Do NOT Collect

Email addresses
Phone numbers
Precise location data
Payment information (Skoul is free)
Social media profiles
Biometric data
Contacts or photos (except avatar, with permission)
Browsing history outside the app

All data collection is transparent and limited to what is necessary for the app to function.

How We Use Your Information

We use the collected information solely to provide and improve the Skoul educational experience:

Personalization (LOCAL ONLY)

Display the child's name in greetings and progress screens
Show the selected avatar throughout the app
Customize difficulty levels based on age and grade
All personalization data stored locally on device

Educational Content Generation

WHAT IS SENT: Age, grade level, country code, difficulty preference, subject, and question count are sent to our backend API or Firebase AI (Gemini) for exercise generation
WHAT IS NOT SENT: Child's name, avatar, and practice history remain on your device and are NEVER transmitted
Apple Intelligence (on supported devices) processes everything on-device with no data transmission
Generated exercises are received and stored locally only

Progress Tracking (LOCAL ONLY)

Record session completion, scores, and time spent
Calculate accuracy and improvement trends
Adapt difficulty based on performance
All progress data stored locally on device

App Functionality

Save user preferences (sound settings, notification preferences)
Determine applicable privacy requirements based on country
Optimize UI based on device type

Purposes We Do NOT Use Data For

Selling or sharing with third parties for marketing
Creating user profiles for advertising
Tracking across other apps or websites
Social media integration
Third-party analytics beyond AdMob advertising

Data Storage

Skoul prioritizes your privacy by storing all personal information and practice data locally on your device:

Local Storage

All profile information is stored only on your iOS device using SwiftData
Practice session data, scores, and progress are stored locally
Avatar photos are stored locally as compressed JPEG files
No user data is transmitted to or stored on external servers
No cloud synchronization or backup of personal data
No user accounts or login system

Data Encryption

All locally stored data is protected by iOS device encryption (AES-256)
Data is encrypted at rest when your device is locked
If you have a device passcode or biometric lock, your data is further protected

What This Means

Your child's information stays on your device
Uninstalling the app permanently removes all data
We cannot recover data if you delete the app or lose your device
Each device is independent; data does not sync across devices

Data Isolation

Skoul's data container is isolated from other apps
Only Skoul can access its stored data
iOS sandboxing protects against unauthorized access

Third-Party Services

Skoul uses select third-party services to provide educational functionality and support app development. We carefully vet all third parties for privacy and security practices.

IMPORTANT: All user data is stored LOCALLY on your device. The only data sent to external services for exercise generation is: age, grade level, country, and difficulty preferences. NO nominative data (name, avatar, practice history) is ever transmitted.

Backend API (Primary Exercise Generation)

Purpose: Generate mathematics, spelling, and reading exercises using our secure backend service
Data Shared: Age, grade level, country code, exercise difficulty, subject, and question count
Data NOT Shared: Child's name, avatar, or practice history
Privacy: Secure HTTPS with certificate pinning and API key authentication
Location: France (HIGHTHEM servers)
Note: Generated exercises are received and stored locally on your device only

Google Firebase AI - Gemini (Secondary Exercise Generation)

Purpose: Backup AI service for generating exercises when backend is unavailable
Data Shared: Age, grade level, country code, language, exercise difficulty, subject, and question count
Data NOT Shared: Child's name, avatar, or practice history
Privacy Policy: https://firebase.google.com/support/privacy
Location: United States (Google Cloud servers)
Note: Only used as fallback; generated exercises stored locally only
Gemini API Terms: https://ai.google.dev/gemini-api/terms

Apple Intelligence (Tertiary On-Device AI)

Purpose: On-device text recognition and exercise generation when available
Data Shared: None (all processing occurs on-device)
Privacy: Complete on-device processing; no data leaves your device
Availability: Supported devices only (iPhone 15 Pro, iPad with M1 or later)

Google AdMob (Advertising)

Purpose: Display age-appropriate advertisements to support free app availability
Data Collected: Device identifiers, ad interaction, limited usage data
Data NOT Shared: Child's name, age, practice data, or any personal information
Privacy Policy: https://policies.google.com/privacy
Location: United States
Control: You can limit ad tracking in iOS Settings > Privacy > Tracking
Note: We do not show behavioral advertising to children; ads are contextual only

No Other Third Parties

We do not use analytics services
We do not use crash reporting services that collect personal data
We do not integrate social media platforms
We do not sell or share data with data brokers

Parental Controls

You can manage some third-party data collection through iOS settings, though this may affect app functionality.

International Data Transfers

Data Storage Location: All personal information and practice data is stored locally on your device and never leaves your device except as described below.

Third-Party Service Transfers

HIGHTHEM Backend API (France - Primary):

When generating educational exercises, we send exercise generation parameters to our backend
Information sent: Age, grade level, country code, difficulty, subject, question count
Information NOT sent: Child's name, avatar, or practice history
Our servers are located in France and comply with GDPR
Exercise content generated is received and stored locally only

Google Firebase AI - Gemini (United States - Secondary Fallback):

Used only when backend is unavailable
Information sent: Age, grade level, country code, language, difficulty, subject, question count
Information NOT sent: Child's name, avatar, or practice history
Google Firebase servers are located in the United States
Google provides adequate data protection under EU-US Data Privacy Framework
Privacy Policy: https://firebase.google.com/support/privacy
Exercise content generated is received and stored locally only

Apple Intelligence (On-Device - No Transfer):

On-device processing only (no data transfer)
Used for text recognition and exercise generation
All processing occurs on your device
Available on supported devices only

Google AdMob (United States):

Ad serving may involve data transfer to Google servers in the United States
See Google's privacy policy for details: https://policies.google.com/privacy
You can limit ad tracking through iOS settings

Legal Basis for Transfers

Necessary for providing the educational service you requested
Based on parental consent obtained during onboarding
Standard contractual clauses with service providers

Your Rights

For EU/French residents, you have the right to object to international transfers. However, this may limit app functionality. Contact us at privacy@skoul.fr for more information.

Children's Privacy (COPPA Compliance)

Skoul is designed specifically for children aged 6-12 and complies with the Children's Online Privacy Protection Act (COPPA) in the United States and the General Data Protection Regulation (GDPR) in France and the European Union.

We obtain parental consent during onboarding before collecting any personal information from children under the applicable age thresholds (13 in the US, 15 in France).

We collect only the minimum information necessary to provide the educational service:

First name (for personalization)
Age (to provide age-appropriate content)
Grade level (for educational alignment)
Country (for compliance requirements)
Optional avatar photo (stored locally)

We DO NOT:

Collect email addresses, phone numbers, or precise location data
Share children's personal information with third parties for marketing purposes
Use children's information for behavioral advertising
Allow children to publicly share personal information

Parents have the right to:

Review the information we have collected
Request deletion of their child's information
Refuse to allow further collection of information

For privacy-related questions or to exercise these rights, contact us at privacy@skoul.fr.

Your Rights (GDPR Compliance)

Under the General Data Protection Regulation (GDPR) and applicable privacy laws, you have the following rights regarding your child's personal information:

Right of Access

You can request a copy of all personal information we have stored
Since all data is stored locally on your device, you already have direct access
You can view profile information in Settings > Profile
Contact us at privacy@skoul.fr for assistance

Right to Rectification

You can correct inaccurate or incomplete information
Edit profile information directly in Settings > Profile > Edit Profile
Changes are applied immediately and stored locally

Right to Erasure ("Right to be Forgotten")

You can request deletion of all personal information
Delete practice data: Settings > Learning Data > Clear All Practice Data
Delete all data: Uninstall the app from your device
Since data is local-only, uninstallation permanently removes all information

Right to Data Portability

You have the right to receive your data in a structured, commonly used format
Since there is no cloud storage, data is already portable on your device
You can export or backup data through iOS device backup mechanisms
Contact us for assistance with data export formats

Right to Object

You can object to certain data processing activities
You can disable optional features (avatar, notifications)
You can limit ad tracking through iOS settings
Note: Some objections may limit core app functionality

Right to Restrict Processing

You can request we temporarily restrict certain data processing
Contact us at privacy@skoul.fr to discuss specific restrictions

Right to Lodge a Complaint

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

Exercising Your Rights

To exercise any of these rights, contact us at privacy@skoul.fr. We will respond within 30 days. Some rights can be exercised directly within the app settings.

Data Deletion

You have complete control over your child's data and can delete it at any time:

Delete Practice Data

Go to Settings > Learning Data > Clear All Practice Data

This removes all session history, scores, and progress tracking
Profile information (name, age, grade) is preserved
This action cannot be undone
Requires parental gate verification

Delete Profile & All Data

Uninstalling the app removes all locally stored data
Since we do not maintain user accounts or cloud storage, no data remains on our servers
Reinstalling the app creates a fresh start with no previous data

Data Deletion Timeline

Practice data deletion: Immediate
Profile deletion (uninstall): Immediate
No data retention period as all data is local

Third-Party Data

For data held by Google AdMob, refer to Google's privacy controls
We do not have access to or control over Google's data collection

For assistance with data deletion or questions about what data is stored, contact us at privacy@skoul.fr.

Security Measures

We implement appropriate technical and organizational measures to protect your child's information:

Technical Security Measures

Encryption:

All data stored on device is encrypted at rest using iOS AES-256 encryption
Data in transit to third-party services uses TLS 1.3+ encryption
Avatar photos are stored as encrypted JPEG files

Access Controls:

Parental gate required for sensitive actions (deleting data, editing profile)
iOS sandboxing isolates app data from other apps
No remote access to user data by HIGHTHEM employees

Data Minimization:

We collect only essential information
Practice data stays on device (not transmitted)
No user accounts mean no password vulnerabilities

Third-Party Security:

Backend API communications are encrypted and authenticated
AdMob uses Google's enterprise-grade security infrastructure
We regularly review third-party security practices

Organizational Measures

Privacy-by-design approach in all development
Regular security reviews of code and infrastructure
Prompt security updates through App Store releases
Incident response procedures for any security concerns

Limitations

While we implement strong security measures, no system is 100% secure. You can enhance security by:

Using a strong device passcode or biometric lock
Keeping iOS updated to the latest version
Only downloading Skoul from the official App Store
Supervising your child's device usage

Reporting Security Issues

If you discover a security vulnerability, please report it immediately to privacy@skoul.fr. We take all security reports seriously and will respond promptly.

Policy Updates

We may update this privacy policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

How We Notify You

The "Last Updated" date at the top of this policy will change
For material changes affecting children's privacy, we will notify you through the app
Material changes may require renewed parental consent
You can always access the current policy from Settings > Privacy Policy

What Constitutes a Material Change

New types of personal information collected
Changes to how we use or share information
Changes to data retention practices
New third-party services that access data
Changes to children's privacy protections

Your Options

Review the updated policy when notified
Contact us with questions at privacy@skoul.fr
If you disagree with changes, you may stop using the app and delete all data

Minor Changes

Clarifications, grammatical corrections, or formatting changes that don't affect your rights will not trigger notifications.

Version History

Current Version: 1.2
Last Updated: November 7, 2025
First Published: October 29, 2025

Contact Us

If you have any questions, concerns, or requests regarding this privacy policy or our data practices, please contact us:

Email: privacy@skoul.fr

Data Controller:
HIGHTHEM
SIREN: 848274338
France

We will respond to all legitimate privacy-related inquiries within 30 days.

For residents of France, you also have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the French data protection authority.

Summary

Key Points:

✅ All user data stored locally on your device
✅ Only non-nominative data (age, grade, country, difficulty) sent for exercise generation
✅ No name, avatar, or practice history ever transmitted
✅ No user accounts or cloud storage
✅ COPPA and GDPR compliant
✅ Uninstalling the app permanently deletes all data
✅ Parent controls for data deletion and privacy settings

This privacy policy is effective as of November 7, 2025