Privacy Policy and Personal Data Protection Policy for “EDOKI ACADEMY” Services

Last modified: April 22, 2026

Children’s Privacy Protection – PRIVO COPPA Safe Harbor Certification

The “EDOKI ACADEMY” services operated by BAYARD are members of the PRIVO Kids Privacy Assured COPPA Safe Harbor Certification Program (the “Program”). The Program’s certification applies only to the digital properties listed on the validation page accessible by clicking on the PRIVO seal.

PRIVO is an independent third-party organization dedicated to protecting children’s personal information collected online.

The PRIVO COPPA certification seal displayed on this page indicates that the “EDOKI ACADEMY” services operated by BAYARD have implemented privacy practices that comply with the U.S. Children’s Online Privacy Protection Act (COPPA) and have agreed to be subject to PRIVO’s oversight and consumer dispute resolution procedures.

If you have any questions or concerns regarding our privacy practices, please contact us at: dpo@groupebayard.com.
If, after contacting us, you have additional concerns, you may contact PRIVO directly at privacy@privo.com

BAYARD places a high priority on protecting privacy and complying with applicable data protection laws.

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

• The Personal Data collected by BAYARD and the reasons for this collection
• How your Personal Data is used
• Your rights as an individual whose data is being processed.

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

• The https://edokiclub.com/  website,
• The Montessori Preschool mobile app,
• The Le bonheur de lire mobile app,
• The Sightwords mobile app,
• The Busy Shapes & Colors mobile app,
• The Code Karts mobile app,
• The Code Karts School Edition mobile app,
• The Joy of Reading mobile app,
• The Jungle Math Challenge mobile app,
• The Busy Shapes mobile app.

Our website is intended for parents and educators; our educational apps are intended for young children with adult supervision.

The Data Controller

Bayard a Public limited company with a Management Board and Supervisory Board), hereinafter referred to as ‘BAYARD’ or ‘We/Us’ is responsible for collecting your Personal Data. The contact details are:

• Address: 15 boulevard Gabriel Péri - 92240 Malakoff (France).
• Email: dpo@groupebayard.com
• Phone number: +33 1 74 31 60 60

How does BAYARD protect Personal Data?

BAYARD integrates the protection of your Personal Data and your privacy when designing its services (Privacy by Design). To ensure the security of your data and safeguard your rights, BAYARD also implements default measures to protect your Personal Data (Privacy by Default).

What Personal Data does BAYARD use?

BAYARD only collects the data strictly necessary for providing its services.

When optional data is requested, BAYARD will clearly inform you which Personal Data is required to perform the service.

Personal Data is collected directly from you and used only for the purposes that have been communicated to you.

Personal Data may also be used to offer you additional services, but only if you have given your consent to receive marketing communications and if these products or services are provided by the same legal entity, are similar to those already offered by BAYARD.

We collect the following personal information through the mobile apps:

• For each parent/educator account:
• The account information: email s, password, chosen interface language.
• Anonymous usage information: connection location (up to the city level), device model, operating system, and pages visited within the app.
• For each child:
• Profile information: alias, progress and achievements in activities, audio snippets (recorded locally on the mobile device only)
• Anonymous usage information: connection location (up to the city level), device model, operating system, app and game usage data, and any other information necessary for the proper functioning of the app and its services.

With your consent, we collect information about your device when you use the website, including your IP address, browser type, operating system, and pages visited.

We use all of this information for the following purposes:

• To improve the mechanics of our games and adapt the interface to users’ needs
• To track users’ progress
• To conduct research and analysis for our own purposes
• To respond to your questions and concerns
• To display content based on your use of the service (e.g., progress)
• To allow you to receive information and offers about our services through our partners

Social Networks

We allow parents/educators to create a profile and share information such as messages, photos, and videos with others. We cannot control the actions of the people with whom you choose to share your pages and information. Therefore, we cannot guarantee that the content you post from our site will not be viewed by someone outside your network.

What is the legal basis for our Processing of your Personal Data?

BAYARD relies on the following legal bases to process personal data:

Performance of a contract

• If you are a customer of BAYARD, the legal basis for Processing the Personal Data collected from the user is the performance of the sales contract. In this context, you are required to provide the data necessary for the execution of the contract. If such data is not provided – including data required by the online payment service provider – it will not be possible to complete the purchase or provide the service.

• Management of complaints.
• Management and issuance of documents evidencing the sale (e.g., digital receipt)

Consent

The legal basis for processing your Personal Data is your consent, where such consent has been provided, for the following purposes:

• Managing subscriptions on the website and applications
• Managing the sending of information relating to exclusive promotions, the latest news, and personalized content tailored to your profile
• Managing notifications for new application availability

Withdrawal of consent for these processing activities by you does not affect the performance of the sales contract concluded between you and BAYARD.

Legitimate Interest

• Sending information about promotions for products similar to those you have previously purchased from BAYARD
• Conducting customer satisfaction surveys

Compliance with a legal obligation

• Responding to the exercise of the rights of access, rectification, erasure, objection, data portability, and restriction of processing
• Retaining data for accounting and tax record-keeping purposes

To whom may your Personal Data be disclosed?

Your data may be shared with:

• Our internal services responsible for delivering the subscribed services, including Customer Service, Sales Administration, and others
• Our partners involved in distributing information and announcements about our services
• External service providers who deliver services necessary for the operation of our platforms, primarily technical providers, including subcontractors
• Companies within the BAYARD GROUP, for purposes consistent with this Policy.

Will your Personal Data be transferred outside the European Union?

Data is stored on servers located in Canada and Ireland.

However, for certain specific services, BAYARD may use subprocessors located outside the EU. In such cases, certain Personal Data may be transferred to them solely for the purposes of performing their tasks. In accordance with applicable regulations, BAYARD requires its subprocessors to implement the necessary safeguards to regulate and secure these transfers, including, where applicable, by signing the European Commission’s standard contractual clauses.

How long does BAYARD retain your Personal Data?

The retention period for your Personal Data depends on the service you have subscribed to. BAYARD commits not to keep your Personal Data longer than necessary to provide the service, that is, for the duration of your use of the service, plus any additional period required by applicable statutory retention rules.

We will retain your personal information as long as your account remains active and will delete it after two (2) years of inactivity. If you wish to delete your account or request that we stop using your information to provide our services, please contact us at: dpo@groupebayard.com

Is your Personal Data protected?

BAYARD is committed to taking all necessary measures to ensure the security and confidentiality of your Personal Data, including preventing it from being damaged, erased, or accessed by unauthorized third parties.

The security of your personal information is important to us. When you provide sensitive information, its transmission is encrypted using Secure Socket Layer (SSL) technology.

We follow industry-recognized standards to protect the personal information you share with us. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

If you have any questions regarding security on our website, you can contact us at: dpo@groupebayard.com

In addition, in the event of a security incident affecting your Personal Data (destruction, loss, alteration, or disclosure), BAYARD is committed to complying with the obligation to notify the CNIL of any Personal Data breach.

What are your rights regarding your Personal Data?

You have the right, at any time, to exercise the rights provided under applicable Personal Data regulations with BAYARD, subject meeting the relevant conditions:

• Right of access: You may obtain a copy of your Personal Data processed by BAYARD in connection with the “EDOKY ACADEMY” services. To do this, log in to the website (https://edokiclub.com/login?locale=en) with your email and password, then go to the “Your Personal Data” section.
• Right to rectification: You may update or request the correction of your Personal Data processed by BAYARD in connection with the “EDOKY ACADEMY” services.
• Right to object, in particular to receiving marketing communications: You may indicate you do not wish to receive marketing communications from BAYARD or request that your Personal Data no longer be processed.
• Right to erasure: You may request the deletion of your Personal Data.
• Right to restriction of Processing: You may request the processing of your Personal Data be suspended.
• Right to data portability: You may request that BAYARD provide your Personal Data so that you can use it elsewhere.

When subscribing to a service or providing your Personal Data, you will be informed of the postal and/or email address to which you can send your request to exercise your rights.

If there is any doubt about the identity of the requester, proof of identity may be required if the information provided is insufficient to verify it. BAYARD is committed to responding to your requests to exercise your rights as quickly as possible and, in all cases, within the legal time limits.

Changes to the Privacy and Personal Data Protection Policy

We may update this privacy statement to reflect changes in our information practices, and we will post notice at the top of the policy if we do.

If we make a material change to the collection and use of your personal information, we will notify you if we have your contact information prior to making the change. We will post notice of material changes at the top of the policy prior to making the change.

We encourage you to review this page regularly to stay informed about our latest privacy practices.

COOKIE POLICY

The https://edokiclub.com/ website and all its pages use cookies to distinguish you from other users of the site. This allows us to improve our services and optimize your user experience.

A cookie is a small text file sent by a website to your computer’s hard drive so that the site can remember you. Cookies can help a website quickly tailor content to your interests. Most major websites use cookies. In general, a cookie contains its originating domain name of its origin, its “lifetime,” and a value, which is a randomly generated unique number.

On the website https://edokiclub.com/, there are two types of cookies:

• Session cookies, which remain in your browser’s cookie file only until you leave the website
• Persistent cookies, which remain in your browser’s cookie file for a longer period (depending on the cookie’s lifetime)

Session cookies are used:

• To allow you to transfer information from one page to another without having to re-enter it
• To enable access to stored registration information

Persistent cookies are used:

• To help us recognize you as a returning visitor (using a numeric identifier, not personal information) when you come back to our website
• To allow us to tailor content or advertisements to your interests, or to prevent you from seeing the same advertisement multiple times
• To compile statistics that help us understand how visitors use our website and improve its structure

You can choose to accept or refuse cookies by adjusting your browser settings. However, disabling cookies may cause certain interactive features of the service to stop functioning properly.

Below is a list of the main cookies we use and their proposes.

Cookie name	Cookie type	Cookie function
_ga	Persistent	We use Google Analytics to compile anonymous and aggregated statistics that help us understand how visitors use our website and to improve its structure. This data does not allow us to identify you personally. For more information, please see: www.google.com/policies/privacy/partners and https://tools.google.com/dlpage/gaoptout.
didomi_token	Persistent	This cookie, provided by our Didomi tool, is used to store your consent choices (so that you are not asked for them again on each page).
euconsent-v2	Persistent	This cookie, also provided by our Didomi tool, contains the IAB TCF consent string and consent information for all IAB standard purposes and vendors.

You can delete and block all cookies from https://edokiclub.com/.  To do so, adjust your browser settings to refuse some or all cookies. Please note, however, that if you choose to block cookies through your browser, certain features of our website may not function properly.

“EDOKI ACADEMY” mobile apps

Which information do we collect from children?

The Edoki Academy apps do not actively collect personal information from children. We work with service providers to support the internal operations of the app that passively collect information from all users of the apps.

Which information do service providers use in relation to children?

We use Mixpanel and Google Analytics to collect analytics data about your and your child’s use of the apps. Mixpanel collects but does not store an IP address to determine approximate location. Google Analytics collects an IP address to determine location at a country level before promptly discarding it.

We use AppsFlyer to help us measure, optimize, and protect our app marketing campaigns, and to track user engagement. AppsFlyer collects device ID, advertising IDs, referrer IDs and an IP address. This information is stored by AppsFlyer for a maximum of 7 months.

Our apps are built using Unity Game Engine and we use Unity to power our in-app purchases. Unity does not collect any personal information from our users.

These service providers do not use the data collected to contact specific individuals, for targeted advertising, or to build a profile of the user. Information collected is not disclosed to any third parties or for any other purpose other than as described.

If you have any questions about our use of service providers in the apps, please contact us at dpo@groupebayard.com.

Parent/Educator’s Rights

Parents/Educators have the right to request access to review, delete or prevent the further collection of information from or about their child by contacting us at: dpo@groupebayard.com

DEFINITIONS

Each term beginning with a capital letter has the meaning set out below:

• “Privacy and Personal Data Protection Policy” and “Policy”: refers to this Policy which describes the measures implemented for the Processing, use, and management of your Personal Data, as well as your rights as a data subject.
• “Personal Data”: means any information relating to you that allows you to be identified, directly or indirectly.
• “Processing”: means any operation or set of operations performed on your Personal Data.
• “Data Controller”: means BAYARD, who determines and carries out the Processing of your Personal Data.
• “Personal Data Breach”: means a breach of security leading, whether accidental or unlawful, to the destruction, loss, alteration, unauthorized disclosure of, or access to, your Personal Data.
• “Recipient”: means the department or company that receives and may access your Personal Data.