Privacy Policy

Who We Are

Welcome to Jolipop

Welcome to Jolipop.

Jolipop is an educational platform designed to help children develop English language skills through engaging, age-appropriate and interactive learning experiences.

Our goal is simple: to make learning enjoyable while creating an environment that parents can trust.

Because Jolipop is built for families, we recognise that protecting personal information is part of providing a quality educational experience. Privacy, security and transparency are therefore considered throughout the design, development and operation of our services.

This Privacy Policy explains how we collect, use, protect and manage personal information whenever you use Jolipop.

Who Operates Jolipop

Jolipop is the controller of the personal information described in this Privacy Policy.

As the data controller, Jolipop determines why and how personal information is processed when providing its educational services.

Our responsibilities include:

• protecting the personal information entrusted to us;
• using information only for legitimate and clearly explained purposes;
• providing parents with meaningful control over their family’s information;
• complying with applicable privacy and data protection laws; and
• continuously improving our privacy and security practices.

Our contact information is provided at the end of this Privacy Policy.

Who Uses Jolipop

Jolipop has been designed around families.

Although children are the learners, parents remain in control of the family’s account.

Within this Privacy Policy we use the following terms:

Parent

A parent or legal guardian who creates and manages a Jolipop account, purchases subscriptions where applicable, communicates with Jolipop and exercises privacy rights on behalf of the family.

Child

A learner whose educational experience is managed through the parent’s account.

Children do not independently create Jolipop accounts.

Children do not purchase subscriptions.

Children do not independently communicate with Jolipop through the platform.

Parents remain responsible for managing their child’s information within Jolipop.

Our Relationship with Families

We understand that educational services require a different level of trust than many other digital products.

Families share information with us because it enables us to deliver meaningful educational experiences, remember learning progress and personalise lessons over time.

That trust carries responsibilities.

Whenever we decide whether to collect, retain or use information, we ask ourselves three questions:

• Is this necessary to provide or improve the educational experience?
• Does this benefit the learner or the parent?
• Would we be comfortable explaining this decision openly to every family using Jolipop?

If the answer to any of these questions is no, we reconsider the decision.

Our Role in Protecting Children’s Privacy

Children deserve special protection when using digital services.

For this reason, Jolipop has been designed so that parents—not children—remain in control of account management and privacy decisions.

We intentionally minimise the amount of personal information associated with children and avoid collecting information that is not required to provide our educational services.

We do not design features intended to encourage children to disclose unnecessary personal information.

Whenever new features are considered, privacy and child protection form part of the design process before those features become available.

Privacy Is Part of the Product

Many organisations describe privacy as a legal requirement.

We see it differently.

Privacy is a product decision.

Every system we build, every feature we introduce and every technology we adopt is evaluated not only for functionality, but also for its impact on the families who use Jolipop.

This approach influences how we design our applications, how we select service providers, how we secure our infrastructure, how we train our team and how we make future product decisions.

We believe the best privacy policy is one that accurately reflects how a product has been built.

This document is intended to do exactly that.

Scope of this Privacy Policy

When This Policy Applies

This Privacy Policy applies whenever you interact with Jolipop, including when you:

• visit the Jolipop website;
• create or manage a parent account;
• create or manage child profiles;
• use the Jolipop mobile applications;
• purchase or manage subscriptions;
• receive emails, notifications or other communications from us;
• contact our support team; or
• otherwise use services that refer to this Privacy Policy.

This Policy also applies to information collected through our official websites and applications before or after you create an account, where applicable.

What This Policy Covers

This Privacy Policy explains:

• what personal information we collect;
• why we collect it;
• how we use it;
• who receives it;
• how long we retain it;
• how we protect it;
• the choices available to parents; and
• the rights available under applicable privacy laws.

Where additional information is required for specific features or services, we may provide supplementary privacy notices.

What This Policy Does Not Cover

This Privacy Policy does not apply to:

• third-party websites that may be linked from Jolipop;
• services operated independently by our payment providers or other third parties;
• information processed by app stores or device manufacturers;
• services that publish their own independent privacy policies.

We encourage you to review the privacy practices of those organisations whenever you use their services.

Applicable Privacy Laws

Jolipop is committed to complying with applicable data protection and privacy legislation, including the General Data Protection Regulation (GDPR) where it applies.

Depending on where you live, you may also have additional rights under local privacy laws. Where those laws provide greater protection than this Privacy Policy, we will respect those rights to the extent required by law.

How Jolipop Works

Understanding the Jolipop Platform

Before explaining what information we collect, we believe it is helpful to explain how Jolipop works.

Many privacy policies begin with lists of personal information. We believe it is more useful to first explain why certain information exists within the platform.

Jolipop has been designed around a simple principle:

Children come to Jolipop to learn. Parents remain in control.

Every decision about how information is collected, stored and used follows this principle.

The information we process exists because it supports learning, enables parents to manage their family’s experience and helps us operate a secure and reliable educational platform.

The Family Account

Every Jolipop account represents a family.

The family account is created by a parent or legal guardian and serves as the central point for managing the family’s relationship with Jolipop.

Through the family account, parents can:

• create and manage child profiles;
• purchase and manage subscriptions;
• review learning progress;
• configure educational settings;
• receive reports and notifications;
• communicate with Jolipop Support;
• exercise privacy rights; and
• manage their family’s personal information.

Children do not independently manage the family account.

Parent Accounts

Parents are our primary users from a privacy perspective.

The parent creates the account, accepts the Terms of Service, provides any necessary consents, manages subscriptions and makes decisions regarding the family’s information.

Because parents act on behalf of their children, communications regarding privacy, security and account management are directed to parents rather than children.

Parents remain responsible for ensuring that information associated with their family’s account is accurate and up to date.

Child Profiles

Within a family account, parents may create one or more child profiles.

A child profile allows Jolipop to personalise educational experiences for each learner.

Depending on how the platform is used, a child profile may include information such as:

• a display name or nickname chosen by the parent;
• age or age range;
• learning level;
• educational preferences;
• completed lessons;
• learning achievements;
• educational progress; and
• other information necessary to provide learning activities.

Child profiles exist solely to support the educational experience.

Children are not expected to independently provide personal information through Jolipop beyond what is necessary to participate in learning activities.

Learning Progress

One of the most valuable features of Jolipop is remembering learning progress over time.

When a child completes activities, lessons or educational exercises, Jolipop records the outcomes so that learning can continue naturally from one session to the next.

For example, Jolipop may remember:

• completed lessons;
• vocabulary mastered;
• pronunciation achievements (when this feature becomes available);
• learning streaks;
• educational milestones;
• progress through educational programmes; and
• recommended future activities.

This allows the platform to provide continuity rather than treating every session as if it were the first.

Learning progress is educational information.

It is not advertising data.

It is not marketing data.

It exists to improve the learning experience for the child.

Educational Personalisation

Children learn differently.

Some require more repetition.

Others progress more quickly.

Educational personalisation allows Jolipop to adapt lessons and recommendations based on previous learning activity.

This helps us present content that is appropriate for each learner’s current stage without requiring parents to manually configure every lesson.

Educational personalisation is intended solely to improve educational outcomes.

It is never used for behavioural advertising, commercial profiling or marketing directed at children.

Subscriptions

Certain Jolipop services may require a paid subscription.

Subscription management is handled through trusted payment partners.

Jolipop does not store complete payment card details.

Instead, payment information is processed by specialised payment providers that meet applicable security and compliance standards.

Subscription information enables us to:

• activate premium features;
• manage billing;
• process renewals where authorised;
• maintain purchase history;
• provide customer support; and
• comply with financial and tax obligations.

Communications

Parents may receive communications from Jolipop relating to their account or the services they use.

Examples include:

• account verification;
• password reset requests;
• subscription information;
• service announcements;
• educational progress summaries;
• important security notifications;
• customer support responses; and
• updates regarding changes to our services or policies.

Where required by law, marketing communications are provided only where appropriate consent has been obtained or another lawful basis applies.

Parents may opt out of promotional communications at any time.

Service-related communications that are necessary for operating your account may continue even if you opt out of marketing messages.

Analytics That Support Learning

Like most modern software platforms, Jolipop collects technical information about how its services are used.

We do this to understand how well the platform performs, identify technical issues, improve educational experiences and maintain system reliability.

Our analytics are designed differently from many commercial platforms.

Our goal is not to build advertising profiles.

Our goal is to understand whether Jolipop is working as intended.

For example, analytics may help us answer questions such as:

• Did a lesson successfully load?
• Which educational activities are most effective?
• Where do learners commonly stop progressing?
• Are there technical errors affecting families?
• Are new features improving the learning experience?

These insights help us improve Jolipop for everyone.

Support

Occasionally, parents may contact Jolipop Support.

Support interactions allow us to answer questions, resolve technical issues and assist families in using the platform.

To protect privacy, Jolipop intentionally limits the information available to support personnel.

Support staff do not receive unrestricted access to family information.

Access is provided only where necessary to assist with a specific request and is limited according to the principle of least privilege.

Support personnel cannot freely browse children’s educational information.

Where possible, support relies on diagnostic information rather than direct access to personal data.

Security

Protecting educational information is an essential part of operating Jolipop.

We continuously monitor our systems to detect technical problems, maintain service availability and protect against unauthorised access.

Security measures include administrative, organisational and technical safeguards designed to protect personal information throughout its lifecycle.

Additional information about our security practices is provided later in this Privacy Policy.

Looking Ahead

Technology continues to evolve, and so will Jolipop.

As we introduce new educational capabilities, we will continue to evaluate how those features affect privacy before they become available.

For example, future capabilities may include pronunciation assessment, speech recognition or AI-assisted educational experiences.

Before introducing features that materially change how personal information is processed, we will:

• evaluate the privacy implications;
• implement appropriate technical and organisational safeguards;
• update this Privacy Policy where necessary; and
• provide additional information to families when appropriate.

Our commitment to protecting children’s privacy will remain the same regardless of how our technology evolves.

Why We Explain This First

Everything described in the remainder of this Privacy Policy exists because of the educational services explained in this section.

We believe understanding why information exists is just as important as understanding what information is collected.

Our goal is to collect the minimum information necessary to provide a high-quality educational experience while giving parents meaningful transparency and control over their family’s information.

Information We Collect

Our Approach to Data Collection

We believe that collecting less information is usually better than collecting more.

Whenever we consider collecting a new category of information, we ask four questions:

• Is it necessary to provide or improve the educational service?
• Does it benefit the learner or the parent?
• Can we achieve the same goal while collecting less information?
• Can we clearly explain why we collect it?

If we cannot confidently answer these questions, we reconsider whether the information should be collected at all.

The categories below describe the information we may collect and why it is needed.

Parent Information

Parents create and manage Jolipop accounts on behalf of their families.

Examples

• Full name
• Email address
• Country or region
• Preferred language
• Account credentials (stored securely)
• Account preferences
• Communication preferences

Why We Collect It

We use this information to:

• create and secure your account;
• authenticate your identity;
• communicate with you;
• manage subscriptions;
• respond to support requests;
• notify you about important service updates; and
• comply with applicable legal obligations.

Is It Required?

Yes.

Without this information, we cannot create or manage your Jolipop account.

Retention

Generally retained while your account remains active and for up to 36 months after account closure, unless a longer retention period is required by law.

Child Profile Information

Parents create child profiles to personalise learning experiences.

Examples

• Display name or nickname
• Age or age range
• Learning level
• Educational preferences
• Avatar selections (where applicable)

Why We Collect It

This information allows Jolipop to:

• personalise educational content;
• recommend suitable learning activities;
• organise educational progress;
• distinguish between multiple learners within one family.

Is It Required?

Only the minimum information necessary to provide personalised educational services is required.

Parents choose what information to provide beyond mandatory fields.

Retention

Generally retained while the family account remains active and for up to 36 months after account closure unless deletion is requested earlier or legal obligations require otherwise.

Educational Information

Educational information is created while children use Jolipop.

Unlike account information, educational information reflects learning rather than identity.

Examples include:

• completed lessons;
• learning progress;
• educational achievements;
• vocabulary mastered;
• learning history;
• recommended future activities;
• lesson completion statistics; and
• educational milestones.

We use this information solely to improve and personalise learning experiences.

Educational information is never used for advertising or sold to third parties.

Device and Technical Information

In addition to information that you or your device intentionally provide, Jolipop automatically receives certain technical information whenever our services are used.

This information helps us operate, secure and improve the platform.

Examples

• Device type
• Operating system
• Application version
• Browser type
• Language settings
• Time zone
• Network information
• Device identifiers where necessary for platform operation
• Technical diagnostic information

Why We Collect It

We use this information to:

• ensure compatibility across devices;
• identify and resolve technical issues;
• maintain platform security;
• improve application performance;
• investigate service interruptions; and
• understand how our applications perform in real-world environments.

Is It Required?

Some technical information is generated automatically whenever digital services are used and is necessary for the secure operation of the platform.

Retention

Technical information is retained only for as long as reasonably necessary to operate, secure and improve Jolipop, in accordance with our retention schedule.

Subscription Information

Where families subscribe to paid services, additional information relating to the subscription is processed.

Examples

• Subscription status
• Subscription type
• Purchase date
• Renewal status
• Transaction identifiers
• Platform used for purchase (where applicable)

Jolipop does not store complete payment card numbers or other sensitive payment credentials.

Payment information is processed by trusted payment providers specialising in secure payment processing.

Why We Collect It

Subscription information enables us to:

• activate premium services;
• verify purchases;
• manage renewals;
• process refunds where applicable;
• provide customer support; and
• comply with accounting and tax obligations.

Is It Required?

Only if you choose to purchase paid services.

Retention

Financial and transaction records may be retained for periods required by applicable accounting, taxation or legal obligations.

Communications

When you communicate with Jolipop, we retain information necessary to continue the conversation and provide assistance.

Examples

• Support requests
• Email correspondence
• Feedback
• Bug reports
• Feature suggestions
• Survey responses
• Customer satisfaction feedback

Why We Collect It

We use this information to:

• answer your questions;
• investigate technical issues;
• improve our services;
• document customer support activities; and
• maintain a record of communications where appropriate.

Is It Required?

Only if you choose to contact us.

Retention

Support records are retained only for as long as necessary to provide assistance, improve our services or comply with legal obligations.

Security Information

Protecting families requires us to monitor the security of our systems.

Certain information is generated automatically whenever accounts interact with Jolipop.

Examples

• Login attempts
• Authentication events
• Password reset requests
• Administrative actions
• Security alerts
• Audit records
• Access logs
• Error logs

Why We Collect It

We use this information to:

• detect unauthorised access;
• investigate security incidents;
• protect accounts;
• maintain platform integrity;
• identify fraudulent activity; and
• comply with security obligations.

Security information is never used for advertising or marketing purposes.

Is It Required?

Yes.

Without security monitoring we would be unable to adequately protect our users and systems.

Retention

Security logs are generally retained for up to 12 months, unless longer retention is necessary for an active investigation or legal obligation.

Information Generated Through Analytics

Jolipop uses internal analytics to understand how well the platform operates.

Our analytics are designed to improve education—not to build advertising profiles.

Examples include:

• feature usage;
• lesson completion rates;
• navigation patterns;
• application performance;
• crash statistics (if implemented in the future);
• anonymised usage trends.

Whenever possible, analytics are aggregated or pseudonymised.

We intentionally avoid collecting information that is unrelated to improving the educational experience.

Why We Collect It

Analytics help us:

• improve educational quality;
• identify usability issues;
• prioritise product improvements;
• measure platform reliability;
• evaluate new features.

Retention

Raw analytical data is generally retained for up to 60 months.

Aggregated or fully anonymised statistical information may be retained indefinitely because it can no longer identify an individual or family.

Information We Do Not Intentionally Collect

Just as important as the information we collect is the information we deliberately choose not to collect.

Unless a future feature specifically requires it and is accompanied by an updated Privacy Policy, Jolipop does not intentionally collect:

• biometric identifiers;
• precise geolocation information;
• government-issued identification numbers;
• health records;
• financial account credentials;
• payment card numbers;
• social media profile information;
• contact lists from your device;
• photographs or videos unrelated to educational features;
• microphone recordings (except where a future pronunciation feature is explicitly enabled);
• unnecessary personal information about children.

If we ever introduce features that require additional categories of information, we will explain those changes before the feature becomes available.

Information From Third Parties

In limited circumstances, Jolipop may receive information from trusted third parties that help us provide our services.

Examples include:

• payment confirmation from our payment providers;
• subscription status from subscription management providers;
• technical delivery confirmations from communication providers.

We receive only the information necessary to provide the relevant service.

We do not purchase personal information from data brokers.

We do not enrich family profiles using external marketing databases.

Accuracy of Information

We encourage parents to keep their account information accurate and up to date.

Accurate information helps us:

• provide appropriate educational experiences;
• communicate important account information;
• process subscriptions correctly;
• respond efficiently to support requests.

Parents can update much of their account information directly through Jolipop.

Where information cannot be updated directly, our Support team can assist.

Data Minimisation

Collecting information simply because it may become useful in the future is not consistent with how Jolipop is designed.

Instead, we follow a principle of data minimisation.

This means we seek to collect only the information that is genuinely necessary to:

• provide our educational services;
• secure our platform;
• support our users;
• improve learning experiences; and
• comply with legal obligations.

Whenever we can achieve the same result while collecting less information, we prefer the option that better protects privacy.

How We Use Personal Information

Why We Process Personal Information

Every category of information described in this Privacy Policy exists because it serves a specific purpose.

We do not process personal information simply because technology makes it possible.

Instead, every processing activity is connected to operating, improving or protecting Jolipop and the educational experience we provide.

The following sections explain the principal purposes for which personal information is processed.

Providing Educational Services

The primary purpose of processing personal information is to deliver the educational services requested by families.

This includes:

• creating family accounts;
• managing child profiles;
• delivering lessons;
• remembering educational progress;
• personalising learning experiences;
• synchronising progress across devices;
• maintaining educational continuity.

Without these activities, Jolipop could not provide the core educational experience.

Managing Accounts

We process account information to:

• authenticate users;
• manage passwords;
• verify account ownership;
• maintain account security;
• update account settings;
• manage subscriptions;
• communicate with parents.

These activities ensure that parents remain in control of their family’s account.

Personalising Learning

Every child learns differently.

We use educational information to adapt the learning experience according to each learner’s progress.

This may include:

• recommending appropriate lessons;
• adjusting educational difficulty;
• remembering completed activities;
• highlighting educational achievements;
• supporting long-term learning continuity.

Educational personalisation exists solely to improve learning outcomes.

It is not used for advertising, commercial profiling or marketing directed at children.

Communicating With Parents

We process communication information to:

• send account notifications;
• respond to support requests;
• provide educational updates;
• notify parents about important service changes;
• send security notifications;
• manage subscription communications.

Where promotional communications are sent, parents can unsubscribe at any time unless the communication is necessary for operating their account.

Processing Payments

Where families purchase subscriptions, information is processed to:

• verify purchases;
• activate subscriptions;
• manage renewals;
• process refunds where applicable;
• maintain financial records;
• comply with accounting and tax requirements.

Sensitive payment credentials are processed by specialised payment providers rather than by Jolipop.

Improving Jolipop

We continuously improve Jolipop based on technical, educational and operational insights.

Information may therefore be processed to:

• improve lesson quality;
• enhance usability;
• identify technical issues;
• measure platform performance;
• prioritise product improvements;
• evaluate new educational features;
• improve accessibility.

Whenever possible, aggregated or pseudonymised information is used for these purposes.

Protecting Our Services

Security is an ongoing responsibility.

We process information to:

• detect suspicious activity;
• prevent fraud;
• investigate security incidents;
• monitor system integrity;
• identify technical vulnerabilities;
• protect families from unauthorized access.

These activities help maintain a safe and reliable educational environment for everyone using Jolipop.

Providing Customer Support

When parents contact Jolipop, we process the information necessary to understand the request and provide assistance.

This may include:

• identifying the relevant account;
• reviewing technical diagnostics;
• responding to questions;
• resolving subscription issues;
• investigating reported problems; and
• documenting support interactions where appropriate.

Our support processes are intentionally designed to minimise access to personal information.

Support personnel are granted only the level of access required to resolve a specific issue.

They do not have unrestricted access to children’s educational records, nor do they routinely browse family accounts.

Complying with Legal Obligations

Like any organisation, Jolipop must comply with certain legal and regulatory obligations.

Where required, we may process personal information to:

• comply with applicable laws;
• maintain accounting and financial records;
• respond to lawful requests from competent authorities;
• establish, exercise or defend legal claims;
• prevent unlawful activity; and
• fulfil other legal responsibilities.

Whenever possible, we disclose only the minimum information necessary to satisfy those obligations.

Conducting Internal Administration

Operating an educational platform requires certain internal administrative activities.

These may include:

• maintaining system documentation;
• monitoring operational performance;
• planning infrastructure improvements;
• managing service providers;
• maintaining audit records;
• ensuring business continuity.

These activities support the reliable operation of Jolipop and are not intended to profile or market to families.

Developing New Educational Features

As Jolipop evolves, we may develop new educational capabilities.

Where appropriate, limited information may be used to:

• evaluate prototype features;
• measure educational effectiveness;
• improve lesson design;
• understand platform performance.

Whenever a proposed feature would materially change how personal information is processed, we will:

• evaluate its privacy impact;
• implement appropriate safeguards;
• update this Privacy Policy before launch; and
• provide additional information where appropriate.

Our Commitment to Responsible Use

The ways in which we use personal information are guided by principles rather than by opportunity.

Technology often makes it possible to collect or analyse more information than is actually necessary.

We deliberately choose not to do so.

Whenever we consider introducing a new processing activity, we evaluate whether it:

• supports our educational mission;
• benefits families;
• respects children’s privacy;
• aligns with our privacy principles; and
• can be clearly explained in plain language.

If a proposed use does not meet these standards, we reconsider whether it should exist at all.

What We Never Do

Trust Is Built by Saying “No”

Most privacy policies explain what a company does.

We believe it is equally important to explain what we deliberately choose not to do.

Many of these decisions are not required by law.

They reflect the values on which Jolipop has been built.

These commitments are part of our approach to earning and maintaining the trust that families place in us.

We Do Not Sell Personal Information

We do not sell personal information.

We do not receive payment for providing personal information to advertisers, data brokers or other commercial organisations.

Personal information entrusted to Jolipop is used to operate and improve our educational services—not as a commercial product.

We Never Sell Children’s Information

Children deserve a higher standard of protection.

Accordingly, Jolipop never sells information relating to children.

This commitment applies regardless of whether applicable law would permit a particular activity.

We Do Not Build Advertising Profiles

Jolipop is an educational platform.

It is not an advertising platform.

We do not create behavioural advertising profiles about children or parents.

We do not monitor educational activity in order to target advertising.

Learning data exists solely to support learning.

We Do Not Show Behavioural Advertising to Children

Children using Jolipop are not shown advertisements that are selected based on profiling, behavioural analysis or personal interests.

Our educational experience is designed around learning—not advertising.

We Do Not Use Customer Information to Train Public AI Models

Artificial intelligence is becoming an increasingly important technology.

Where Jolipop uses AI internally, it is used to assist with activities such as content creation and operational efficiency.

We do not use personal information belonging to our families to train publicly available artificial intelligence models.

Likewise, we do not submit customer information to public AI services for training purposes.

Should future AI-powered educational features require the processing of additional personal information, those features will undergo privacy review before becoming available.

We Do Not Collect Information “Just in Case”

We reject the idea that information should be collected simply because it may become useful in the future.

Every category of information collected by Jolipop must have a defined purpose that supports:

• education;
• platform operation;
• security;
• customer support; or
• legal compliance.

If we cannot justify collecting information, we do not collect it.

We Do Not Give Support Teams Unrestricted Access

Providing good customer support does not require unrestricted access to family information.

Accordingly:

• support personnel cannot freely browse family accounts;
• access is limited to what is necessary to resolve a specific issue;
• access is logged where appropriate;
• administrative permissions are carefully controlled.

Protecting privacy includes protecting information from unnecessary internal access.

We Do Not Create Independent Child Accounts

Jolipop has been designed around family-managed accounts.

Children do not independently register for Jolipop.

Children do not independently purchase subscriptions.

Children do not independently manage privacy settings.

Parents remain responsible for creating and managing their family’s account.

We Do Not Surprise Families

We believe privacy practices should never come as a surprise.

If we introduce significant new features that materially change how personal information is processed, we will explain those changes before the feature becomes available.

Transparency should come before deployment—not afterwards.

We Do Not Trade Trust for Convenience

Sometimes collecting more information would make product development easier.

Sometimes reducing privacy protections would simplify engineering.

Sometimes sharing additional information with third parties would reduce operational effort.

We deliberately choose not to take those shortcuts.

We believe that trust, once lost, is difficult to rebuild.

Protecting the information entrusted to us is therefore considered part of delivering a high-quality educational service—not a competing objective.

Processing Personal Information

Performance of a Contract

Most of the information processed by Jolipop is necessary to provide the educational services requested by parents.

This includes activities such as:

• creating family accounts;
• delivering lessons;
• remembering educational progress;
• managing subscriptions;
• providing customer support;
• maintaining user settings.

Without this processing, Jolipop would not be able to provide its services.

Compliance with Legal Obligations

Certain information is processed because applicable law requires us to do so.

Examples include:

• maintaining financial records;
• complying with tax obligations;
• responding to lawful requests;
• fulfilling regulatory requirements.

Legitimate Interests

In some situations, we process information because doing so supports legitimate interests while respecting the rights and freedoms of our users.

Examples include:

• protecting platform security;
• preventing fraud;
• investigating technical incidents;
• improving system reliability;
• maintaining operational records;
• improving educational quality through internal analytics.

Whenever we rely on legitimate interests, we carefully consider the potential impact on individuals and implement safeguards where appropriate.

Consent

Certain activities may rely on consent where required by law.

Examples may include:

• optional marketing communications;
• certain optional cookies or similar technologies;
• future educational features that require additional permissions.

Where consent is used as the legal basis, it may generally be withdrawn at any time.

Withdrawal of consent does not affect processing that occurred before consent was withdrawn.

Protecting Children’s Interests

Whenever information relates to children, Jolipop applies additional safeguards regardless of the legal basis relied upon.

Our decisions are guided not only by legal compliance but also by our commitment to protecting children and maintaining the trust of families.

We seek to ensure that every processing activity involving children’s information is necessary, proportionate and consistent with the educational purpose for which the information was collected.

Sharing Personal Information

Our Approach to Sharing Information

Families trust Jolipop with information that is personal and, in many cases, relates to their children.

We therefore treat the sharing of personal information as an exception rather than the default.

We share personal information only when it is necessary to:

• provide our services;
• operate our platform securely;
• comply with legal obligations; or
• protect the rights, safety or security of our users or Jolipop.

We do not sell personal information.

We do not provide personal information to advertisers for behavioural advertising.

We do not disclose more information than is necessary for the specific purpose.

Sharing Within Jolipop

Personal information is processed internally only by authorised personnel who require access to perform their responsibilities.

Access is granted according to the principle of least privilege.

This means employees receive access only to the information necessary for their specific role.

Access permissions are reviewed periodically and may be removed whenever they are no longer required.

Service Providers

Like most modern online services, Jolipop works with carefully selected service providers that help us operate the platform.

These providers process information only on our behalf and only in accordance with our instructions.

Where applicable, we require appropriate contractual, technical and organisational safeguards before sharing personal information.

We carefully evaluate service providers before using them and periodically review whether they continue to meet our privacy and security expectations.

Payment Providers

When purchasing subscriptions, payment information is processed directly by our payment providers.

Jolipop does not receive or store complete payment card numbers.

Instead, our payment providers securely process payment credentials and provide us only with the information necessary to:

• confirm successful payments;
• activate subscriptions;
• process refunds where applicable;
• maintain subscription status; and
• comply with financial obligations.

Communications Providers

When we send emails or SMS messages, the relevant communication provider necessarily processes information required to deliver those messages.

Depending on the communication, this may include:

• recipient address;
• recipient telephone number;
• message delivery status;
• technical delivery information.

Communication providers are not authorised to use this information for their own marketing purposes when acting on our behalf.

Legal Requirements

There may be circumstances where Jolipop is legally required to disclose personal information.

Examples include:

• responding to lawful court orders;
• complying with applicable legislation;
• cooperating with competent regulatory authorities;
• responding to legally valid requests from public authorities.

Whenever legally permitted, we seek to disclose only the minimum information necessary to satisfy the applicable legal requirement.

Where appropriate and lawful, we may also notify affected users before information is disclosed.

Protecting Rights and Safety

In limited situations, we may disclose information where reasonably necessary to:

• protect the safety of users;
• prevent fraud;
• investigate security incidents;
• enforce our Terms of Service;
• protect Jolipop’s legal rights;
• protect the rights of others.

Such disclosures are made only where appropriate and proportionate under the circumstances.

Business Changes

If Jolipop undergoes a corporate transaction such as a merger, acquisition, restructuring or sale of assets, personal information may be transferred as part of that transaction.

Should such an event occur, we will seek to ensure that:

• the information remains protected;
• the acquiring organisation honours applicable privacy obligations; and
• families are informed where required by applicable law.

Any successor organisation would be expected to continue protecting personal information in a manner consistent with this Privacy Policy unless families are informed otherwise.

We Never Share Information for Advertising

To avoid any misunderstanding, we wish to be explicit.

Jolipop does not share personal information with advertising networks for behavioural advertising.

We do not sell educational information.

We do not commercialise children’s personal information.

These are intentional design decisions and reflect our long-term commitment to protecting families.

International Data Transfers

Processing Information Across Borders

Modern cloud services may involve processing information in more than one country.

Where personal information is transferred internationally, Jolipop seeks to ensure that appropriate safeguards are in place to protect that information.

Our Infrastructure

Jolipop is currently designed to operate using secure infrastructure that supports the reliable delivery of our services.

As our platform evolves, we intend to operate primarily on infrastructure provided by Google Cloud.

Our infrastructure providers are selected based on factors including:

• security;
• reliability;
• privacy;
• regulatory compliance;
• operational resilience.

Our Safeguards

Whenever personal information is transferred internationally, we seek to ensure that appropriate legal mechanisms are in place.

Depending on the circumstances, these safeguards may include:

• adequacy decisions issued by competent authorities;
• Standard Contractual Clauses (SCCs);
• contractual commitments;
• technical safeguards such as encryption;
• organisational measures designed to protect personal information.

Our Commitment

International transfers do not reduce our responsibility to protect personal information.

Regardless of where information is processed, Jolipop remains responsible for ensuring that our service providers maintain appropriate privacy and security standards.

Data Retention

Why We Retain Information

Information is retained only for as long as necessary to fulfil the purposes described in this Privacy Policy.

Different categories of information require different retention periods.

For example, educational progress may need to remain available while a family actively uses Jolipop, whereas security logs are generally useful only for a defined operational period.

Whenever information is no longer required, we seek to securely delete, anonymise or otherwise remove it in accordance with our retention policies.

Our General Retention Schedule

These periods may be adjusted where required by law or where information must be retained to resolve disputes, investigate incidents or comply with legal obligations.

Account Deletion

Parents may request deletion of their Jolipop account.

Following a verified deletion request, we will seek to remove or anonymise personal information that is no longer required.

Certain information may continue to be retained where necessary to:

• comply with legal obligations;
• resolve disputes;
• prevent fraud;
• maintain security records;
• establish, exercise or defend legal claims.

Retention of such information is limited to the extent necessary for those purposes.

Backups

To protect against accidental loss and support business continuity, Jolipop may maintain encrypted backups of its systems.

Information contained within backup systems is protected by the same security standards that apply to production systems.

Backup data is retained only as long as necessary to support disaster recovery and operational resilience.

Where practical, deleted information naturally expires from backup systems according to established backup rotation schedules.

Children’s Privacy

Children Are the Reason Jolipop Exists

Jolipop has been created for children.

Protecting children’s privacy is therefore not simply a legal obligation—it is one of our fundamental responsibilities.

Every decision regarding the processing of children’s information is evaluated with this responsibility in mind.

We believe children deserve digital services that place their interests ahead of commercial considerations.

Parents Remain in Control

Jolipop is designed so that parents manage the family’s relationship with the platform.

Parents:

• create family accounts;
• create child profiles;
• manage subscriptions;
• receive communications;
• exercise privacy rights;
• request corrections or deletion;
• make decisions regarding the family’s information.

Children do not independently create Jolipop accounts.

We Collect the Minimum Necessary

Whenever information relates to children, we apply an additional level of scrutiny.

We ask not only whether collecting information is legally permitted, but whether it is genuinely necessary to support learning.

Where we can provide the same educational experience while collecting less information, we choose the option that better protects children’s privacy.

Educational Information Is Not Advertising Information

Educational progress belongs in education.

It does not belong in advertising systems.

Information about lessons completed, vocabulary learned, educational achievements or learning progress is processed solely for educational purposes.

It is never used to create advertising profiles or behavioural marketing segments.

Future Educational Features

As educational technology evolves, Jolipop may introduce new capabilities such as:

• pronunciation assessment;
• speech recognition;
• AI-assisted educational experiences;
• adaptive learning technologies.

Before any feature that materially changes how children’s personal information is processed becomes available, Jolipop will:

• conduct an appropriate privacy review;
• evaluate risks to children;
• implement suitable safeguards;
• update this Privacy Policy where necessary;
• provide clear information to families before deployment.

Innovation should never come at the expense of children’s privacy.

Our Promise to Families

Everything described throughout this Privacy Policy reflects a simple belief.

Children are not products.

Their curiosity should not become advertising data.

Their learning should not become commercial profiling.

Their educational journey should remain exactly that—an educational journey.

This principle guides our decisions today and will continue to guide the future development of Jolipop.

Contact Us

How to Reach Our Privacy Team

For any privacy question or request, reach us through Help & Support inside the Jolipop app.

A parent can also exercise every privacy right described in this Policy directly from Settings, where you can see the data held for each child profile, export a copy of your family's data, delete an individual child profile, delete your whole account, and review or change your consent decisions.