Privacy Policy

The data controller for the processing described in this policy is:

We have not appointed a Data Protection Officer. Privacy questions and data subject requests should be sent to privacy@foxio.eu, which is monitored by the team responsible for data protection at Foxio.

Where Foxio provides the platform to a school, employer or other organisation under a business agreement, that organisation is the controller for the account data it administers and Foxio acts as its processor. This policy then describes our own processing only.

Account holders (parents and guardians)

Adults who register, pay and administer the family account. You are our contracting party.

Children

Children whose profiles a parent creates, and children who sign in to their own child account using a username and code issued by their parent. Children do not contract with Foxio; their data is processed on the basis of the parent's contract and, where required, the parent's consent.

Teachers and educators

Adults who register a teacher account, use classroom features or participate in the referral programme.

Organisational users

Employees or members of a company, school or institution that has purchased access. See section 1 on our role in that case.

Visitors

Anyone browsing the public parts of foxio.eu - courses, storybooks, games, printables and pricing - without an account.

We collect only what a given feature needs. If you never open Story Studio we never receive a photo; if you never use an assistant we never receive a conversation.

Every processing operation needs a legal basis under Article 6 GDPR - and, for special categories of data, under Article 9. Ours are:

Where we rely on legitimate interests, we have carried out a balancing assessment weighing our interest against your rights and freedoms. You may ask us for a summary of that assessment, and you may object to the processing under section 12.

Because children use the assistants, every message is checked by an automated safety classifier before an answer is produced. If the classifier judges a message to be unsafe, we block the answer and record a safety flag.

A safety flag records the category of concern (sexual content, violence, self-harm, hate, dangerous activity or other), a severity level, the subject, the language, a short excerpt of the message, and the child profile and parent account involved.

• Safety flags are visible only to the parent who holds the account, in the Foxio dashboard.
• We send the parent an email alert. The excerpt of the flagged message is never included in that email - you must sign in to see it.
• Flags are not shared with schools, advertisers or any third party, and we do not use them to profile your child.
• We do not automatically contact emergency services or any authority. Foxio is not a crisis service. If you believe a child is in danger, contact your local emergency number or a child helpline immediately.

You can read more about how this works, and how to talk to your child about it, in the Children and Family Data Notice.

Foxio is designed for children but sold to adults. We do not knowingly allow a child to open an account in their own name, and we do not knowingly collect personal data directly from a child except through a child account that a parent has created and controls.

• A child account is created by the parent, who chooses the username and access code and can delete the account at any time.
• A child account cannot buy anything, cannot change billing details and cannot see the parent's data.
• The parent can see their child's activity, assistant conversations and safety flags.
• We do not show behavioural advertising to anyone, and we never target advertising at children.

If you believe a child has provided us with personal data without a parent's involvement, write to us at privacy@foxio.eu and we will delete it.

The full detail - parental consent, what a child can and cannot do, photographs, safety alerts and how to exercise a child's rights - is in the Children and Family Data Notice.

Foxio does not train or operate its own large language models. We send the content needed to answer a question, or to write and illustrate a story, to specialist providers acting as our processors, and we return their output to you.

AI systems can be wrong. Answers, stories and exercises are generated automatically and are not reviewed by a person before you see them. They are not professional educational, medical, psychological or legal advice. The limits of what we promise about AI output are set out in the Terms of Service.

We do not sell personal data and we do not share it with advertising networks or data brokers. We use a small number of service providers who process data on our documented instructions under Article 28 GDPR contracts:

Our database, authentication and file storage are hosted in the European Union. Your account data, your children's data, your assistant conversations and your generated books are stored on servers inside the EEA.

Some of the providers listed in section 9 are established outside the EEA, or use sub-processors that are, principally in the United States. Where personal data is transferred outside the EEA we rely on one or more of the following safeguards under Chapter V GDPR:

• an adequacy decision of the European Commission for the country concerned;
• the European Commission's Standard Contractual Clauses, supplemented where necessary by additional technical and organisational measures identified in a transfer impact assessment;
• the EU-US Data Privacy Framework, where the recipient is certified under it.

You may request a copy of the relevant safeguards by writing to privacy@foxio.eu.

We keep personal data only as long as we need it for the purpose it was collected for, or as long as the law requires.

When you delete your account we delete or irreversibly anonymise your personal data, except records we are legally required to keep - principally invoices and accounting records, which are retained for the statutory period and are not used for any other purpose.

Under the GDPR you have the following rights. They apply to your own data, and you may exercise them on behalf of your child.

Access (Article 15)

Obtain confirmation of whether we process your data, a copy of it, and information about how it is used.

Rectification (Article 16)

Correct data that is inaccurate or incomplete. Most account and child profile data can be corrected directly in your profile.

Erasure (Article 17)

Have your data deleted where there is no overriding reason for us to keep it. You can delete your account yourself from your profile.

Restriction (Article 18)

Ask us to stop using your data while a dispute about its accuracy or our legal basis is resolved.

Portability (Article 20)

Receive the data you provided to us in a structured, commonly used, machine-readable format, and have it sent to another controller where technically feasible.

Objection (Article 21)

Object at any time to processing based on our legitimate interests, and object absolutely to direct marketing.

Withdraw consent (Article 7(3))

Withdraw any consent you have given - for marketing, analytics cookies or photo uploads - at any time. Withdrawal does not affect processing that already happened.

Automated decisions (Article 22)

Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects. See section 13.

To exercise a right, write to privacy@foxio.eu. We answer within one month. If a request is complex we may extend this by a further two months and will tell you why within the first month. Exercising your rights is free; we may charge a reasonable fee, or refuse, only where a request is manifestly unfounded or excessive.

We may need to verify your identity before acting, so that we do not disclose a family's data to the wrong person.

We do not make decisions with legal or similarly significant effects about you by automated means alone.

We do use automation in two ways that are worth naming plainly:

• Content adaptation. Difficulty, recommendations and story themes are adjusted automatically from your child's age, interests and results. This affects what appears on screen and nothing else.
• Safety classification. An automated classifier decides whether an assistant message is unsafe, and can block an answer and raise a flag. A wrongly blocked message has no consequence beyond that answer not being given; you can see the flag in your dashboard and write to us if you think it was wrong.

Payment fraud checks are performed by Stripe as part of its own service; Stripe describes them in its privacy policy.

• All traffic to and from foxio.eu is encrypted in transit with TLS, and data is encrypted at rest by our infrastructure providers.
• Passwords are never stored in readable form; our authentication provider stores only a salted hash.
• Database access is governed by row-level security, so one family's records are technically unreachable from another family's session rather than merely hidden by the interface.
• Uploaded photographs and generated books live in a private storage bucket that is not publicly addressable and is served only through short-lived signed links.
• Access by our staff is limited to those who need it to operate and support the service.
• We keep our platform and dependencies patched, and we review our security configuration regularly.

No online service can promise perfect security. If a personal data breach is likely to result in a risk to your rights, we will notify the supervisory authority within 72 hours and, where the risk is high, notify you without undue delay.

We send service emails - confirmations, password resets, safety alerts, order updates and notices about changes to these documents - because they are necessary to provide the service. You cannot unsubscribe from these while you hold an account.

We send marketing emails and newsletters only if you have asked for them. Every such message contains a one-click unsubscribe link, and you can also withdraw consent by writing to us. Unsubscribing does not affect your account.

We use a small number of strictly necessary cookies to keep you signed in and to remember your language, and we ask for your consent before loading anything else. Your browser also stores a little data locally for things like game progress and sound settings.

Every cookie and storage item we use is listed, with its purpose and lifetime, in the Cookie Policy. You can change your choices at any time from the "Cookie settings" link in the footer.

We update this policy when our processing changes or the law does. Every version carries a version number and an effective date at the top of the page.

For minor clarifications we simply publish the new version. For changes that materially affect your rights or how we use your data, we will notify account holders by email at least 30 days before the change takes effect.

Please come to us first - most issues are resolved quickly. Write to privacy@foxio.eu.

You also have the right to lodge a complaint with a data protection supervisory authority, in the EU Member State of your habitual residence or place of work, or where you believe an infringement occurred. Our lead supervisory authority is:

You may also bring a claim before the competent court, either where we are established or where you live.