1. Scope of this policy
This policy covers PokoClub, Nyo & Cie and the services needed to run them on iOS and Android. It supplements information shown when permissions and consent are requested. It does not replace the separate policy for ordering a plush toy on the website.
2. Use is supervised by a parent
An authorised adult creates the account and profiles, selects features and links the child app. Sensitive Nyo & Cie settings are protected by a parental gate. The child app does not offer purchases or advertising.
We request the parental consent required for AI processing on a separate screen. If you believe a profile was created without permission, contact us to request suspension and deletion following verification. Children can exercise their rights with help from their legal representative.
3. Data we process
We do not ask for a child’s surname, full date of birth, address, school, phone number or email in their profile. Open-ended conversations may nevertheless contain personal information: avoid adding intimate or unnecessary details.
An internal identifier does not make data anonymous. Summaries and inferred preferences remain personal data and may be inaccurate. They are not a medical assessment.
The microphone is used for authorised voice features. The camera may be used to scan a pairing QR code; images and documents shared with AI are processed when the relevant feature is used and authorised. The app does not scan your entire photo library. We do not collect precise location, address books or advertising identifiers.
| Category | Examples and source |
|---|---|
| Parent account | Name, email address, internal identifiers, sign-in method, agreement statuses and dates. Provided by you or your sign-in provider. |
| Child profile | First name, age, optional sex, avatar, interests, relationship to the adult, preferences and settings. Entered by the parent. |
| Conversations and memory | Messages, audio, transcripts, summaries, memories and context used in responses. Generated through activities and settings. |
| Creations and files | Stories, songs, images, books, prompts and files you choose to provide, including images or documents for permitted features. |
| Activity and security | Usage time, security events, technical identifiers, network information and logs needed for diagnostics and protection. |
| Notifications and support | Notification tokens, preferences, support requests and replies. |
| Purchases | Product, transaction ID, status, relevant dates, usage-unit balance and history. We do not receive the card number used in the store. |
4. Purposes and legal bases
You can withdraw consent without affecting the lawfulness of processing already carried out. The consequences are limited to features requiring the processing concerned. Where the legal conditions are met, you can object to processing based on legitimate interests.
| Purpose | Legal basis |
|---|---|
| Creating an account and providing features requested by the parent | Performance of the contract with the adult account holder, for processing necessary to deliver that service. |
| Personalisation and processing conversations through AI providers | Consent obtained through the relevant flow where required; delivery of expressly requested features in other applicable cases. |
| Billing, tracking access rights and accounting records | Performance of the contract and legal obligations. |
| Security and prevention of fraud and abuse | Legitimate interests in protecting accounts and children; legal obligations where applicable. |
| Support, service emails and requested notifications | Delivery of the service; consent where required for the communication involved. |
| Handling rights requests and legal requests | Legal obligations; defence of legal rights where necessary. |
5. Recipients and service providers
Access is limited to authorised people and providers, according to the feature used and the data needed for their task. AI providers that may be involved are Google Cloud Platform, OpenAI, Mistral AI and RunPod. The detailed list also identifies hosting, storage, communication and security providers.
Not all content is sent to every provider. Apple and Google also provide sign-in, app store and notification services, depending on their respective responsibilities.
We do not authorise the sale of this data or its use for advertising. Technical retention, abuse prevention and a provider’s processing arrangements depend on the service and applicable contractual safeguards. Sending content to an AI does not mean it is erased immediately after each response.
Strictly necessary data may be disclosed to an authority as required by law, or to an adviser to defend legal rights, after the request has been reviewed.
6. International transfers
Providers may process data outside the European Economic Area. Safeguards depend on the recipient and service: an applicable adequacy decision or standard contractual clauses accompanied by any necessary supplementary measures. The EU–US framework applies only to recipients that are actually certified and to processing covered by that certification.
You can request information about recipients and processing locations, and a copy of the safeguards applicable to your situation, by contacting the data controller, subject to third-party confidential information.
7. Retention and deletion
Account deletion covers associated active data, subject to records that must be retained by law. Backup copies may remain until they are rotated out, with restricted access. Provider retention periods may differ from those of our active database. We do not promise immediate erasure of every technical copy.
| Data | Retention period or criterion |
|---|---|
| Conversation text | Text is purged from conversations inactive for 30 days. An ongoing conversation may retain older messages. |
| Titles, summaries and memory | Stored separately from messages until the relevant deletion, or deletion of the profile or account. Purging messages does not erase these records. |
| Profiles, settings and creations | For the lifetime of the account or profile, until the relevant deletion. Files stored on your device may need to be deleted locally. |
| Transient audio | For the time needed to process the feature, subject to applicable provider retention; library audio is retained as a creation. |
| Session and notification tokens | Until expiry, invalidation or deletion, depending on their purpose. |
| Support, diagnostics and security | For the time needed to resolve issues, maintain security and defend legal rights, depending on the incident’s nature and severity. |
| Billing and necessary evidence | For the period required by legal obligations and applicable time limits for defending legal rights. |
8. Security and automated decisions
The apps use encrypted connections, secure token storage and access controls for accounts and households. Authorised people and systems may process content to provide the service: this is not end-to-end encryption.
Safety controls may block a request or content. You can ask support to review a decision. Summaries, memories and safety signals are not medical decisions or reliable assessments of a child. No security system eliminates every risk.
9. Your rights and contact
Subject to applicable conditions, you have rights of access, rectification, erasure, portability, restriction, objection and withdrawal of consent. You may also give instructions about your data after your death where French law provides for this.
Email hello@pokoplush.fr, preferably from your account’s email address. Proportionate verification of identity and authority over the profile may be needed. We normally respond within one month; a justified extension is possible under the applicable legal conditions.
You may lodge a complaint with the CNIL, the French data protection authority, or the competent authority in your country. Mandatory rights applicable in your country of residence remain protected.
10. Tracking and changes to this policy
The apps contain no advertising or advertising tracking across apps or websites. This legal centre does not activate the shop website’s advertising trackers. Technical logs needed to deliver and secure these pages are separate from advertising tracking.
This policy is dated. Important changes are communicated where required. If a change requires fresh consent, updating this document alone does not replace obtaining that consent.