Privacy Policy

Privacy and cookies policy (“cookies”)

Last updated: June 9 2025

Applies to: the Kouloo mobile application, https://www.kouloo.com and https://portail.kouloo.com

About this Policy

This Privacy Policy explains how Nuxovia Solutions Inc., doing business as “Kouloo” (“Kouloo”, “we”, “us”, “our”), collects, uses, discloses, retains, and protects Personal Information when you use our mobile application and website. It fulfills transparency and disclosure requirements when Personal Information is collected by technological means and must be written in clear, simple terms.

Definitions

For the purposes of this Policy:

“Personal Information” means any information relating to an identifiable individual.
“Processing” refers to any operation performed on Personal Information, such as collection, use, disclosure, storage, or deletion.
“Child” means a minor under the age of 14, as defined under applicable Quebec law.
“Consent” means freely given, specific, informed, and unambiguous agreement to the processing of Personal Information.

1) Identity of the organization and Privacy Officer

Organization: Nuxovia Solutions Inc.
Registered address: 3, rue de Sannois, Terrebonne (Québec) J6W 0B2, Canada
Privacy Officer (Loi 25): Andre Claude Chagnon, President
Contact: legal@nuxovia.com | 1-888-918-0144

Kouloo designates a Privacy Officer and publishes their contact details. The Privacy Officer oversees governance of Personal Information and can be reached for any privacy request or complaint.

2) What we collect

We collect the following categories of Personal Information from account creation and app/website use:

Account & authentication: username, password, email.
Profile: first/last name, mobile phone, profile photo (optional), child links/relationships.
Children’s information (provided by a parent/guardian): child’s first/last name, childcare service name and group, photo.
Device & app data (automatic): timestamps, IP address, OS/platform, model, version, language, app version, approximate or precise location (if enabled), crash/diagnostics.
Cookies, SDKs and similar technologies: identifiers, analytics events, preferences (see Section 9).

We limit collection to what is necessary for stated purposes and avoid collecting sensitive data unless required and consented to.
We take reasonable steps to ensure that Personal Information is accurate, complete, and up to date, and we encourage users to update their information regularly.

3) Purposes and legal bases (why we collect)

We use Personal Information to:

Open and manage accounts; authenticate users.
Verify identity/relationship with childcare providers and validate child enrollment.
Provide core features (pickup coordination, preferences such as transportation mode, notifications).
Security, fraud and misuse prevention; logs and access controls.
Compliance with legal/regulatory obligations and to handle requests/complaints.
Service improvement (analytics, quality, performance).

We obtain free, informed, specific consent for each purpose that requires it, especially for geolocation, profiling, or identification/localization features.

For any new technology or processing activity that may present a high risk to privacy, Kouloo conducts a Privacy Impact Assessment (PIA) in accordance with Loi 25.

4) Mobile permissions and features

We request OS level permissions only when needed and you can change them in device settings:

Location (foreground/background): to enable location based features (e.g., arrival estimates, check in), disabled by default; precise/approximate location is configurable.
Camera/Photos (optional): for profile/child photos.
Push notifications: operational alerts and updates (opt in via OS).

We present a just in time notice stating the purpose before each permission prompt.

5) Consent management

Explicit, granular consent is obtained for each purpose beyond what is strictly necessary to deliver the requested service.
You can withdraw consent at any time via in app settings or by contacting us.
Children’s data: Accounts are intended for adults/guardians. Where a minor’s information is involved, we rely on parental/guardian consent and will take steps to verify authority before processing the child’s data.

We do not knowingly allow children to create accounts. All child-related data must be submitted by a verified parent or guardian. We apply heightened safeguards to children’s data, including limited access, encryption, and restricted sharing.

6) Your rights

Subject to applicable law, you have rights to:

Access and rectify your Personal Information.
Withdraw consent to processing for optional purposes.
Data portability (receive a structured copy of certain data), implemented pursuant to Loi 25 timelines.
Cessation of dissemination/de indexation in applicable contexts.
Complaint to Kouloo’s Privacy Officer and, if unresolved, to the Commission d’accès à l’information.

We provide simple mechanisms in app or via email to exercise these rights.

7) Retention and deletion

We retain Personal Information only for the time necessary to fulfill the stated purposes, then securely delete or anonymize it according to our retention schedule. After account closure, limited data may be retained for backup, audit, and compliance for a commercially reasonable period, then deleted/anonymized. Retention periods and criteria are available on request.

8) Security

We apply administrative, technical, and physical safeguards proportionate to risks, such as encryption in transit/at rest, role based access, privileged account management, firewalls, secure key management, and secure disposal (shredding/wiping). No method is 100% secure, but we use commercially acceptable means and risk based controls.

9) Cookies, SDKs and similar technologies

Website cookies: We use necessary cookies and, with consent, analytics/functional cookies. Browser settings allow you to refuse non essential cookies; refusal may affect some features.
Mobile SDKs/identifiers: With consent, we may use [e.g., Firebase Analytics, Crashlytics, Map SDKs] to measure usage, diagnostics, and deliver features. You can opt out of analytics in Settings → Privacy.

We provide clear information and obtain consent for profiling or tracking technologies where required.

10) Third party service providers

We engage vetted processors to host data, deliver app functions, and support. They access Personal Information only to perform agreed services under contractual confidentiality and security obligations.

We do not sell or share Personal Information with third parties for marketing or advertising purposes. Any sharing is strictly limited to service providers under contractual obligations.

11) International transfers

Kouloo stores and processes data in Canada. If we transfer Personal Information outside Canada, we will first assess privacy risks (legal framework, safeguards), implement appropriate contractual protections, and inform you of such transfers as required by law.

12) Automated decision making & profiling

If we introduce features that significantly impact you based on automated processing or profiling, we will: (i) inform you of the decision making logic; (ii) obtain consent where required; and (iii) provide a way to contest or request human review.

13) Incident management and breach notification

We maintain an incident register and a process to assess and contain privacy incidents. Where an incident presents a risk of serious injury, we will notify the CAI and the affected individuals and take reasonable steps to reduce risks.

14) Changes to this Policy

We may update this Policy periodically. We will announce material changes in app and/or on our website before they take effect and update the effective date at the top.

15) Contact

Privacy Officer — Andre Claude Chagnon
Email: legal@nuxovia.com
Mail: Solutions Nuxovia Inc., Attn: Legal Affairs, 3, rue de Sannois, Terrebonne (Québec) J6W 0B2, Canada

This Privacy Policy is available in both English and French. In case of discrepancies, the French version shall prevail for Quebec residents.