Privacy Policy

Effective Date: October 21, 2026 Last Updated: October 21, 2026 Version: 2026-10-21 (supersedes 2026-10-20)

What changed in version 2026-10-21. This version adds a section for Koydo Homeschool, where a parent or guardian creates the account and adds each child as a learner profile (see Koydo Homeschool). It says what we collect about learners, who can see it, how long we keep it, and how a parent can review, export and delete it. It also adds how long PRISM session snapshots are kept: the daily cleanup is scheduled to delete them once they are 30 days old. Nothing changes in how Koydo handles information for any other product or account.

What changed in version 2026-10-20. This version describes optional page-view counting for signed-out visitors on a few pages addressed to adults (home, pricing, sign-in and billing), which happens only if the visitor accepts optional analytics in the cookie banner (see Sections 2.5, 4.1 and 7). It is not switched on yet. Before it is, we will give the notice described in the Terms of Service (Section 12).

What changed in version 2026-10-19. This version adds a section for Anvil, our mobile app testing product for development teams (see Anvil). Correction on October 20, 2026: An earlier version of the table in Section 7 said "DPA executed March 19, 2026" for OpenAI. That agreement names our founder, not KOYDO LLC, as the customer. A data processing agreement between KOYDO LLC and OpenAI took effect on October 20, 2026; the transfers page describes its transfer terms. Koydo sends requests to OpenAI's US service and does not use OpenAI's EU data residency. See the correction notes on the sub-processor page and the transfer page. This correction does not add new collection or sharing.

What changed in version 2026-10-16. This version rewrites the AI help part of the Koydo Matura (Polska) section for the version of the app that offers AI help. It describes what the app sends, to whom (Google Firebase, Koydo's AI gateway on Supabase, and OpenAI), the consent and 16+ statement that come first, what is and is not kept and for how long, and how to withdraw consent. It removes Google (Gemini) from the Matura AI recipients, because the app does not use it, and adds Supabase and OpenAI to the Matura recipient list. This note describes the changes to the Matura AI-help text.

What changed in version 2026-10-15.2. This version updates one sentence in the Tester Feedback section: the Doozle survey is switched off with no parent-approval flow available today, and Doozle testers can reply to their invitation email instead. Nothing else changes.

What changed in version 2026-10-15.1. This version adds an optional section for grown-ups who help us test Doozle and Koydo Homeschool (see Tester Feedback). Nothing changes in how Koydo handles information for any other product or account.

What changed in version 2026-10-15. This version adds a section for Koydo Matura, our Polish-language mobile app for matura preparation (see Koydo Matura (Polska)), written in Polish first with an English summary, and adds Google (Firebase) to the list of processors in section 7. Nothing changes in what we collect, how we use it, or who we share it with for any other Koydo product or account.

What changed in version 2026-10-14.2. This version corrects the wording about our AI providers and voice features, and updates the Koydo Life section. First, it removes statements that OpenAI, Anthropic and Google work under "zero data retention". What a provider keeps depends on the service, its terms and the account settings: standard commercial API terms may allow limited retention for safety or to run the service, and we claim zero retention only when current evidence supports it. It also removes the statement that voice recordings are always "immediately discarded". A child's personal information can be sent to an AI provider only with a parent's separate consent and only while Koydo holds current evidence that the provider meets our requirements. As of this version, no AI feature that sends children's personal information to a provider is switched on, and a parent's earlier AI disclosure consent does not cover a feature that is switched on for children later. Second, the Koydo Life section now describes the "Not now" choice on the health data permission screen and the limited screen that follows it.

What changed on October 14, 2026. This version adds a section for Koydo Life, our nutrition, fitness and health-context app for adults 18 and older (see Koydo Life). Nothing changes in what we collect, how we use it, or who we share it with for any other Koydo product or account.

What changed on October 2, 2026. This version corrects how this policy describes several things Koydo already does. Nothing changes in what we collect, how we use it, or who we share it with. The corrections cover how the parent card check works (a 50¢ charge that we refund in full), when optional analytics can run, how deletion and withdrawing consent work, what our error reports contain, which cookies we use, that Daily.co video and Mixpanel analytics are switched off, and what Cloudflare does for us. Four of these corrections may matter to you:

• Deleting an adult or teen account in the Koydo web app starts a 30-day period in which you can cancel the request, so a mistaken deletion can be undone. In Koydo's mobile apps, deletion is final once the app confirms it. The old text said deletion finished within 14 days.
• When a parent withdraws consent, new collection stops right away, but a sign-in that was already active can keep working for up to one hour before it expires. The old text said your child's account was deactivated immediately.
• After an account is deleted, copies in our rotating backups and security logs are kept until those backups expire on their normal schedule. They are not returned to normal use. The old text said all personal data was permanently deleted within 14 days.
• If you visit without signing in, we can't check your age, so optional analytics run only if you choose adult mode and agree to analytics. The old text said analytics loaded by default outside the EEA, UK and Switzerland.

The full policy below is the authoritative document; this summary is provided in plain language for accessibility.

What we collect. Account info (display name, age, grade), learning progress (lesson completion, scores, skill mastery), how you interact with activities (signals like time spent, retries, content choices), and — only with your explicit opt-in — additional behavioral signals used by our adaptive learning engine PRISM to personalize the learning experience. When pronunciation features are available, short voice clips may be sent to an approved provider for real-time analysis. Koydo does not keep the source recording after processing.

What we do NOT do.

• We do not run advertising. Ever.
• We do not sell or share your personal information for cross-context behavioral advertising.
• We do not use your child's work or conversations to train AI models.
• We do not profile your child for non-educational purposes.
• We do not keep voice recordings.

Tablefort party games. No account and no sign-in; room data is deleted within 2 hours. See Tablefort.

Your rights. You can access, correct, export (machine-readable JSON), and delete your data anytime. Parents of children under 13 can review the child's information, delete it, export it, disable Koydo Intelligence, and revoke consent. California residents have additional CPRA rights (limit use of sensitive personal information, opt out of profiling/automated decisions, learn about automated decision-making logic). EEA, UK, and Swiss users have full GDPR rights including access, rectification, erasure, portability, restriction, and objection.

How to delete your stuff. Adults: Account Settings → Delete Account. Teens (13–17): Account Settings → Delete Account. Parents: Parent Dashboard → Manage Child's Data → Delete All Data. Schools: contact privacy@koydo.app — we delete within 30 days. Koydo deletes its own records and requests or performs provider-side deletion where the provider stores an addressable record.

Who decides what we do with data. Koydo's Privacy Officer at privacy@koydo.app. EEA users may also contact our EU Article 27 representative listed at the international transfer notice.

For more detail on any of the above, the full policy follows.

KOYDO LLC ("Koydo," "we," "us," or "our") operates the Koydo educational platform, including the Koydo website, Koydo mobile applications (Koydo Jr., Koydo Kids, Koydo Learn, Koydo Academy), the Koydo Distill notes application, and Tablefort, our party games for your TV (collectively, the "Service"). This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you use our Service.

We take the privacy of all users seriously, and we take the privacy of children extremely seriously. This policy is written in plain language so that parents, students, teachers, and all users can understand our data practices.

If you have questions about this policy, contact us at privacy@koydo.app.

Table of Contents

1. Definitions
2. Children Under 13 (COPPA)
3. Students Age 13-17
4. Adults 18+
5. Koydo Distill (Notes App)
6. Koydo Intelligence (KI) and the PRISM System
7. Third-Party Data Processors
8. Data Retention
9. Data Security
10. Your Rights
11. International Users and Cross-Border Transfers
12. Changes to This Policy
13. How to Contact Us

See also: Tablefort (party games on your TV) · Koydo Life (nutrition and fitness, for adults) · Anvil (mobile app testing) · Koydo Matura (aplikacja do matury, po polsku) · Tester Feedback (Doozle and Koydo Homeschool) · Koydo Homeschool (parent-managed learners)

• Child or Children: Users under the age of 13.
• Teen: Users between the ages of 13 and 17, inclusive.
• Adult: Users 18 years of age or older.
• Parent: A parent or legal guardian of a Child or Teen user.
• Koydo Intelligence or KI: Our optional adaptive learning system that uses behavioral signals to personalize the learning experience. KI is powered by the PRISM system described in Section 6.
• PRISM: Prismatic Learning Intelligence Signal Model, our behavioral signal analysis system that observes how a learner interacts with the platform in order to adapt content difficulty, pacing, and presentation style.
• Student Profile: A profile created by a Parent for a Child or Teen user.

This section applies to users under the age of 13. Koydo is designed to comply with the Children's Online Privacy Protection Act ("COPPA"), 15 U.S.C. 6501-6506, and the Federal Trade Commission's implementing rule at 16 C.F.R. Part 312, including amendments effective June 23, 2025, with a general compliance date of April 22, 2026. Those amendments expand the definition of personal information to include biometric identifiers that can recognize an individual and add protections concerning disclosure, security, retention, and deletion.

Koydo Homeschool works differently, because only parents and guardians have accounts there; it is described in its own section, Koydo Homeschool (parent-managed learners).

2.1 Parental Consent Is Required

We do not knowingly collect personal information from children under 13 without first obtaining verifiable parental consent. Before a child can use any feature of Koydo that involves the collection of personal information, a parent must:

1. Create a parent account and add the child as a Student Profile.
2. Provide the child's birth date (used solely to determine applicable age protections).
3. Review a consent notice describing our data practices.
4. Verify consent through our Verifiable Parental Consent (VPC) process. By default this is an email confirmation sent to the parent's verified email address, containing a summary of data practices and a signed confirmation link. Where a higher-assurance method is appropriate, Koydo instead uses the payment-card method at 16 C.F.R. § 312.5(b)(2)(ii): a $0.50 charge to a parent-owned card that is refunded in full immediately after the payment is confirmed. The parent may see both the charge and the refund on their statement; Koydo retains none of it. Signed consent form, government-issued ID check, and video-conference verification are available on request to privacy@koydo.app.

Tablefort is the one exception. It has no accounts, and anyone who chooses an age group of 13 or under picks a nickname from our list instead of typing one. The only other information (their age group, their answers, scores and game settings, and the technical data that connects their phone) is used only to run the game and is deleted within hours. So we don't collect personal information from them that needs a parent's consent. See the Tablefort section.

A child's participation in Koydo is never conditioned on the disclosure of more personal information than is reasonably necessary to participate in the Service.

2.2 Information We Collect from Children (Default Mode)

When a parent provides consent, we collect the following information in default mode (without Koydo Intelligence enabled):

We do NOT collect the following from children under 13:

• Email addresses belonging to the child
• Precise geolocation
• Photographs or videos stored on our servers
• Persistent source audio recordings on Koydo servers after voice processing is complete
• Social media identifiers
• Advertising identifiers or persistent tracking identifiers
• Any data for behavioral advertising

2.3 Information Collected When Koydo Intelligence Is Enabled (OptIn)

Koydo Intelligence ("KI") is an optional feature that parents may enable or disable at any time. When KI is enabled, we collect additional behavioral signals through our PRISM system to provide an adaptive, personalized learning experience. These signals are described in full in Section 6 of this policy.

KI is off by default for children under 13. A parent must affirmatively opt in to KI, and the parent is presented with a separate, specific disclosure of what KI collects before enabling it. The parent may disable KI at any time from the Parent Dashboard, and once KI is disabled, we stop collecting PRISM signals. Raw PRISM signal events are deleted automatically once they are 90 days old, and session snapshots are scheduled for deletion by the daily cleanup once they are 30 days old, unless a legal hold applies.

2.4 How We Use Children's Information

We use information collected from children exclusively for the following purposes:

• Providing the educational service: Delivering lessons, quizzes, games, and learning activities appropriate to the child's age and skill level.
• Tracking learning progress: Generating progress reports visible to the child and parent.
• Adaptive learning (KI only): When KI is enabled, adjusting content difficulty, pacing, modality, and presentation based on the child's observed learning patterns.
• Safety and moderation: Monitoring AI-assisted interactions for safety and content policy compliance.
• Service improvement: Analyzing aggregated, de-identified usage patterns to improve our educational content and platform. No child's data is individually identifiable in these analyses.

We do NOT use children's information for:

• Behavioral advertising or targeted advertising of any kind
• Sale to third parties
• Creating public profiles or social networking features
• Any purpose unrelated to the educational service

2.5 Disclosure of Children's Information

We do not sell children's personal information. We do not disclose children's personal information to third parties except as follows:

• Service providers (with separate parental consent for AI disclosure): Certain AI features may use OpenAI, Anthropic, or Google Gemini. Separate parental consent is necessary but not sufficient: Koydo's child-safe router also requires current private evidence of contract coverage, provider data-use terms, retention controls, and matching account settings. If no provider passes that review, the child-facing AI feature is unavailable rather than routed to an unverified provider.
• Content-generation providers that do not receive child personal data: ElevenLabs may render approved Koydo-authored lesson narration, and fal.ai may generate staff-authored creative assets. These flows do not include a child's account data, conversation, uploaded audio, or other child personal information.
• Infrastructure providers (no separate consent required — essential to service operation):
• Supabase — Database hosting and authentication. Processes account and learning data as essential infrastructure under applicable data-processing terms.
• Sentry — Error monitoring. Receives minimized crash metadata only. Koydo removes user identity, request data, learner content, breadcrumbs, custom context, and attachments before transmission for every user; automatic session tracking, session replay, and performance traces are disabled.
• Cloudflare — Runs the Tablefort game-room server. Holds Tablefort nicknames (children pick from a preset list), age groups, answers, scores and game settings only while a room is active, and deletes them automatically 2 hours after the room's last activity.
• Vercel — Hosts our web pages, including the Tablefort pages on your TV and phone. Sees the internet address of any device that loads a page, only to deliver it. (Vercel Analytics is covered below.)
• Providers that do NOT receive child data:
• Stripe and RevenueCat — Payment processing for adult account holders only.
• Mixpanel — Optional product analytics integration, disabled in the current linked web configuration. If enabled later, it requires a known adult active profile and analytics consent.
• Vercel Analytics — Optional web analytics; Vercel reports page-view results in aggregate. They are not loaded for active profiles known to be under 18, on websites or pages made for children or teens, or inside any learning area. On the few pages addressed to adults (the home page, pricing, sign-in and billing pages), a signed-out visitor is counted only after choosing "Accept" for optional analytics in the cookie banner. We do not verify the age of signed-out visitors, so a minor who visits one of those adult pages and accepts could be counted. Declining, ignoring the banner, "Do Not Sell or Share" and the parent opt-out keep analytics off, and if your browser sends a Global Privacy Control signal and you have not made a choice, analytics stay off. You can change your choice at any time with "Manage Cookies" in the footer.
• Legal requirements: We may disclose information when required by law, subpoena, court order, or government request.
• Safety: We may disclose information when we believe in good faith that disclosure is necessary to protect the safety of a child.

2.6 Parent Rights Under COPPA

If you are the parent or legal guardian of a child under 13 using Koydo, you have the right to:

1. Review your child's data: Access a complete summary of all personal information Koydo has collected from your child, available through the Parent Dashboard or by emailing privacy@koydo.app.
2. Delete your child's data: Request deletion of all personal information collected from your child. You may do this through the Parent Dashboard ("Manage Child's Data" > "Delete All Data") or by emailing privacy@koydo.app. The live account purge is scheduled within 14 days of your confirmed request. Restricted rotating backups and security logs expire on their provider schedules and are not returned to ordinary use.
3. Disable Koydo Intelligence: Turn off KI at any time from the Parent Dashboard. Once disabled, we stop collecting PRISM signals, and raw signal events are deleted automatically once they are 90 days old, and session snapshots are scheduled for deletion by the daily cleanup once they are 30 days old, unless a legal hold applies.
4. Export your child's data: Download a machine-readable (JSON) export of all data associated with your child's account from the Parent Dashboard.
5. Revoke consent entirely: Withdraw your consent for Koydo to collect personal information from your child. Koydo revokes refresh sessions and stops new collection; an already-issued access token can remain valid for up to one hour before it expires. After a 14-day grace period (during which you may reverse your decision), Koydo purges the live account. Restricted rotating backups and security logs then age out on their provider schedules.
6. Consent to collection without consenting to disclosure: You may consent to Koydo's collection and use of your child's information without consenting to disclosure to third parties. Note that declining disclosure to essential service providers may limit the availability of certain features (such as AI-powered tutoring, which requires an AI model provider).

To exercise any of these rights, visit the Parent Dashboard or contact us at privacy@koydo.app. We will verify your identity as the child's parent before fulfilling any request.

2.7 What Children Can Access Without Parental Consent

Before a parent provides consent, a child may browse Koydo's course catalog and read course descriptions, and play Tablefort party games, as described in the Tablefort section. These activities do not involve collecting personal information that needs a parent's consent. All other features that involve the collection of personal information are locked until parental consent is verified.

2.8 Separate Consent for ThirdParty AI Disclosure (COPPA Amended Rule)

Under the amended COPPA Rule, whose general compliance date was April 22, 2026, operators must obtain separate, specific parental consent before disclosing a child's personal information to third parties unless the disclosure is integral to the website or online service. This consent is distinct from consent for the operator's own collection and use.

Koydo implements this requirement as follows:

1. Two-part consent process: During the Verifiable Parental Consent flow, parents are presented with two distinct consent decisions:

• General consent: Consent for Koydo to collect and use the child's personal information as described in Sections 2.2 through 2.4 of this policy. This enables core platform features (lessons, quizzes, games, progress tracking) that do not involve third-party data disclosure.
• AI disclosure consent: Separate, specific consent for Koydo to transmit the child's personal information to an AI provider named in Section 2.5 for the purpose described at consent time. A provider must also pass Koydo's private evidence gate before the feature can send child personal data. Because consent applies to the disclosures made when it was given, a parent's earlier AI disclosure consent does not authorize a provider route that is enabled for children later; before enabling one, Koydo asks the parent again, based on this policy as then in effect.

2. Consent without disclosure: A parent may consent to Koydo's collection and use of the child's data (general consent) without consenting to third-party AI disclosure. In this case:

• The child can use all non-AI features: lessons, quizzes, games, flashcards, progress tracking, and all offline-capable learning content.
• AI-powered features (AI tutoring, pronunciation exercises, photo tutor, AI-generated content) will be unavailable.
• The parent may grant AI disclosure consent at any time from the Parent Dashboard.

3. Revocation: A parent may revoke AI disclosure consent at any time from the Parent Dashboard without affecting general consent. Upon revocation, AI features are immediately disabled for the child. Koydo deletes its own associated records and submits provider-side deletion where a provider stored an addressable record.
4. Named third parties: The providers eligible for private review are OpenAI, L.L.C., Anthropic, PBC, and Google LLC. Eligibility does not mean a provider is currently enabled for child personal data. Koydo enables a provider only after the contract and configuration evidence described above is current. If Koydo adds a new provider that may process child personal data, parents will be notified and new consent will be obtained before disclosure.
5. Voice/biometric data: A pronunciation feature that sends a child's recording to an external provider requires AI disclosure consent and a current provider evidence gate. Koydo does not keep the source recording after processing. Provider-side handling is governed by the specific approved service and settings disclosed at consent time; if those protections are not current, the feature remains unavailable.

COPPA's parental consent requirement applies to children under 13. For students between the ages of 13 and 17, the following applies:

3.1 Account Creation

Students age 13-17 may create their own Koydo account. During account creation, we collect:

• Email address
• Display name
• Birth date (to determine age group and applicable protections)
• Communication language preference

3.2 Parental Dashboard (Optional but Available)

Although parental consent is not legally required for users 13 and older under COPPA, we recognize that parents of teenagers may wish to monitor their child's educational progress. Parents may:

• Link their parent account to a teen's Koydo account (with the teen's approval)
• View learning progress and session activity
• Request data export or deletion on behalf of the teen (subject to the teen's confirmation for users 16 and older)
• Disable Koydo Intelligence for the teen's account

3.3 Data Collection for Teens

We collect the same categories of data from teen users as described in Section 2.2 (Default Mode), plus:

• Email address: The teen's own email address for account management and communications.
• AI tutor conversations: Text-based interactions with our AI tutoring system, retained for 90 days.
• Photo Tutor images: Homework photos submitted to the Photo Tutor, transmitted to the AI provider but not stored on Koydo servers. Available for users 13 and older.
• Social features: Direct messages, workspace participation, and social challenge participation, where the teen elects to use these features.
• Analytics: Mixpanel is disabled in the current linked web configuration and its optional code path blocks users under 18. No behavioral advertising identifiers are collected from teens.

3.4 Koydo Intelligence for Teens

KI is available to teens and may be enabled by the teen or their linked parent. The same PRISM signals described in Section 6 are collected when KI is enabled. Teens may disable KI at any time from their account settings.

3.5 Teen Rights

Teen users may:

• Access and review all data in their account
• Export their data in machine-readable format
• Delete their account and all associated data
• Enable or disable Koydo Intelligence
• Control social feature participation

4.1 Data Collection

Adult users (18 and older) provide and generate the following data:

• Account information: Email address, display name, birth date, communication language, billing state, avatar, theme and accessibility preferences.
• Learning data: All categories described in Section 2.2 (Default Mode), plus AI tutor conversations, Photo Tutor submissions, and social features.
• Koydo Intelligence: Available and may be enabled at any time. See Section 6 for details.
• Payment information: When subscribing or making purchases, payment is processed through Stripe. Koydo does not store credit card numbers, CVVs, or full payment card details. We store only a Stripe payment intent identifier and subscription status.
• Analytics: Mixpanel is currently disabled. If Koydo enables it later, it will require an eligible adult profile and analytics consent, and you may opt out through Settings or supported browser privacy signals.
• Web page-view data: If you accept optional analytics, Vercel Analytics counts page views, which we review in aggregate to understand page use. Vercel receives the timestamp, URL, referrer, query parameters (after filtering), geolocation (country, region and city), operating system and version, browser and version, and device type. It identifies a visitor with a hash created from the request and discards that session after 24 hours, and says it uses no third-party cookies. For signed-out visitors this covers only the home, pricing, sign-in and billing pages. We use it to find broken pages and to learn which pages help people decide. We do not use these analytics to target ads.

4.2 How We Use Adult Data

In addition to the educational purposes described in Section 2.4, adult data may be used for:

• Account management and billing
• Personalized content recommendations
• Platform analytics and improvement (with consent)
• Communications about account status, new features, and educational content (with opt-out available)
• Fraud prevention and security

4.3 Adult Rights

Adult users may exercise all rights described in Section 10 of this policy.

Koydo Distill is our notes and study companion application. It includes a voice recording feature for capturing lectures and study notes.

5.1 Voice Recordings

• Processing: When you record audio through Koydo Distill, the recording is transmitted to our AI provider for transcription. The audio is processed in real time and is not stored on Koydo's servers after transcription is complete.
• Transcripts: The text transcript generated from your recording is stored in your Koydo account and is accessible only to you (and your parent, if you are under 18 and a parent account is linked).
• No server-side audio storage: Koydo does not retain audio recordings on its servers. Audio is processed and discarded. If this practice changes in the future, we will update this policy and, for users under 13, re-obtain parental consent.
• AI provider processing: When transcription uses an external provider, Koydo uses a commercial API and does not opt in to provider model training. Provider-side retention varies by service and verified account setting; Koydo does not describe a flow as zero retention without current evidence for that exact service.
• Children under 13: Voice features for children under 13 require verified parental consent and a current provider evidence gate. If either is missing, external voice processing is unavailable.

5.2 Notes and Documents

• Notes, summaries, and study materials created in Koydo Distill are stored in your account and retained for the lifetime of your account.
• You may export or delete your notes at any time.

Party games on your TV

Tablefort needs no account and no sign-in. You play on your TV, and everyone joins on their own phone with a room code.

What we collect, and why

• A nickname. Anyone who chooses an age group of 13 or under picks one from our list, so they never type their own name. Players 14 and older type a one-word nickname. Please don't use your real name.
• An age group, so every player gets questions at their own level. If anyone who chooses an age group of 13 or under joins, the whole room plays in kids mode.
• Your answers, scores and game settings (such as your language) during the game.
• Your phone's internet address and a random seat code, only to connect you, let you rejoin your seat, and protect the game from abuse. We don't store your internet address with your room. To slow down abuse we use a scrambled version of it that is kept only briefly and never written down. The seat code works only for your room and ends with it.

We use this only to run the game. We never use it for ads or profiling, never link it to a Koydo account, never use it to contact you, and never sell it.

How long we keep it

Your room lives on our game server, which Cloudflare runs for us. Everything in the room is deleted automatically 2 hours after its last activity. Your phone's browser keeps your nickname, age group and seat code so you can rejoin quickly. You can clear them in your browser settings at any time.

The web pages that run the game on your TV and phone are hosted by Vercel, which sees your internet address when a page loads, as any website host does.

If something goes wrong

Tablefort may send an error report to Sentry, our error-monitoring provider. Reports contain no name and nothing you typed, we tell Sentry not to store your internet address, and reports are deleted within 90 days.

What Tablefort never has

No chat, no ads, no purchases, no analytics and no location, for every player in every round.

Children

Children can play Tablefort without a parent account because we don't collect personal information from them that needs a parent's consent. Anyone who chooses an age group of 13 or under picks a nickname from our list, and everything is deleted within hours.

Your choices

Because Tablefort has no accounts, we can't find a room's information after the game ends, and it's deleted within 2 hours anyway. While a room is open, the person using the TV can remove any player. For anything else, write to privacy@koydo.app.

Legal basis (EU and UK)

We rely on our legitimate interest in running the game you chose to play, keeping it secure and fixing crashes. We weighed that interest against every player's privacy, especially children's: we collect very little and delete it within hours. You can object at any time by writing to privacy@koydo.app.

Because we don't rely on consent for Tablefort, the parental-consent ages for online services described in Section 10.4 (Article 8 GDPR) don't apply to it.

Questions

Write to privacy@koydo.app.

Nutrition, fitness and health-context tracking, for adults 18 and older

Koydo Life is provided by KOYDO LLC. This section covers what Koydo Life handles and why. How we handle health information in particular is set out in more detail in Koydo Life's Consumer Health Data Privacy Policy. That page describes how we handle health information for everyone who uses Koydo Life, wherever they live, and it is also Koydo Life's consumer health data privacy policy for Washington and Nevada and explains how we handle consumer health data for people in Connecticut. Where this section and that page overlap, they say the same thing; where the page is more detailed, the detail applies.

What we collect, and why

• Your account. The email you sign in with, or your Apple or Google sign-in if you choose it, plus your language and time zone. We give your account a random ID.
• Your setup answers and profile. Age, sex, height, weight, activity level, your goal, and diet choices such as allergies or a halal or kosher diet, plus a display name. Some diet choices can reveal your religious or other beliefs, and our request for your explicit consent covers them too. We treat all of these, including your display name while it is linked to them, as health information. We ask for your explicit consent before we collect or process health information. We ask on a screen of its own, separate from our Terms and from sign-in, and nothing is ticked for you. You can choose Not now instead. Koydo Life then shows a limited screen where nothing is logged, saved or tracked: from there you can review and agree later, open support resources, read this policy, or delete your account. The tracking features need your consent, so they stay off until you agree.
• What you log. Meals, drinks, water, fasting, recipes, workouts and runs you record, medicines, check-ins and notes. This is what you type, say, scan or photograph in the app. Most of it is health information, and so is the data you allow from Apple Health, Health Connect or a connected service, so our request for your explicit consent covers all of it.
• Photos, voice and scans, only when you use those features. A meal or label photo, a voice recording, or a barcode. How each is handled, and how long it lasts, is in the health-data policy linked above.
• Health apps and connected services, only if you allow them. Apple Health, Health Connect, and services such as a smart ring or scale send us only the data types you allow.
• Your subscription status. The app stores and RevenueCat tell us whether you have a subscription. We never see your card.
• A short list of product events and diagnostics. For example, that the app started, that a meal was confirmed or that a screen was viewed. Events carry no name, email or content, and we count how often and how costly AI requests are, never what was in them.

We use this to run the features you use, keep your data in sync across your devices, answer your requests when you turn on AI help, share what you choose with the people you choose, keep Koydo Life secure and within usage limits, fix problems, and meet our legal obligations.

We never sell your information, never use health information for advertising or marketing, and never use it to profile you for ads. Koydo Life is not a medical device and doesn't diagnose or treat any condition.

Who receives it

We use a small number of service providers to run Koydo Life: Supabase hosts the database, sign-in and file storage in the United States; Cloudflare runs a clean-up job and delivers some files; OpenAI provides AI help, only when you turn AI help on, and it is our only AI provider; Apple and Google provide sign-in, payments and the health apps you connect; RevenueCat processes subscription status. A barcode number alone goes to Open Food Facts when our own food database doesn't know a product. The health-data policy lists each company, what it receives and how to contact it, and we keep that list current. Section 7 of this policy covers our third-party providers in general.

You can also choose to share with people: members of a Circle you join, someone you ask to look out for you in Care, or the one person you pick for live sharing. Sharing with people is always a separate choice you make.

How long we keep it, and how to delete it

We keep the information in your account for as long as you have a Koydo Life account, unless you delete something sooner, withdraw your health-data consent, or delete your account, as described here. Some things are kept for much less time: an entry you delete is erased from your account as soon as your phone syncs, AI answers are cached for about five minutes, a live-sharing position is deleted within an hour after sharing ends, and sleep and soreness numbers for the readiness check are not stored at all. In the app, go to Settings and choose Delete my account to delete it. That takes effect right away, erases your information from your account and your phone, and can't be undone. Copies in our backups are removed within 7 days. OpenAI may keep AI requests for up to 30 days to detect abuse, which we can't shorten.

You can also withdraw your health-data consent at any time in Settings without deleting your account. We then erase your health information from your account and your phone, keep your account, sign-in, subscription and your consent record, and ask for your consent again before saving anything new; if you choose Not now, you see the limited screen described above. Copies in our backups are removed within 7 days, and anything we already sent to OpenAI stays with OpenAI for up to 30 days, as described above.

Your choices and rights

In the app you can export your data (Settings, Export my data), correct most of what you've logged, turn off any single use such as AI help or connected services, and delete your account. For anything else, write to privacy@koydo.app from the address on your account. We offer these in-app choices to everyone, free of charge. Further legal rights depend on where you live. Section 10 of this policy describes your rights in more detail, including those that apply in California and in the EEA, the UK and Switzerland. If you live in California, the health information described here is sensitive personal information under California law. We use it only to provide the features you ask for, to keep Koydo Life secure and to meet our legal obligations, which are among the uses California law (Cal. Civ. Code § 1798.121 and its regulations) allows without offering a right to limit. If we ever use it for anything else, we will offer you that right first. If we turn down a request you can appeal by writing to privacy@koydo.app with "Appeal" in the subject line.

Children

Koydo Life is for adults 18 and older. It asks your age during setup and doesn't create a profile for anyone who says they are under 18. If we learn that a person under 18 has an account, we delete it.

Legal basis (EU and UK)

We process your account and logs, including your health information, because it is necessary to provide Koydo Life to you (Article 6(1)(b)). Because health information, including diet choices that can reveal your beliefs, is special-category data, we also rely on your explicit consent (Article 9(2)(a)), which you can withdraw at any time as described above. We keep Koydo Life secure and fix problems on the basis of our legitimate interest in doing so (Article 6(1)(f)), using only product events and diagnostics that carry no personal content. You can object to this at any time by writing to privacy@koydo.app. When you choose to share with people in a Circle, in Care or through live sharing, we do so because you asked us to (Article 6(1)(b)) and under your explicit consent (Article 9(2)(a)). Where the law requires it, we keep a record of your consent and of requests you make to us; these records contain no health information. Supabase stores our database, sign-in and file storage in the United States. When you turn on AI help, your request is sent to OpenAI in the United States. Section 11 explains the safeguards we use for transfers from the EEA, the UK and Switzerland.

Questions

Write to privacy@koydo.app.

Mobile app testing for development teams

Anvil is provided by KOYDO LLC. This section covers what Anvil handles and why.

What we collect, and why

• Account details. Your email address, name and organization, so you can sign in and so your team can share a workspace.
• Billing details. If Anvil offers a paid plan and you purchase it, Stripe processes your payment-card information. We may receive billing-related information from Stripe.
• Test-run information. The devices you register, when runs happen, the commands a run executes, and the files you upload or create during a run, such as screenshots, traces and replays.
• Usage and error information. How the dashboard is used, and error reports that help us fix problems.

We use this to run Anvil, which is the service you or your organization signed up for, to keep it secure, to fix problems, to keep the records the law requires and to answer your requests. We do not sell it. We keep this information while your organization has an Anvil account and for as long as we need it for those purposes. You can ask us to delete it sooner, as described below. For personal information in an organization's test runs or run files, we handle deletion requests as our Data Processing Agreement describes and as the organization instructs.

Who decides what happens to it

For account, billing and security information, KOYDO LLC decides why and how it is used. For personal information that an organization puts into its test runs or run files, the organization decides what goes in and is responsible for having the right to use it, and we handle it for the organization. Our Data Processing Agreement covers that handling.

Service providers and data storage

Anvil is built to use WorkOS for single sign-on, Stripe for payments, PostHog for product analytics, Sentry for error reports, and Cloudflare R2 for stored run files. Account and run records are stored in a PostgreSQL database. An organization can turn off product analytics for its workspace in the dashboard. Section 7 of this policy covers our service providers in general.

Your choices

To ask about your information or to have it deleted, write to anvil@koydo.app from the address on your account. Our Data Processing Agreement is available to read at any time. Section 10 of this policy describes your rights in more detail.

Aplikacja mobilna do przygotowania do matury, dla uczniów od 16 lat. W sprawach aplikacji Koydo Matura (com.koydo.matura) ta sekcja ma pierwszeństwo przed ogólnymi zapisami tej polityki. Tekst polski jest tekstem głównym; krótkie streszczenie po angielsku znajduje się na końcu sekcji.

Administrator

Administratorem danych osobowych w aplikacji Koydo Matura jest KOYDO LLC (Teksas, USA), 940 W. FM 544 #332, Wylie, TX 75098-5157. Kontakt w sprawach prywatności: privacy@koydo.app. Przedstawiciele w UE i Wielkiej Brytanii są wymienieni na stronie the international transfer notice.

Jakie dane przetwarzamy i po co

• Konto. Możesz logować się adresem e-mail, kontem Google lub Apple albo kluczem dostępu (passkey). Przetwarzamy adres e-mail, identyfikator użytkownika Firebase (Firebase UID) oraz, jeśli dostawca je przekaże, wyświetlaną nazwę. Dzięki temu Twoje postępy i subskrypcja przechodzą z Tobą na nowe urządzenie.
• Postępy w nauce. Informacje o ukończonych lekcjach i dzienne liczniki użycia, zapisane w Twoim koncie.
• Subskrypcja. RevenueCat otrzymuje Firebase UID jako identyfikator użytkownika aplikacji; RevenueCat i sklep (App Store lub Google Play) obsługują informacje o zakupie i przekazują nam status subskrypcji oraz potwierdzenie zakupu. Nie widzimy numeru Twojej karty.
• Dane techniczne. Firebase Authentication przetwarza adres IP i identyfikator aplikacji Firebase; Cloud Functions otrzymuje adres IP wywołującego, a na Androidzie także token FCM; Firebase Installations przetwarza identyfikator instalacji aplikacji. Nie używamy adresu IP do ustalania Twojej lokalizacji.
• Zgłoszenie do pomocy, tylko jeśli sam je wyślesz. Opis problemu, który wpisujesz, oraz podstawowe dane techniczne (wersja aplikacji i systemu, typ urządzenia, numer ekranu, kod błędu, stan połączenia, ostatnie zdarzenia w aplikacji oraz losowy identyfikator tej sesji aplikacji, niepowiązany z kontem). Zgłoszenie wysyłasz dopiero po obejrzeniu jego pełnej treści; dołączenie odwołania do konta jest Twoim wyborem.

Przetwarzamy te dane, aby świadczyć usługę (art. 6 ust. 1 lit. b RODO), dbać o bezpieczeństwo i zapobiegać nadużyciom (art. 6 ust. 1 lit. f) oraz wypełniać obowiązki prawne, w tym podatkowe i księgowe (art. 6 ust. 1 lit. c).

Czego nie robimy

Aplikacja nie zawiera reklam, nie śledzi Cię w innych aplikacjach ani na innych stronach, nie używa narzędzi analitycznych ani raportowania awarii, nie korzysta z Twojej lokalizacji, kontaktów, zdjęć, kamery ani mikrofonu i nie pyta o datę urodzenia. Nie sprzedajemy danych i nie udostępniamy ich do celów reklamowych.

Kto otrzymuje dane

• Google LLC (Firebase Authentication, Cloud Firestore i Cloud Functions): logowanie, zapis postępów i funkcje serwerowe. Cloud Firestore działa w regionie europe-central2 (Warszawa), a Cloud Functions w regionie europe-west3 (Frankfurt); Authentication jest usługą globalną.
• RevenueCat, Inc. (USA): weryfikacja zakupów i status subskrypcji.
• Apple i Google Play: zakupy oraz logowanie kontem Apple lub Google.
• Cloudflare, Inc. (sieć dostarczania treści i magazyn obiektów opisane w sekcji 7): aplikacja pobiera obrazy i nagrania prowadzącego z serwera multimediów Koydo (assets.koydo.app), więc Twój adres IP jest widoczny dla tej usługi, jak przy każdym pobraniu z internetu.
• Zespół pomocy Koydo: tylko wtedy, gdy wyślesz zgłoszenie.
• Supabase, Inc. (USA): bramka AI Koydo, tylko gdy korzystasz z pomocy AI po wyrażeniu zgody (zob. „Pomoc AI”).
• OpenAI, L.L.C. (USA): dostawca modelu AI, tylko gdy korzystasz z pomocy AI po wyrażeniu zgody (zob. „Pomoc AI”).

Pełna lista podmiotów przetwarzających znajduje się w tabeli w sekcji 7 oraz na stronie /legal/subprocessors. Przekazywanie danych poza Europejski Obszar Gospodarczy opisuje sekcja 11.

Pomoc AI

Pomoc AI jest dobrowolnym dodatkiem dla osób od 16 lat. Celem przetwarzania danych opisanych poniżej jest udzielenie pomocy AI, o którą prosisz: wyjaśnienia zadania, orientacyjnej oceny odpowiedzi pisemnej albo odpowiedzi korepetytora AI dotyczącej konkretnego zadania. Obejmuje szersze wyjaśnienie zadania („Wyjaśnij szerzej”), w planie Premium ocenę odpowiedzi pisemnej („Oceń z pomocą AI”), a w planie Premium AI rozmowę z korepetytorem AI o konkretnym zadaniu. Pozostałe funkcje aplikacji działają bez niej.

• Zgoda przed pierwszym użyciem. Zanim cokolwiek wyślemy, aplikacja pokazuje ekran „Pomoc AI i Twoje dane”, na którym wskazujemy odbiorców danych. Zgodę wyrażasz przyciskiem „Zgadzam się” po potwierdzeniu zdania „Mam co najmniej 16 lat.”. Nie pytamy o datę urodzenia. Bez zgody nic nie jest wysyłane do usługi AI. Podstawą przetwarzania treści Twojej prośby w celu udzielenia pomocy AI jest Twoja zgoda (art. 6 ust. 1 lit. a RODO). Możesz ją w każdej chwili wycofać w ustawieniach konta (Konto i ustawienia, wiersz „Zgoda na pomoc AI”, „Wycofaj zgodę”); wycofanie zgody nie wpływa na zgodność z prawem przetwarzania przed jej wycofaniem.
• Co wysyłamy. Treść zadania, Twoją odpowiedź lub pytanie oraz, w rozmowie z korepetytorem, kilka ostatnich wiadomości z tego zadania. Do żądania przekazywanego z Google Cloud Functions do bramki AI, a dalej do OpenAI, nie dołączamy danych profilu, takich jak imię, adres e-mail, numer telefonu ani identyfikator konta. Treść zadania oraz wpisana przez Ciebie odpowiedź, pytanie lub wiadomość są jednak wysyłane; jeśli wpiszesz w nich dane osobowe, mogą zostać przekazane do usługi AI. W wiadomościach do korepetytora przed wysłaniem ukrywamy adresy e-mail, numery telefonów i numery PESEL. Prosimy, nie wpisuj danych osobowych w odpowiedziach, pytaniach ani wiadomościach.
• Kto przetwarza te dane. Prośba trafia z aplikacji do Google (Firebase Cloud Functions, region europe-west3, Frankfurt), stamtąd do bramki AI Koydo działającej na infrastrukturze Supabase, Inc. (USA), a z bramki do dostawcy modelu: OpenAI, L.L.C. (USA). Podmioty te przetwarzają dane w naszym imieniu; Dane pomocy AI mogą być przetwarzane poza Europejskim Obszarem Gospodarczym, w tym w USA; podstawy takiego przekazania opisuje sekcja 11.
• Jak długo. Rozmów z korepetytorem, wyjaśnień ani ocen AI nie zapisujemy na Twoim koncie Koydo Matura. Osobno, aby rozliczać koszty usług AI i dbać o działanie usługi (nasz prawnie uzasadniony interes, art. 6 ust. 1 lit. f RODO), zapisujemy o każdym wywołaniu tylko dane techniczne, bez treści zadania i odpowiedzi oraz bez identyfikatora konta. Dzienniki naszych funkcji serwerowych w Google Cloud (m.in. rodzaj odpowiedzi, szacowany koszt, status i czas odpowiedzi) są usuwane po 30 dniach. Bramka AI Koydo zapisuje m.in. nazwę aplikacji, model, liczbę tokenów, koszt i status; nie zawierają treści, identyfikatora konta ani adresu IP. Te zapisy kosztów przechowujemy jako dokumentację rozliczeń i zobowiązujemy się przechowywać je nie dłużej niż 7 lat; najstarsze z nich pochodzą z 2026 r., a automatyczne usuwanie po 7 latach wdrożymy, zanim którykolwiek zapis osiągnie ten wiek. Zgodnie z warunkami API OpenAI dane przesyłane przez API nie są używane do trenowania modeli OpenAI, a w dziennikach służących wykrywaniu nadużyć są przechowywane do 30 dni, chyba że dłuższe przechowywanie jest wymagane przez prawo lub jest rozsądnie konieczne do ochrony usług OpenAI albo osób trzecich przed szkodą. Na Twoim koncie zapisujemy tylko informację o zgodzie (czy i kiedy jej udzielono, w jakiej wersji tekstu oraz potwierdzenie wieku 16+), abyśmy mogli wykazać, że zgoda została udzielona (art. 6 ust. 1 lit. c w związku z art. 7 ust. 1 RODO), oraz dzienne liczniki użycia, aby stosować dzienne limity Twojego planu (art. 6 ust. 1 lit. b RODO); usuwamy je razem z kontem.
• Ocena AI. Wyjaśnienia i oceny AI mogą zawierać błędy. Ocena AI jest orientacyjna i służy wyłącznie nauce: nie jest wynikiem egzaminu CKE i nie podejmujemy na jej podstawie decyzji, które wywołują wobec Ciebie skutki prawne lub w podobny sposób istotnie na Ciebie wpływają.
• Zgłaszanie odpowiedzi AI. Pod każdą odpowiedzią AI jest przycisk „Zgłoś odpowiedź AI”. Otwiera on zgłoszenie do pomocy opisane wyżej; wysyłasz je dopiero po obejrzeniu jego treści.

Jak długo przechowujemy dane i jak je usunąć

Dane konta i postępów przechowujemy, dopóki masz konto. Konto usuniesz w aplikacji (Konto i ustawienia, „Usuń konto”) albo na stronie koydo.app/delete-account. Usuwamy wtedy konto Firebase, dane nauki i liczniki użycia, klucze dostępu oraz klienta w RevenueCat. Usunięcie konta nie anuluje subskrypcji w sklepie, dlatego najpierw użyj „Zarządzaj lub anuluj”. Zapisy księgowe dotyczące zakupów przechowujemy do 7 lat. Kopie zapasowe wygasają według normalnego harmonogramu.

Twoje prawa

Masz prawo dostępu do danych, ich sprostowania, usunięcia, ograniczenia przetwarzania, przenoszenia (w aplikacji: Konto i ustawienia, „Kopiuj dane konta”) oraz sprzeciwu wobec przetwarzania opartego na naszym uzasadnionym interesie. Możesz złożyć skargę do Prezesa Urzędu Ochrony Danych Osobowych (uodo.gov.pl). Napisz do nas: privacy@koydo.app.

Wiek

Aplikacja jest przeznaczona dla uczniów od 16 lat. Z pomocy AI można korzystać dopiero po potwierdzeniu w aplikacji, że ma się co najmniej 16 lat.

In English (summary)

Koydo Matura is a Polish-language mobile app for students 16 and older. We process your account (e-mail, optional Apple/Google display name, account ID), your study progress and usage counters, your subscription status (RevenueCat and the store), and technical data processed by Google Firebase (including IP address and an installation ID) to run and secure the app. There are no ads, no tracking, no analytics or crash-reporting tools, and no location, contacts, photos, camera or microphone access. Optional AI help (explanations, AI marking of written answers in the Premium plan and, in the Premium AI plan, an AI tutor) is for users 16 and older and works only after you consent on an in-app screen that names the recipients; we never ask for a date of birth. It sends the task, your answer or question and, in the tutor, a few recent messages. We do not attach profile fields such as your name, e-mail, phone number or account ID, but what you type is sent and may include personal data if you enter it; in tutor messages we redact e-mail addresses, phone numbers and PESEL numbers before sending, so please do not type personal data. Requests go through Google Cloud Functions and Koydo's AI gateway (Supabase) to OpenAI, which under its API terms does not use this data to train its models and keeps abuse-monitoring logs for up to 30 days unless longer retention is required by law or is reasonably necessary to protect OpenAI's services or any third party from harm. We do not store tutor chats, explanations or AI marks on your account. Per call we keep only technical data without content or account ID: Koydo's AI gateway cost records (kept as cost accounting records; we commit to keeping them no longer than 7 years and will have automatic deletion in place before any record reaches that age) and our server function logs in Google Cloud (deleted after 30 days). AI marks are advisory study feedback, not CKE results. We send your request to the AI service on the basis of your consent (GDPR Article 6(1)(a)); we keep the technical call records for AI cost accounting and service operation on the basis of our legitimate interests (Article 6(1)(f)); the consent record and daily usage counters have the bases stated in the Polish text. Transfers outside the EEA, including to the US, are described in section 11. You can withdraw consent in the app's settings. You can delete your account in the app or at koydo.app/delete-account, export your data in the app, and contact privacy@koydo.app.

Optional feedback from grown-ups who help us test

When we invite a family to help test Doozle or Koydo Homeschool, the app may show a grown-up a short, optional feedback survey. The Doozle survey is currently switched off, and there is no parent-approval flow available today. It will remain off unless Koydo later enables the parent-approval feature; if enabled, it will appear only in the grown-ups area, never on a child's screen, and only after a parent approves it from their own account. Meanwhile, grown-ups helping test Doozle can reply to their invitation email. In Koydo Homeschool it appears only on the dashboard of a parent or guardian's own account, never in a child's linked account. You can skip any question, say "Not now", or ignore it. The survey has a 7-day snooze and appears no more than three times.

What we collect, and why

• Your answers to a few multiple-choice questions (for example, how it's going and which parts were most useful), and any notes you choose to type or dictate.
• App and build details, which vary by app. Doozle includes its app version and your device platform; Koydo Homeschool includes "App: Koydo Homeschool (web)". The review screen shows the full email before you send it.

Nothing is sent automatically. The survey opens your own email app (or lets you copy the text) with your answers filled in, addressed to admin@koydo.app. It is only sent if you press Send yourself, so the email also carries your email address and name as your email app shows them. Your own email provider handles the message you send.

Please don't include a child's name or other personal details in your notes. Doozle dictation uses your device keyboard; Koydo Homeschool on the web offers browser speech dictation. Depending on your device, browser and settings, a speech-recognition provider (for example, Google when you use Chrome, or Apple or Google for your phone's keyboard) may process the audio under its own terms and privacy policy. Koydo does not receive dictation audio. If you email feedback, Koydo receives the email contents (your answers, notes and app details) and the sender name and address your email app includes.

We use feedback only to understand and improve our apps. We never use it for ads or profiling, never sell it, never share it for cross-context behavioural advertising, and never add it to a child's record.

Legal basis (EEA and UK). We process feedback you choose to send on the basis of our legitimate interests in improving our apps (Article 6(1)(f) GDPR). We weighed that interest against your privacy: sending is entirely voluntary, we ask for no child details, and we keep feedback only as long as stated below. You can object at any time by writing to privacy@koydo.app. For Switzerland, we process feedback in accordance with applicable Swiss data-protection law.

California residents. This is our notice at collection for tester feedback. Before you provide answers or dictated notes, the survey gives you a conspicuous, working link to this notice and our privacy policy, which you can open before providing feedback. We collect identifiers (the name and email address your email app sends) and the content you choose to send, only to understand and improve our apps, and we keep it as described below. We do not sell or share it (including for cross-context behavioural advertising). You have the right to know, delete and correct it, and we won't treat you differently for using these rights. The California addendum (CA) to this policy applies.

If a child sends feedback, or a child is identified. The survey is meant for grown-ups. We check each feedback email when it arrives. If we identify feedback sent by a child or identifying a child, we stop using it and promptly delete it or irreversibly remove the identifying information, no later than 24 hours after identification; we retain only genuinely non-identifying feedback.

Who can see it, and how long we keep it

Only authorised Koydo team members read feedback emails. Our email-hosting provider, Google (Google Workspace), stores and processes them for us, including in the United States. Section 11 (International Users and Cross-Border Transfers) explains the safeguards we use for transfers from the EEA, the UK and Switzerland, such as the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum. We move each feedback email out of the inbox no later than 12 months after receipt; it may remain in Trash for up to 30 more days before permanent deletion (up to 13 months in total).

Your choices and rights

You can ask us what feedback we hold about you, to correct it, or to delete it sooner, and you have the other rights described in Section 10 (Your Rights). Write to privacy@koydo.app (or admin@koydo.app). You don't have to write from the address you used; we may ask a few questions to confirm it's you before acting. We respond within the time the law requires and delete on request within 30 days.

What the survey never does

No tracking, analytics or ads are used for the survey. The survey does not send answers to Koydo automatically. If you use browser speech dictation, your browser may send audio to its speech-recognition provider as described above. Koydo receives feedback only if you choose to send it to us by email.

For parents and guardians who teach their children at home

Koydo Homeschool is for parents and guardians. Only adults (18 or older) create accounts. Children do not have their own accounts in Koydo Homeschool: a parent adds each child as a learner profile, and the child uses Homeschool while the parent is signed in. For Koydo Homeschool, this section applies instead of Section 2 wherever the two differ. You must be the parent or legal guardian of a learner you add, or have their parent's authority to add them.

What we collect about learners, and why

• What you enter: a learner's name or nickname, grade level, state, start date and instruction goals, and the records you choose to keep: grades, attendance and instruction logs, lesson plans, report cards and transcripts, assessments, compliance deadlines, co-op group enrolment, education-funding (ESA) expenses and orders, and documents or photos of work that you upload. If you connect Google Classroom, the roster and grades you import.
• What Homeschool records when a learner does a lesson: which lesson it was, whether the answers were right, and when.
• What we do not collect: a child's own e-mail address, birth date, precise location, or microphone or camera access. We do not use identifiers for advertising.
• Why: to run Homeschool for you: record-keeping, planning, progress reports and state compliance records.

Who can see it

• You. Learner information is visible to your account.
• Co-op groups. If you join a co-op group and add a learner to it, the group's organizers can see the learner you add to it.
• Sharing links. If you turn on a sharing link for a portfolio, anyone with the link can see what it shows. You can turn it off.
• Service providers that host and secure Homeschool, as listed in Section 2.5. We do not sell learner information, we do not show ads, and we do not use learner information for advertising.
• AI tools. Some Homeschool tools (for example worksheets and essay feedback) may send the text you submit to an AI provider listed in Section 2.5. Please do not put a child's name or other personal details in text you submit.

Your choices and rights as a parent

• You can review a learner's information in Homeschool. You can export it where the app offers an export, or ask us at privacy@koydo.app.
• You can delete a learner profile in Homeschool. This removes that learner's Homeschool records: grades, logs, plans, report cards, transcripts, documents and uploaded files. If you want any other record we hold for that learner removed, or if a deletion does not complete, write to privacy@koydo.app and we will handle your request under Section 10 (Your Rights).
• You can delete your whole account at koydo.app/delete-account.
• To ask a question or use any right, write to privacy@koydo.app. We will confirm you are the learner's parent before we act on a request.

How long we keep it

We keep learner information until you delete the learner profile or your account, and only as long as needed to run Homeschool.

Koydo Intelligence is our adaptive learning engine. When enabled, it uses the PRISM (Prismatic Learning Intelligence Signal Model) system to observe how a learner interacts with the platform, not just what they answer, but how they engage. PRISM uses these observations to adjust content difficulty, pacing, and presentation style in real time.

KI is entirely optional. It is off by default for users under 13 and requires affirmative opt-in.

6.1 What PRISM Collects (46 Behavioral Signals Across 7 Categories)

When KI is enabled, PRISM collects the following categories of behavioral signals. All signals are numeric measurements of interaction patterns. PRISM does not collect names, photos, audio, or any content the user creates -- only measurements of how the user interacts with learning activities.

Timing Patterns (6 signals)

How quickly or slowly a learner works through activities:

• How long a learner pauses before acting on a question
• How long it takes to complete an activity
• The gap between successive actions
• Whether the learner is speeding up or slowing down over time
• How consistent the learner's working rhythm is
• How long the learner thinks before submitting an answer

Touch and Movement Patterns (8 signals)

How precisely and comfortably a learner interacts with the screen:

• Accuracy of taps on intended targets
• Speed of drawing strokes
• Smoothness of drawing strokes
• Precision when coloring within boundaries
• How quickly the learner scrolls through content
• Accuracy when dragging objects to targets
• Complexity of gestures used
• How frequently the learner uses the eraser tool

Color Preferences (6 signals)

What colors a learner gravitates toward when given choices in creative activities:

• Which colors are selected most often
• How many different colors are used
• Preference for warm versus cool colors
• Preference for bright versus muted colors
• Whether color choices are consistent across sessions
• How often dark colors are chosen

Spatial Preferences (6 signals)

How a learner organizes and navigates visual elements:

• Preferred shapes in creative activities
• How organized the learner's spatial arrangements are
• Preference for symmetrical versus asymmetrical layouts
• Preferred sizes of drawn or placed elements
• Where on the screen the learner tends to place objects
• How the learner navigates between screens and activities

Persistence and ProblemSolving Patterns (8 signals)

How a learner responds to challenges, errors, and difficulty:

• Whether the learner retries after making an error
• How long it takes to recover from an error and try again
• When the learner requests hints (early, middle, or late in a problem)
• How many consecutive failures the learner endures before stopping
• Whether the learner voluntarily repeats completed activities
• How often the learner skips activities
• Whether the learner seeks out harder or easier content
• How quickly the learner recovers from frustration

Social Interaction Patterns (5 signals)

How the learner engages with collaborative and competitive features:

• Whether the learner checks leaderboards or peer comparisons
• Preference for collaborative versus individual activities
• How often the learner shares achievements or content
• Response to competitive elements (motivated, neutral, or discouraged)
• How often the learner helps peers

Daily and Session Patterns (7 signals)

When and how long the learner engages with the platform:

• What time of day sessions typically begin
• How long each session lasts
• How quickly engagement declines during a session
• How long it takes the learner to "warm up" at the start of a session
• The time of day when the learner performs best
• Which days of the week the learner is most active
• How often the learner takes breaks during a session

6.2 What PRISM Derives from These Signals

PRISM combines the 46 raw signals into composite indices that guide the adaptive learning system:

• Cognitive load estimate: Whether the learner appears under-challenged, appropriately challenged, or overwhelmed.
• Emotional state estimate: Whether the learner appears to be thriving, neutral, or struggling.
• Developmental stage markers: Fine motor development, spatial reasoning development, and abstraction level, used to select age-appropriate content.
• Learning modality preference: Whether the learner responds best to visual, kinesthetic, auditory, or reading/writing activities.
• Engagement quality: Whether the learner is actively engaged, passively present, or disengaging.
• Frustration risk: Real-time estimate of whether the learner is becoming frustrated, used to trigger difficulty adjustments or break suggestions.
• Curiosity indicators: Whether the learner is voluntarily exploring content, used to offer enrichment opportunities.
• Confidence calibration: Whether the learner's confidence matches their performance, used to provide appropriate encouragement or challenge.
• Attention quality: Sustained attention estimate within a session, used to suggest breaks when attention wanes.
• Intrinsic motivation: Whether the learner is engaging voluntarily and with interest, versus completing tasks under external pressure.

6.3 How PRISM Uses This Data

PRISM data is used exclusively to:

1. Adjust difficulty: Make questions easier or harder based on the learner's current state.
2. Switch modality: If a learner responds better to visual activities than text-based ones, present more visual content.
3. Suggest breaks: When attention or engagement declines, suggest a break.
4. Offer encouragement: When frustration risk is elevated, provide supportive feedback.
5. Optimize session length: Recommend session durations based on the learner's observed attention patterns.
6. Generate parent reports: Provide parents with insights into their child's learning patterns and progress.

PRISM data is never used for advertising, behavioral profiling for non-educational purposes, sale to third parties, or any purpose outside of the educational service.

6.4 PRISM Data and Children Under 13

For children under 13:

• PRISM is off by default and requires specific parental opt-in.
• Parents receive a dedicated disclosure describing all 46 signals before opting in.
• Parents may disable PRISM at any time. Once disabled, we stop collecting PRISM signals. Raw PRISM signal events are deleted automatically once they are 90 days old, and session snapshots are scheduled for deletion by the daily cleanup once they are 30 days old, unless a legal hold applies.
• Aggregated PRISM profiles (the derived indices described in Section 6.2) are deleted upon account deletion or parental request.
• PRISM data is never shared with third parties.

We use the following third-party service providers to operate the Service. Each provider processes data only as directed by Koydo and only for the purpose of providing their service to us.

Important notes regarding child data and third-party processors:

• Koydo does not opt API content into provider model training. Provider retention is service-specific: standard commercial API terms may permit limited retention for safety or service operation, while enhanced retention controls require separate eligibility, configuration, or agreement. Koydo claims zero retention only when current evidence covers the exact service and account.
• Child-safe AI routing is fail-closed. A provider cannot receive child personal data merely because it is available as an adult-route fallback.
• Mixpanel analytics are disabled in the current linked web configuration. The guarded integration blocks minors, anonymous visitors, unresolved profile ages, consent withdrawal, and opt-out transitions before wrapper events can send.
• Stripe and RevenueCat process payment data only for adult account holders. Children do not have a direct payment relationship with Koydo.
• ElevenLabs may receive text for live narration on eligible non-child routes and may render approved Koydo-authored narration. Koydo does not send it a user's audio recording through these flows.

Sub-processors and change notifications. The processors listed above retain their own sub-processors (for example, Supabase uses AWS; Vercel uses Cloudflare and AWS). The current authoritative list of Koydo direct processors and their material sub-processors — together with a free email subscription to be notified of additions or replacements — is published at /legal/subprocessors. Where a User or Institutional customer reasonably objects to a new sub-processor within thirty (30) days of notice, Koydo will work in good faith to address the objection, including by offering an alternative arrangement or, where no reasonable alternative exists, terminating the affected service for that customer.

We retain different categories of data for different periods, based on the purpose of collection and applicable legal requirements.

Upon account deletion:

• Adult and teen self-service requests in the Koydo web app use a cancellable 30-day grace period; in Koydo's mobile apps, in-app deletion completes when the app confirms it. Parent-confirmed child requests use a 14-day grace period. Verified GDPR erasure requests are queued without a grace period, and institutional requests are processed within 30 days.
• After the live account is purged, restricted rotating database backups and provider security logs may retain copies or request metadata until their scheduled expiry. They are not returned to ordinary use. If a backup is restored for disaster recovery, deletion requests must be reapplied before restored data can return to ordinary use.
• Supabase Storage objects are deleted separately through the Storage API and are not included in Supabase database backups.
• Financial records are anonymized (user identifiers removed) and retained for the legally required period.
• Deletion audit records are retained in anonymized form (no personal identifiers) to verify that deletion was properly executed.
• Koydo submits provider-side deletion for addressable records created through a provider API. For stateless API calls without a user-keyed provider record, retention follows the provider's applicable terms and verified account settings; Koydo records cleanup successes, failures, and documented skips.

Legal hold exception. The retention periods above may be extended only for specific User accounts subject to a documented written legal hold (active dispute, regulatory inquiry, court order, subpoena, or formal claim). Legal holds are issued through a documented internal process; they apply only to the specific account(s) implicated; they auto-expire when the trigger event closes; and they do not justify general retention beyond the periods stated above for any other User. The "dispute resolution" rationale alone does not authorize indefinite retention.

We take all measures required pursuant to GDPR Article 32 and maintain reasonable administrative, technical and physical safeguards to protect your personal information against unauthorized access, alteration, disclosure, or destruction, taking into account the nature of the processing and the risks. For children's personal information, Koydo maintains reasonable procedures to protect its confidentiality, security and integrity, as COPPA (16 C.F.R. § 312.8) requires.

9.1 Payments

Payments are processed by our payment providers. Koydo does not store raw payment card data on its own servers.

9.2 Access Controls

• Access to user data is restricted to authorized personnel on a need-to-know basis.

9.3 AI Safety

• AI interactions involving children are subject to content moderation and safety controls.
• AI safety events are logged for audit and review.

9.4 Infrastructure Providers

Our infrastructure providers maintain their own security certifications and controls.

9.5 Breach Notification

In the event of a data breach affecting personal information:

• We will notify affected users (or parents, in the case of children) without undue delay and in any event within 72 hours of becoming aware of the breach.
• We will notify the Federal Trade Commission and any applicable state attorneys general as required by law.
• For EU users, we will notify the relevant supervisory authority within 72 hours as required by GDPR Article 33.
• Notification will include: the nature of the breach, the categories of data affected, likely consequences, and measures taken to address the breach.

10.1 All Users

Regardless of age or location, all Koydo users (or their parents, for children) have the right to:

• Access: Request a copy of all personal information we hold about you.
• Correction: Request correction of inaccurate personal information.
• Deletion: Request deletion of your account and associated personal information.
• Export: Download your data in a machine-readable format (JSON).
• Opt out of analytics: Disable optional analytics collection at any time.

10.2 Parents of Children Under 13 (COPPA Rights)

See Section 2.6 for a complete description of parental rights, including the right to review, delete, export, disable KI, and revoke consent.

10.3 California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"):

CCPA core rights:

• Right to know. Request a copy of the personal information we have collected about you, the categories of sources, the purposes of collection, and the categories of third parties with whom we share it.
• Right to correct. Request correction of inaccurate personal information.
• Right to delete. Request deletion of your personal information, subject to limited statutory exceptions.
• Right to opt out of sale or share. Koydo does not sell or share personal information for cross-context behavioral advertising. We nevertheless honor "Do Not Sell or Share My Personal Information" requests at /legal/do-not-sell.
• Right to non-discrimination. We will not deny service, charge a different price, or provide a different level of service because you exercised any of these rights.

CPRA additional rights (effective for all Koydo California Users):

• Right to limit use and disclosure of Sensitive Personal Information. California recognizes certain categories of personal information as "sensitive" — including precise geolocation, biometric identifiers used for unique identification, health information, racial or ethnic origin, religious beliefs, contents of mail or messages, financial-account credentials, sex life or sexual orientation, and the fact that an individual is a minor. You may direct Koydo to use Sensitive Personal Information only for the purposes that are reasonably necessary to provide the Service and for the additional purposes permitted by Cal. Civ. Code § 1798.121(b). To exercise this right, visit /legal/limit-sensitive-pi.
• Right to opt out of profiling and automated decision-making with significant effect. Where Koydo uses automated processing — for example, the PRISM behavioral signal system that informs adaptive learning decisions described in Section 6 — you may opt out of having that processing applied to your account. When you opt out, Koydo serves a non-personalized version of the adaptive learning experience. You can opt out at any time in Account Settings.
• Right to information about automated decision-making logic. You may request meaningful information about the logic involved in any automated decision, the significance of the processing, and the envisioned consequences. Koydo's authoritative disclosure of its automated decision-making logic — the PRISM signal taxonomy, derived indices, and how the indices are used — is published at /legal/automated-decisions.

To exercise any of these rights, contact us at privacy@koydo.app or use the controls in your account settings. We respond within forty-five (45) calendar days, with one forty-five-day extension where reasonably necessary, in line with CCPA § 1798.130.

10.4 European Economic Area, United Kingdom, and Switzerland (GDPR / UK GDPR / FADP)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following additional rights, in each case as recognized by the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), the United Kingdom General Data Protection Regulation and Data Protection Act 2018 ("UK GDPR"), and the Swiss Federal Act on Data Protection (revised effective 1 September 2023, "FADP"):

• Right of access (Art. 15) — request a copy of your personal data.
• Right to rectification (Art. 16) — correct inaccurate or incomplete data.
• Right to erasure / "right to be forgotten" (Art. 17) — request deletion in the circumstances specified by law.
• Right to restriction of processing (Art. 18).
• Right to data portability (Art. 20) — receive your data in a structured, commonly used, machine-readable format (we provide JSON).
• Right to object (Art. 21) — object to processing based on legitimate interest, including profiling.
• Right not to be subject to a decision based solely on automated processing (Art. 22) where the decision produces legal or similarly significant effects.
• Right to withdraw consent at any time for processing based on consent (Art. 7(3)).
• Right to lodge a complaint with your local supervisory authority. EEA Users may identify their authority at edpb.europa.eu; UK Users may contact the Information Commissioner's Office at ico.org.uk; Swiss Users may contact the Federal Data Protection and Information Commissioner at edoeb.admin.ch.

Legal bases for processing. Koydo processes personal data under the following lawful bases identified by Art. 6 GDPR and corresponding provisions of UK GDPR and FADP: contract performance (delivering the Service you signed up for); legitimate interest (adaptive learning, platform security, service improvement, fraud prevention, debugging); consent (Koydo Intelligence opt-in, optional analytics, marketing-showcase use of co-created content per TOS § 8.4(c)); and legal obligation (child safety, financial recordkeeping, regulator response). For each processing activity, the applicable legal basis is recorded in our internal Article 30 record of processing activities, available to supervisory authorities on request.

Privacy Team. Koydo's Privacy Team is the single point of contact for data-protection inquiries and is reachable at privacy@koydo.app. Koydo does not currently designate a named individual as Data Protection Officer; if Koydo becomes required to maintain a formal DPO under GDPR Article 37, the appointment will be reflected in this Section.

EU / UK Article 27 Representatives. Our EU representative under GDPR Article 27 is Robert Waltos, Jasionka 543, 36-002 Jasionka, woj. podkarpackie, Poland, privacy@koydo.app. Robert Waltos is also Koydo's founder and chief executive officer. Koydo has not yet appointed a representative under UK GDPR Article 27; the status is published at the international transfer notice and will be updated when one is appointed. UK data subjects may contact Koydo's Privacy Team directly at privacy@koydo.app. EEA data subjects retain the right to lodge a complaint with the supervisory authority of their habitual residence; UK data subjects retain the right to lodge a complaint with the Information Commissioner's Office at ico.org.uk.

Cross-border transfers. Your personal data is transferred to and processed in the United States. Koydo relies on the following transfer mechanisms, each documented and available for inspection at the international transfer notice:

• EU SCCs — the Standard Contractual Clauses adopted by the European Commission in Decision 2021/914, Modules 2 (Controller-to-Processor) and 3 (Processor-to-Processor), as appropriate to the processing relationship;
• UK Addendum to the EU SCCs — the International Data Transfer Addendum issued by the UK Information Commissioner's Office (version B1.0, in force 21 March 2022), which incorporates the EU SCCs into UK law for transfers from the United Kingdom; and
• Swiss FADP addendum — the supplementary clauses recognized by the Swiss Federal Data Protection and Information Commissioner for transfers from Switzerland.

Koydo's certification status under the Data Privacy Framework, where applicable, is published at the international transfer notice.

Member-state age thresholds. For Users in EU member states where the GDPR parental-consent age threshold is higher than 13 (Art. 8 GDPR and member-state implementations), Koydo applies the stricter threshold. Examples: Germany and the Netherlands require parental consent up to age 16; France up to age 15. Users in the United Kingdom are governed by the UK GDPR's age 13 threshold and the UK Age Appropriate Design Code (Children's Code) standards.

Koydo is based in the United States. If you access the Service from outside the United States, your data will be transferred to, stored in, and processed in the United States and any other country where Koydo or its processors operate.

• EEA Users: Where a transfer requires a Chapter V safeguard, Koydo relies on the EU Standard Contractual Clauses (Decision 2021/914) or another lawful mechanism applicable to the specific service. Provider-level status is maintained in Koydo's private contract register and described at the international transfer notice.
• UK Users: Transfers from the United Kingdom to the United States are made pursuant to the UK Addendum to the EU SCCs (B1.0, 21 March 2022), adopted by the Information Commissioner's Office, executed alongside the EU SCCs above. Alternatively, where executed separately with a processor, Koydo relies on the UK International Data Transfer Agreement (IDTA).
• Swiss Users: Transfers from Switzerland to the United States rely on the EU SCCs as supplemented by the FADP-specific addendum recognized by the Swiss Federal Data Protection and Information Commissioner.
• Sub-processor transfers: Koydo requires applicable flow-down data-protection obligations before a provider processes Customer Personal Data. The current sub-processor list is at /legal/subprocessors.
• AI model providers: OpenAI, Anthropic, and Google process data in the United States. Commercial API terms generally prohibit training on customer API content unless the customer opts in. Retention and transfer safeguards vary by product and account configuration; child personal data remains blocked unless evidence for the exact provider flow is current.

If you would like a copy of the executed transfer mechanism for a specific data flow, contact privacy@koydo.app — Koydo will provide the document or a redacted summary within thirty (30) days.

12.1 What Counts as a "Material Change"

A change to this Privacy Policy is material if it touches any of the following:

1. Categories of personal data Koydo collects;
2. Identity of Koydo's processors or sub-processors;
3. Data retention periods;
4. User rights or how to exercise them;
5. Any provision specifically governing Children, Teens, or Parents;
6. Security commitments or breach-notification timelines;
7. International transfer mechanisms; or
8. Lawful bases for processing.

Non-material changes — typographical fixes, formatting, restructuring, and clarifying language that does not alter rights or obligations — may be published without advance notice. The version and effective date at the top of this policy will be updated.

12.2 Notice Process for Material Changes

For material changes affecting adults (18+) and teens (13–17), Koydo provides at least thirty (30) days' advance notice via:

1. Email to the address associated with your account; and
2. In-app notification displayed prominently within the Service; and
3. A one-click "review changes" page summarizing what changed and why.

Continued use after the effective date constitutes acceptance. You may decline by closing your account before the effective date.

12.3 Children Under 13 — ReVerifiableParentalConsent

For material changes affecting any provision governing Children under 13 — including changes to data categories, processors, retention periods, or children-specific rights — Koydo will, consistent with 16 C.F.R. § 312.5, re-obtain Verifiable Parental Consent before the change applies to existing Child Profiles. Until re-consent is obtained from a Parent, the previously-consented practices remain in effect for that Child Profile. If a Parent does not respond, the affected Child Profile remains on the previously-consented practices; Koydo will not silently default to the new practices.

12.4 LegallyRequired Changes

Changes required by law, regulation, court order, or regulator directive may be implemented with shorter notice or with immediate effect. The reason and effective date will be described in this policy or the accompanying notice.

Koydo uses a small number of cookies and similar local-storage technologies for authentication, security, accessibility, locale preferences, and recorded privacy choices. Mixpanel is currently disabled. Optional Vercel analytics run only after the consent and eligibility checks described in this policy, and Vercel says it uses no third-party cookies for them. Koydo does not use advertising cookies; Koydo does not run advertising of any kind.

For users in the EEA, UK, and Switzerland, Koydo presents a consent banner on first visit allowing you to accept or reject non-essential cookies; your choice is stored and respected. For users elsewhere, the same controls are available in your account settings under "Manage Cookies." A complete cookie inventory — including each cookie name, purpose, provider, retention, and type — is published at /legal/cookies.

Mobile applications (Flutter native, native iOS Swift, native Android) do not use web cookies. Where those applications use platform-level analytics or measurement frameworks, consent is obtained through the platform's native consent mechanism — Apple App Tracking Transparency (ATT) on iOS and Google's User Messaging Platform (UMP) on Android — not through this web Privacy Policy or any embedded web banner.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, you may contact us at:

KOYDO LLC 940 W. FM 544 #332 Wylie, Texas 75098-5157 United States Telephone: +1 (214) 218-6693 Email: privacy@koydo.app

Privacy Team. Koydo's Privacy Team is the single point of contact for data-protection matters and is reachable at privacy@koydo.app. Koydo does not currently designate a named individual as Data Protection Officer in this Privacy Policy; if Koydo is required to maintain a formal DPO under GDPR Article 37, the appointment will be reflected in this Section.

EU / UK Article 27 Representatives. EU representative: Robert Waltos, Jasionka 543, 36-002 Jasionka, woj. podkarpackie, Poland, privacy@koydo.app. Robert Waltos is also Koydo's founder and chief executive officer. A UK representative is not yet appointed; UK data subjects may contact the Privacy Team directly at privacy@koydo.app. The current status is at the international transfer notice.

Reviewed and approved by Robert Waltos, Founder & Chief Executive Officer of KOYDO LLC, on September 29, 2026 for version 2026-09-29. The corrections in version 2026-10-02 adopt text already published at app.koydo.app and were reviewed under Koydo's internal review process on October 2, 2026. On October 14, 2026, Mr. Waltos re-attested version 2026-10-14.2 as published, under the same attestation standard as before. On October 16, 2026, Mr. Waltos attested versions 2026-10-15 through 2026-10-16, including the Koydo Matura (Polska) section, under the same attestation standard. What changed in each version is recorded in Koydo's legal version history. Mr. Waltos attested, to the best of his knowledge as of each attestation date, that the substantive content of the attested version reflected Koydo LLC's actual data-handling practices, processor relationships, security commitments, and legal posture. Neither attestation substitutes for outside legal counsel review, which is scheduled per the company's annual review cadence. External regulators, users, and counterparties may rely on the substantive content of this document; any inaccuracy will be corrected promptly upon discovery and any material change will follow Section 12 above.

Koydo Privacy Policy v2026-10-16 — Effective October 16, 2026 — supersedes v2026-10-15.2

These addenda supplement the Koydo Terms of Service and Privacy Policy. The addendum for a user's location, billing region, school relationship, or child-safety law applies in addition to the main documents. If an addendum conflicts with the main document for a covered user, the addendum controls for that user.

Applies to: Users physically located in or with primary residence in the State of Texas. Version: 2026-05-09 Effective Date: 2026-05-09 Companion: TX-SCOPE Addendum — applies in parallel for Users known to be under 18 and for Institutional school accounts.

For Texas Users, these Terms are governed by the laws of the State of Texas. Any litigation arising from these Terms (where arbitration does not apply per TOS §11) shall be brought exclusively in the state or federal courts located in Collin County, Texas, except as provided by TOS §11.10 (Minors carve-out).

For Texas consumers, non-waivable rights under the Texas Deceptive Trade Practices–Consumer Protection Act (DTPA), Tex. Bus. & Com. Code Chapter 17, remain available and are not limited by these Terms.

Texas consumer rights under the TDPSA (Tex. Bus. & Com. Code Chapter 541) — access, correct, delete, portability, opt-out of targeted advertising / sale / profiling — are described in the TX-SCOPE Addendum §3.

Automatic-renewal disclosures, affirmative consent, and cancellation access are provided in compliance with applicable Texas law (Tex. Bus. & Com. Code § 17.46(b)(38) and related provisions).

For Institutional Accounts in Texas (school districts, charter schools, accredited private schools, homeschool cooperatives), see TX-SCOPE Addendum §2.

Nothing in these Terms waives any non-waivable Texas consumer right.

Texas General Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in the State of Texas, United States. Version: 2026-05-09 Effective Date: 2026-05-09 Authoritative documents: /legal/terms-of-service and /legal/privacy-policy

This Addendum supplements the Terms of Service and Privacy Policy as they apply to Koydo Users in Texas. It implements Koydo's compliance with the Texas Securing Children Online through Parental Empowerment Act (SCOPE Act), codified at Tex. Bus. & Com. Code Chapter 509 (effective September 1, 2024), the Texas Data Privacy and Security Act ("TDPSA"), codified at Tex. Bus. & Com. Code Chapter 541, and the Texas Student Privacy Act.

Where this Addendum and the body of the Terms or Privacy Policy conflict, this Addendum controls solely with respect to Users in Texas.

For each Texas User Koydo knows or reasonably believes to be under 18 ("Minor"), Koydo:

1. Verifies parental identity and consent before the Minor's account is activated, using the Verifiable Parental Consent process described in TOS §3.2 and Privacy Policy §2.
2. Restricts known-Minor accounts from the following data practices:

• Targeted advertising — not applicable, because Koydo does not run advertising of any kind.
• Sale of personal data — not applicable, because Koydo does not sell personal data.
• Sharing of personal data with third parties for purposes other than providing the Service.
• Use of the Minor's personal data to train, fine-tune, evaluate, or improve any AI model.

3. Provides parental access to:

• The Minor's account, including a parent dashboard with visibility into the Minor's activity, time-on-platform, and content interactions.
• Tools to manage privacy settings on behalf of the Minor.
• The ability to delete the Minor's account or any associated data.

4. Defaults privacy settings for known-Minor accounts to the most protective configuration available (Koydo Intelligence off, social features at "friends only" for under-13 and as set by the Minor for 13–17, no public profile).
5. Implements safety filters for harmful content categories enumerated in the SCOPE Act (suicide/self-harm promotion, eating disorders, substance abuse, harassment, sexual exploitation), with a parental escalation path.

For Institutional Accounts in Texas (school districts, charter schools, accredited private schools, and homeschool cooperatives), Koydo:

• Acts as a "School Official" under FERPA (20 U.S.C. § 1232g) with a legitimate educational interest in providing the Service.
• Processes student education records solely as directed by the Institution under the institutional agreement.
• Does not sell student data, target advertising to students, or use student data for any purpose other than providing the Service.
• Provides a 30-day institutional deletion workflow for any school requesting deletion of student data.

Texas residents whose accounts are subject to the TDPSA may exercise the following rights:

• Right of access — request a copy of personal data held by Koydo.
• Right to correct inaccuracies.
• Right to delete personal data.
• Right to data portability in machine-readable format.
• Right to opt out of targeted advertising — not applicable; Koydo does not run advertising.
• Right to opt out of the sale of personal data — not applicable; Koydo does not sell personal data.
• Right to opt out of profiling in furtherance of decisions producing legal or similarly significant effects — Koydo Intelligence does not produce such decisions; see /legal/automated-decisions.
• Right to appeal any denial of a TDPSA request — appeals may be sent to privacy@koydo.app with subject "TDPSA Appeal."

To exercise these rights, contact privacy@koydo.app or use the controls in your account settings. Koydo responds within 45 days.

In the event of a breach affecting Texas residents, Koydo notifies affected Users without unreasonable delay and in compliance with Tex. Bus. & Com. Code § 521.053. Where the breach affects 250 or more Texas residents, Koydo also notifies the Office of the Texas Attorney General within 30 days.

Disputes brought by Texas Users are governed by Texas law, in the courts of competent jurisdiction in Collin County, Texas, consistent with TOS §11.8 and §11.10 (minors carve-out from arbitration).

Koydo cooperates in good faith with inquiries from the Office of the Texas Attorney General regarding compliance with the SCOPE Act, TDPSA, and Texas Student Privacy Act. Inquiries should be directed to legal@koydo.app.

Texas SCOPE / TDPSA / Student Privacy Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in the State of California, United States. Version: 2026-05-09 Effective Date: 2026-05-09 Authoritative documents: /legal/terms-of-service and /legal/privacy-policy

This Addendum supplements the Terms of Service and Privacy Policy as they apply to Koydo Users in California.

California Users' privacy rights — including the right to know, correct, delete, opt out of sale or share (Koydo does neither), opt out of profiling and automated decision-making with significant effects, limit use of Sensitive Personal Information, and non-discrimination — are enumerated at Privacy Policy §10.3. Koydo does not sell or share personal information for cross-context behavioral advertising and does not run advertising of any kind.

The "Do Not Sell or Share My Personal Information" request is available at /legal/do-not-sell. The "Limit Use of Sensitive Personal Information" control is at /legal/limit-sensitive-pi. Automated-decision-making logic disclosure is at /legal/automated-decisions.

Koydo honors the Global Privacy Control (GPC) browser signal as a valid opt-out of sale, share, and analytics tracking.

To the extent the California Age-Appropriate Design Code is enforceable (subject to ongoing litigation), Koydo voluntarily aligns with its design standards for known-Minor accounts (under 18), including:

• Default privacy settings to most protective (Koydo Intelligence off, no public profile, social features at "friends only" for under-13).
• Plain-language disclosure at the /legal/privacy-summary.
• No dark patterns — refusing or revoking consent is no harder than granting it.
• Data minimisation — collect no more than reasonably necessary for the educational purpose.
• No profiling for non-educational purposes — Koydo Intelligence is pedagogical only.

For Institutional Accounts serving California schools, Koydo complies with SOPIPA (Cal. Bus. & Prof. Code §§ 22584–22585):

• No targeted advertising to students based on data acquired through the Service.
• No use of student data to amass a profile other than for K-12 school purposes.
• No selling, renting, trading, or otherwise making available a student's personal information.
• No disclosure of student personal information except as enumerated by SOPIPA.

For California consumers purchasing auto-renewing subscriptions through Koydo:

• Clear and conspicuous disclosure of auto-renewal terms at the time of purchase, including renewal cycle, renewal price, and cancellation method.
• Affirmative consent to the auto-renewal at checkout.
• Acknowledgment confirmation post-purchase including the foregoing.
• Annual renewal reminder for annual subscriptions, sent 15–45 days before renewal.
• Easy cancellation through Account Settings → Subscription, online and without unreasonable friction.
• Refund alignment with TOS §4.4 (14-day no-questions refund of any charge; refund of unused whole months for annual plans thereafter, with no fee; cancel-anytime for monthly).

Under California Civil Code § 1789.3, California residents may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs at 1625 N. Market Blvd., Suite N-112, Sacramento, California 95834, or by telephone at (800) 952-5210.

Nothing in these Terms waives any non-waivable consumer protection right available to California residents under California law, including but not limited to those under the California Consumer Privacy Act (as amended by the CPRA), the California Online Privacy Protection Act, the California Invasion of Privacy Act, the SHIELD Act analogues, and applicable consumer-protection statutes. Where a non-waivable California right conflicts with the body of these Terms, the California right controls.

California Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in the State of New York, United States. Version: 2026-05-09 Effective Date: 2026-05-09 Companion: NY-SAFE Addendum — applies in parallel for Users known to be under 18. Authoritative documents: /legal/terms-of-service and /legal/privacy-policy

For New York consumers purchasing auto-renewing subscriptions through Koydo (Stripe-processed):

• Clear and conspicuous disclosure of auto-renewal terms at purchase.
• Affirmative consent at checkout.
• Renewal reminder for annual subscriptions between 15 and 45 days before renewal, with a one-click cancellation link.
• Easy cancellation via Account Settings → Subscription, with no friction designed to deter cancellation.

For New York schools, school districts, BOCES, and charter schools, see the NY-SAFE Addendum §2 for the Parents' Bill of Rights, Data Security and Privacy Plan, subcontractor disclosure, and annual reporting commitments.

Koydo implements administrative, technical, and physical safeguards consistent with General Business Law § 899-bb (NY SHIELD Act): encryption (TLS 1.2+ in transit, AES-256 at rest), access controls, periodic security assessments, employee training, vendor due diligence, and an incident-response plan.

Nothing in these Terms waives any non-waivable consumer-protection right available to New York residents.

New York General Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in the State of New York, United States. Version: 2026-05-09 Effective Date: 2026-05-09 Authoritative documents: /legal/terms-of-service and /legal/privacy-policy

This Addendum supplements the Terms of Service and Privacy Policy as they apply to Koydo Users in New York. It addresses the New York Stop Addictive Feeds Exploitation (SAFE) for Kids Act (S.7694, 2024), New York Education Law § 2-d (Parents' Bill of Rights for Data Privacy and Security), the NY SHIELD Act (Stop Hacks and Improve Electronic Data Security Act), and GBL § 527-a (auto-renewal disclosure).

Koydo is, in substance, an adaptive educational service — not a social-media platform. Koydo's adaptive learning feature, Koydo Intelligence, is a pedagogical system, not an "addictive feed" within the meaning of the SAFE for Kids Act.

Nonetheless, to align defensively with the policy intent of the SAFE for Kids Act, Koydo applies the following protections to all New York Users known to be under 18:

1. No algorithmic feed of unbounded user-generated content. Koydo does not host or recommend an open social feed.
2. Default chronological ordering of any list of activities, content, or messages. Adaptive recommendations from Koydo Intelligence are pedagogical (next lesson, suggested skill review) and require opt-in parental consent for under-13 (Koydo Intelligence off by default per Privacy Policy §6.4).
3. Notification quiet hours. Push notifications and in-app reminders are suppressed between midnight and 6 AM local time for known-Minor accounts (under 18) by default. Parents may adjust this window in the Parent Dashboard.
4. Time-on-platform visibility for parents, including session-length and weekly-total reports.
5. Right of parental disable. A Parent may, at any time, disable any adaptive recommendation feature for their child via the Parent Dashboard; the Service continues to function on a fixed pedagogical curriculum path.

For Institutional Accounts serving New York schools, school districts, BOCES, and charter schools, Koydo provides the protections required under § 2-d, including:

• Parents' Bill of Rights for Data Privacy and Security — incorporated by reference into every institutional agreement.
• Data Security and Privacy Plan describing the categories of personally identifiable information (PII) Koydo accesses, the purposes of processing, the data security measures (encryption in transit and at rest, MFA, access logging, breach response), and the entities receiving PII.
• Subcontractor disclosure at /legal/subprocessors.
• Annual report to participating school districts on Koydo's data-handling practices upon request.
• No sale of student PII and no use of student PII for any purpose other than providing the Service.

To request the institutional Data Security and Privacy Plan, schools may contact legal@koydo.app.

Koydo implements administrative, technical, and physical safeguards consistent with the NY SHIELD Act (General Business Law § 899-bb), including encryption (TLS 1.2+ in transit, AES-256 at rest), access controls, periodic security assessments, employee training, vendor due diligence (see /legal/subprocessors), and an incident response plan.

For New York consumers purchasing auto-renewing subscriptions through Koydo (Stripe-processed; not via app stores):

• Pre-renewal notice. Koydo provides a clear and conspicuous notice of the auto-renewal terms — including the renewal cycle, the renewal price, and the cancellation method — at the time of purchase.
• Renewal reminder. For annual subscriptions, Koydo provides an email reminder between 15 and 45 days before the renewal date, stating the renewal date and price and a one-click cancellation link.
• Easy cancellation. Cancellation is available via Account Settings → Subscription, with no friction designed to deter cancellation. Exit-intent retention offers, if any, are clearly skippable.
• Refund alignment. Koydo's tiered refund policy (TOS §4.4) — 14-day no-questions refund of any charge; refund of unused whole months for annual plans thereafter, with no fee; cancel-anytime for monthly — applies to New York consumers without diminution.

To the extent a comprehensive NY consumer-privacy statute is enacted and effective, this Addendum will be updated to reflect the resulting rights. Pending such enactment, NY consumers may exercise the universal rights described in Privacy Policy §10.1 (access, correction, deletion, export, opt out of analytics).

Disputes brought by New York consumers are subject to the choice-of-law and venue provisions of TOS §11.8 and the minors carve-out at §11.10. Nothing in this Addendum waives any non-waivable consumer right under New York law.

New York SAFE for Kids / §2-d / SHIELD / Auto-Renewal Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in the State of Florida, United States. Version: 2026-05-09 (stub) Effective Date: 2026-05-09 Status: Stub pending litigation resolution. Florida HB 3 ("Online Protections for Minors") is partially enjoined as of the effective date of this Addendum (NetChoice v. Moody, Northern District of Florida, ongoing). Several provisions of HB 3 are not currently enforced. Koydo will revise this Addendum once the litigation is resolved and the law's enforceable scope is clarified.

Koydo is in substance an online educational service. Florida HB 3 contains explicit carve-outs for educational platforms, including the exclusions at Florida Statutes § 501.1735 for online services whose primary purpose is the provision of educational content and services to minors and students under the supervision of a parent, school, or other authorized adult.

Koydo's primary purpose — adaptive learning, AI tutoring, exam preparation, language learning, and adaptive curriculum delivery — falls within the educational-services scope. The Service is not a social-media platform, does not host an unbounded user-generated-content feed, and does not derive revenue from advertising. Accordingly, Koydo asserts the educational-platform carve-out and operates outside the scope of the substantive HB 3 minor-account provisions.

Notwithstanding the carve-out, Koydo voluntarily aligns with the policy intent of HB 3 by applying the protections described in the New York SAFE for Kids Addendum to Florida Users known to be under 18 — including default-protective privacy settings, no targeted advertising (Koydo runs no advertising of any kind), parental dashboard, and notification quiet hours.

To the extent applicable, Florida consumers may exercise the rights described in Privacy Policy §10 and may file complaints with the Florida Department of Legal Affairs, Office of the Attorney General.

This Addendum is intentionally short pending resolution of NetChoice v. Moody and any subsequent Florida Department of Legal Affairs guidance. When the enforceable scope of HB 3 is clarified, this Addendum will be updated and the change recorded in Koydo's legal version history.

Florida HB 3 Stub Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in Washington State. Version: 2026-05-09 Effective Date: 2026-05-09

For Washington subscribers, recurring-charge disclosures are shown before purchase, and account cancellation methods are maintained in account settings or support channels in compliance with RCW 19.224.

Koydo does not collect "consumer health data" within the meaning of Washington's My Health My Data Act (RCW 19.373). Where any Koydo data could be construed to fall within that definition, Koydo applies the consent and rights regime described in Privacy Policy §10 to such data and treats it as Sensitive Personal Information per California CPRA standards.

Breach notification follows RCW 19.255 for Washington residents — without unreasonable delay and in any event no later than 30 days after discovery, with content specified by the statute.

Nothing in these Terms waives any non-waivable consumer-protection right available to Washington residents.

Washington Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in the Commonwealth of Virginia. Version: 2026-05-09 Effective Date: 2026-05-09

Virginia residents whose accounts are subject to the VCDPA (Va. Code § 59.1-575 et seq.) may exercise:

• Right of access — request a copy of personal data.
• Right to correct inaccuracies.
• Right to delete personal data.
• Right to data portability in machine-readable format.
• Right to opt out of targeted advertising — n/a; Koydo runs no advertising.
• Right to opt out of the sale of personal data — n/a; Koydo does not sell.
• Right to opt out of profiling in furtherance of decisions producing legal or similarly significant effects — Koydo Intelligence does not produce such effects (see /legal/automated-decisions).
• Right to appeal a denied request — appeals to privacy@koydo.app, subject "VCDPA Appeal." Response within 60 days; if denied, the Virginia Attorney General contact is included in the response.

Recurring-plan disclosures and cancellation controls are provided in purchase and account workflows.

Nothing in these Terms limits non-waivable protections available under Virginia law.

Virginia Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in the State of Colorado. Version: 2026-05-09 Effective Date: 2026-05-09

Colorado residents whose accounts are subject to the CPA (Colo. Rev. Stat. § 6-1-1301 et seq.) may exercise:

• Right of access, correction, deletion, and data portability.
• Right to opt out of targeted advertising — n/a; Koydo runs no advertising.
• Right to opt out of the sale of personal data — n/a; Koydo does not sell.
• Right to opt out of profiling in furtherance of decisions producing legal or similarly significant effects — opt-out via Account Settings → Privacy → "Disable Adaptive Learning"; see /legal/automated-decisions for logic disclosure.
• Right to appeal a denied request — appeals to privacy@koydo.app, subject "CPA Appeal."

Koydo honors universal opt-out mechanisms including the Global Privacy Control (GPC) browser signal as a valid CPA opt-out, consistent with the Colorado AG's regulations.

Koydo does not keep the source recording of a pronunciation exercise after processing it, and does not currently send the voice of a child under 13 to any outside provider. Sending it would require a parent's verified, separate and specific consent to send the child's personal information to that named provider for the stated purpose, and current evidence that the provider meets Koydo's requirements. To the extent any data could be characterized as biometric within the meaning of the CPA's biometric provisions, the consent regime in Privacy Policy §2.8 applies.

Recurring billing authorization and cancellation pathways are provided as part of checkout and account workflows. Nothing in these Terms limits non-waivable rights under Colorado law.

Colorado Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in the State of Connecticut. Version: 2026-05-09 Effective Date: 2026-05-09

Connecticut residents whose accounts are subject to the CTDPA (Conn. Gen. Stat. § 42-515 et seq.) may exercise: access, correction, deletion, portability, opt-out of targeted advertising / sale / profiling for decisions with significant effects, and appeal of denied requests (privacy@koydo.app, subject "CTDPA Appeal").

Koydo honors the GPC as a valid opt-out signal.

For Users under 16 in Connecticut, Koydo applies the heightened protections described in Privacy Policy §2 and §3, including no targeted advertising (n/a) and no sale of personal data (n/a). Where Connecticut law imposes additional protections beyond COPPA, those protections apply.

Recurring-subscription disclosures are presented before purchase, and cancellation access is provided through account controls or support. Nothing in these Terms waives non-waivable Connecticut consumer protections.

Connecticut Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in the State of Vermont. Version: 2026-05-09 Effective Date: 2026-05-09

For Vermont consumers purchasing auto-renewing subscriptions through Koydo:

• For subscriptions with a term of one year or more, a written reminder notice between 30 and 60 days before the next renewal date stating the renewal date, the cancellation method, and the renewal price.
• Clear disclosure at purchase of all material terms.
• Easy cancellation in Account Settings → Subscription, with no friction designed to deter cancellation.

Recurring charge disclosures and cancellation methods are provided with the objective of plain-language consumer notice. Nothing in these Terms limits non-waivable rights under Vermont law.

Vermont Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in any Member State of the European Union or the wider European Economic Area. Version: 2026-09-29 (supersedes 2026-05-09) Effective Date: 2026-09-29 Authoritative documents: /legal/terms-of-service and /legal/privacy-policy

This Addendum supplements the Terms of Service and Privacy Policy as they apply to Koydo Users in the EU/EEA. Where this Addendum and the body conflict, this Addendum controls solely with respect to EU/EEA Users.

For consumers residing in the European Union or European Economic Area (EEA), nothing in these Terms deprives you of the protection afforded by mandatory provisions of your country of residence.

The binding arbitration and class-action waiver provisions of TOS Section 11 do not apply to EU/EEA consumers. You have the right to bring legal proceedings in the competent courts of your country of residence.

If you reside in the EU/EEA, you have a statutory right to withdraw from a paid subscription within 14 days of purchase without giving any reason (Consumer Rights Directive 2011/83/EU), unless you expressly consented to immediate digital performance and acknowledged the loss of the withdrawal right. To exercise this right, contact support@koydo.app within 14 days.

To the extent required by EU law, the governing law of Texas (TOS §11.8) is superseded by the mandatory consumer-protection laws of your EU member state of residence.

The European Commission provides an Online Dispute Resolution (ODR) platform at ec.europa.eu/consumers/odr. Koydo's contact point for ODR is legal@koydo.app.

Data Controller. KOYDO LLC, 940 W. FM 544 #332, Wylie, Texas 75098-5157, United States, is the data controller for personal data collected through the Service. Contact: privacy@koydo.app.

Data Protection Officer. Koydo has not appointed a formal DPO under GDPR Article 37. Where Koydo becomes required to maintain a formal DPO, the appointment will be reflected at the international transfer notice. Pending such appointment, data-protection enquiries are handled by Koydo's Privacy Team at privacy@koydo.app.

EU Article 27 Representative. Robert Waltos, Jasionka 543, 36-002 Jasionka, woj. podkarpackie, Poland, privacy@koydo.app (see also the international transfer notice). Robert Waltos is also Koydo's founder and chief executive officer. EEA data subjects retain the right to lodge a complaint with the supervisory authority of their habitual residence; a list of national authorities is at edpb.europa.eu.

Lawful bases (Art. 6 GDPR).

• (a) Contract performance (Art. 6(1)(b)) — account creation, authentication, learning progress tracking, subscription management, and customer support.
• (b) Consent (Art. 6(1)(a)) — analytics (Mixpanel), opt-in adaptive learning (Koydo Intelligence), opt-in marketing/showcase use of co-created content (TOS §8.4(c)). Withdrawable at any time.
• (c) Legitimate interest (Art. 6(1)(f)) — security monitoring, fraud prevention, abuse detection, service-integrity protection. Balancing test performed and documented.
• (d) Legal obligation (Art. 6(1)(c)) — billing/tax retention, response to lawful requests, child-safety obligations.

Special-category data. Koydo does not intentionally collect data within Art. 9 GDPR. Koydo does not keep the source recording of a pronunciation exercise after processing it, and does not currently send the voice of a child under 13 to any outside provider; voice recordings are addressed in Section 2.8 of the Privacy Policy. Learning progress is not health data.

Children's data. For Users under the GDPR Article 8 age threshold (13 in some member states, 14, 15, or 16 in others — Koydo applies the stricter member-state threshold where higher than 13), Koydo requires verifiable parental consent before processing personal data beyond the minimum for account security. Tablefort, our account-free party games, is the exception: it relies on legitimate interests rather than consent, so these consent ages don't apply to it. It collects very little and deletes it within 2 hours; see the Tablefort section of the Privacy Policy. AI features are restricted for users under 13. Parents may request access, correction, or deletion of a child's data via privacy@koydo.app.

International transfers. See the international transfer notice. Transfers from the EEA to the U.S. and other third countries rely on EU SCCs Modules 2 and 3 with documented Transfer Impact Assessments under EDPB Recommendations 01/2020.

Retention. See Privacy Policy §8 for the per-category retention table, including the tiered AI-conversation retention (30 days under 13 / 90 days teens / 12 months adults).

Your rights under GDPR (Art. 15–22). Access, rectification, erasure, restriction of processing, portability, objection (including profiling), withdrawal of consent at any time, and the right not to be subject to a decision based solely on automated processing producing legal or similarly significant effects. To exercise any of these, contact privacy@koydo.app. Response within 30 days (extendable by 60 per Art. 12(3)).

Right to lodge a complaint. Direct complaints to the supervisory authority of your member state of residence (links at edpb.europa.eu).

Automated decision-making. Koydo's PRISM adaptive-learning system does not produce decisions with legal or similarly significant effects within the meaning of Art. 22. Detailed disclosure at /legal/automated-decisions.

EU/EEA Addendum v2026-09-29 — Effective September 29, 2026 — supersedes v2026-05-09

Applies to: Users physically located in or with primary residence in England, Wales, Scotland, or Northern Ireland. Version: 2026-05-09 Effective Date: 2026-05-09 Authoritative documents: /legal/terms-of-service and /legal/privacy-policy

This Addendum supplements the Terms of Service and Privacy Policy as they apply to Koydo Users in the United Kingdom.

For consumers residing in the United Kingdom, nothing in these Terms limits your statutory rights under the Consumer Rights Act 2015 or any other non-waivable UK consumer-protection legislation.

The binding arbitration provision of TOS Section 11 is not mandatory for UK consumers. You may bring proceedings in the courts of England, Wales, Scotland, or Northern Ireland depending on your place of residence.

You have a statutory right to cancel a paid digital subscription within 14 days of purchase, subject to your consent to begin digital service delivery immediately (Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013). To cancel, contact support@koydo.app.

Any unfair terms under the Consumer Rights Act 2015 are unenforceable against you to the extent they are unfair.

UK Data Controller. KOYDO LLC, 940 W. FM 544 #332, Wylie, Texas 75098-5157, United States, is the data controller for personal data processed in relation to UK Users. The UK GDPR (as retained in UK law by the European Union (Withdrawal) Act 2018) and the Data Protection Act 2018 govern our processing. Contact: privacy@koydo.app.

UK Article 27 Representative — pending appointment. See the international transfer notice for current status. UK data subjects retain the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by telephone at 0303 123 1113.

Lawful bases. Same as EU Addendum §2: contract, consent, legitimate interest, legal obligation. Mapped to UK GDPR Articles 6(1)(a)–(f).

Children's data — UK Age Appropriate Design Code (Children's Code). Koydo is designed to be used by children and implements the Children's Code standards, including:

• Privacy settings defaulted to high for child users.
• No nudge techniques that encourage children to weaken their privacy protections.
• No behavioral advertising targeting users under 18 — and indeed Koydo runs no advertising of any kind.
• Data minimisation for child accounts.
• Age-appropriate, plain-language privacy information — see the /legal/privacy-summary and the summary block at the top of the Privacy Policy.
• Detrimental use prohibited — Koydo does not use child users' personal data in ways that have been shown to be detrimental to their well-being.
• Profiling off by default for child users; PRISM is opt-in via Verifiable Parental Consent only.
• Parental controls at /parent/dashboard.

International transfers. Transfers from the UK rely on the UK Addendum to the EU SCCs (B1.0, 21 March 2022) issued by the ICO, executed alongside the EU SCCs. Where executed separately, Koydo relies on the UK International Data Transfer Agreement (IDTA). See the international transfer notice.

Retention. See Privacy Policy §8 for the per-category retention table, including tiered AI-conversation retention.

Your rights under UK GDPR. Access, rectification, erasure, restriction, portability, objection, automated-decision-making safeguards. To exercise, contact privacy@koydo.app. Response within one calendar month (extendable by two months for complex requests, Art. 12(3) UK GDPR).

Governing law for UK consumer matters. English law (or Scots law where applicable) applies to non-waivable UK consumer-protection issues, notwithstanding the Texas choice-of-law clause in TOS §11.8.

UK Addendum v2026-05-09 — Effective May 9, 2026

Applies to: Users physically located in or with primary residence in Switzerland or the Principality of Liechtenstein. Version: 2026-05-09 Effective Date: 2026-05-09

For Swiss Users, Koydo's processing is governed by the revised Swiss Federal Act on Data Protection (FADP), in force from 1 September 2023.

Swiss data subjects have rights of access, rectification, deletion, restriction, objection, and data portability substantially equivalent to GDPR. To exercise, contact privacy@koydo.app.

The right to lodge a complaint may be exercised with the Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch.

Transfers from Switzerland to the United States rely on the EU SCCs supplemented by the FADP-specific addendum recognized by the FDPIC. See the international transfer notice.

Nothing in these Terms limits non-waivable consumer rights under Swiss law.

Switzerland Addendum v2026-05-09 — Effective May 9, 2026