XOUL is an emotional monitoring platform that passively analyzes digital behaviors. It uses artificial intelligence and machine learning to detect emotional and behavioral patterns based on the use of applications, sensors, social networks and other digital signals from smartphones.
We believe that accompanying children and adolescents in the digital world does not have to involve invading their privacy. Our application is designed to protect the privacy of children and the third parties they interact with.
We have applied privacy by design to ensure best practices for protecting the personal data of those who use our application and their environment.
Here we tell you how we process personal data and how to exercise your rights over them.
This privacy policy is complemented by the terms and conditions for using our service.
We are LosSales LLC, a commercial company that owns' Xoul ', with registered address at 131, Continental Dr, Suite 305, Newark, DE 19713, United States. We are responsible for the processing of the personal data of those who use our application and visit our website.
- When a father or mother downloads our application and subscribes, we need their identification data, name, address, age, email and telephone number.
- When you register your dependent son, daughter, boy or girl, we need some personal data to be able to provide the service: your identification data, your identification to verify consent, your telephone number, address and the data of your parents.
- As part of the monitoring process, the artificial intelligence system we use deals with the digital behavior of the supervised user: the time spent using the cell phone, the time of use, the applications and the content of the communications. You can have authorized access to your messages and content. It processes data about your routine, school schedules, social environment, activities, and other related activities.
- The messages and metadata used to generate a report are deleted immediately after the system produces an observation. The reports and observations that we share with parents are also considered personal data.
- We collect persistent identifiers such as IP address and device identification number (Device ID), necessary for the operation of the application.
- When the AI system processes messages from the supervised user, it sometimes accesses the personal data of third parties, such as telephone number and name. This data is pseudonymized to ensure privacy. The system blocks any other personal data of third parties such as address, email or telephone number. This data is not processed.
- When you visit our website, we process your browsing data and your location in accordance with the Cookies policy detailed below.
- Our associated billing platform will process the data necessary to manage the collection of the subscription.
We process the above-mentioned data to be able to provide you with the monitoring service, to be able to carry out the reports provided by our artificial intelligence system and to send you alerts if necessary.
Our application uses artificial intelligence techniques to analyze the digital behavior of the supervised user and generate automated reports on the child's behavior, emotional state and social relationships. This treatment is carried out in order to provide parents with respectful and preventive support tools.
Since these reports may contain personal evaluations that influence relevant decisions about the boy or girl, we inform that this treatment can be considered behavioral profiling under the terms of current legislation.
Profiling is carried out based on:
- Data obtained on the digital behavior of the supervised user.
- Data obtained from monitored conversations.
- Non-deterministic algorithmic criteria.
- Automatic evaluation of aspects such as emotional expression, conflict management, friendly relationships or situations of digital risk.
Every profile generated is subject to human review prior to delivery to parents, and automated decisions are not taken with legal or significantly similar effects on the child.
Human monitoring is carried out on pseudonymized reports to protect privacy.
The processing of personal data for these purposes is carried out on the legal basis of the explicit consent granted by the account holder, as required by the Delaware Personal Data Privacy Act (DPDPA).
We do not profile the third parties with whom the child interacts.
Automated decisions with legal or significantly similar effects are not made.
Nor do we carry out any type of marketing-related activity with the information collected.
In the case of browsing data, we process them in order to improve your experience when visiting our website.
- Consent: when you register and create your account, we request your consent to process your data. We verify the parent's consent in accordance with the law (COPPA).
- Execution of a contract: when we use your data to provide the requested service.
- Compliance with legal obligations: to comply with tax or data protection obligations.
Own legitimate interest: to improve the service, perform statistical analysis or protect the security of the application or website.
- Legitimate interest of the parents and the child: when processing the personal data of third parties who interact with the child. You can object at any time to the processing of your personal data based on our legitimate interest, by contacting us at the indicated email address. We will evaluate your request based on legal criteria
- With our cloud server provider, Google Cloud Platform, under strict security commitments. Privacy policy: https://cloud.google.com/privacy. Data is always encrypted in transit and at rest.
- If it is necessary to make an international transfer, we will do so taking the necessary precautions to ensure security.
- We share the observations generated by our system with parents. Parents are responsible for the processing of their children's personal data from the moment they receive the observations.
- In order to manage payment for the service, the payment platform can process the data necessary to manage the collection of the service.
The data will be securely stored on our Cloud server whose provider is Google Cloud Platform. Privacy policy: https://cloud.google.com/privacy
- The data linked to your subscription are kept for a maximum period of 4 years from the time you request to cancel the subscription.
- The data of supervised users are deleted immediately after the subscription is canceled.
- The data included in the observations are deleted immediately as soon as you request to unsubscribe.
- The data of third parties who interact with the supervised user contained in the monitored messages are deleted immediately after the system produces the observation.
- To protect the privacy and security of users and third parties, information will be deleted without exception, as described above.
You can exercise them by sending an email to soporte@xoul.me, proving your identity. Requests will be answered within 30 days. If you disagree with our response, you can request a review within 45 days.
If you believe that any of your rights have been violated, you can file a complaint with the competent authority in the state of Delaware: Delaware Department of Justice — Consumer Protection Unit
Web site: https://attorneygeneral.delaware.gov/fraud/cpu/
- Access your personal data.
- Rectify inaccurate data.
- Request deletion when they are no longer necessary.
- Oppose or limit your treatment.
- Porting your data to another service provider.
- Limit the processing of your data.
- Request a review if your request has been denied.
Cookies are small files that are stored locally on your computer over the internet.
Our site uses cookies and/or similar technologies that store and retrieve information when you browse the internet. These technologies allow the web space to recognize your browser and, as a result, store your user preferences.
It also allows the advertising you see when browsing to be adjusted to your interests and preferences. We use our own and third-party cookies, which you can accept or decline in the options menu that appears when you enter our website.
We have considered the legitimate interest in processing the data of third parties:
We have carried out a prevalence analysis between the legitimate interest invoked, its need, the existence of less intrusive means and the risks to the rights of third parties who interact with the child whose conversations are processed by our system.
The legitimate interest invoked is that of children and their parents or legal guardians in:
- Ensure the physical and emotional safety of children in the digital messaging environment.
- Detect risks such as grooming, bullying, harassment or exposure to inappropriate content.
- Accompany the child's psychoaffective development.
In a digitized environment, parents often review the conversations their younger children have with third parties. It is a generalized domestic practice that, while always invasive, is usually not effective.
The objective of detecting risky behaviors or situations requires analyzing the content of the child's conversations, which inevitably involves the processing of data from the third parties with whom the minor communicates (other children, adolescents, adults). Doing so in an effective and less invasive way requires the use of AI techniques or automated analysis to generate reports or alerts.
Checking the phone manually is no less intrusive. The purpose of the tool is also to protect the child's privacy by allowing the parent to monitor their activity without having to manually check the device.
Security measures and respect for privacy are applied, such as:
- Limited extraction of data, metadata and/or patterns instead of full text.
- Blocking the processing of personal identification data of third parties, names, addresses, emails.
- Pseudonymization of child and third party data.
- Immediate removal of messages and their content, retaining only an observation in which personal references from third parties are not included.
- Encryption in transit and at rest of information.
- Immediate deletion of data.
- Secure data governance.
- That their communications be accessed without their knowledge or consent.
- That your personal information (name, images, opinions, emotions) is processed without sufficient legal basis.
- That the data be used to generate inferences or profiles without your informed participation or consent.
- That your data is leaked in a security breach or breach.
- That the data of children under 13 years of age are treated without parental consent.
There is a direct relationship between the interest invoked and the processing of third-party data. There are no less intrusive means to achieve the purpose of safeguarding children's digital security. We consider that the expectation of privacy of those who interact with a child is low or zero.
The processing of personal data is minimal, for a very short period of time, with guarantees such as the pseudonymization of third parties, the encryption of information and the blocking of the processing of personal identifying data. No company employees are involved in the processing, it is automatic. The reports are reviewed on the observations produced by the system, which contain pseudonyms and do not contain identifying data.
Finally, the processing is followed by the immediate removal of the data.
We conclude that it is feasible to base the processing on the legal basis of the legitimate interest of the child and his parents.
We may need to modify or update this privacy policy, so we reserve the right to do so.
- I declare that I am the father, mother or legal guardian of the minor that I will register as a Supervised User.
- I expressly authorize Xoul (LosSales LLC) to process my personal data and those of my dependent child or minor in accordance with the Privacy Policy and the Terms and Conditions of the service.
- I have read and understood the purposes of the treatment, the security measures applied, and the rights that I have as a data subject.
- I understand that the child's data will be treated for the purpose of digital supervision and automated reporting, without human access to conversations and with immediate removal of the messages and data analyzed.
- I grant this consent in a free, specific, informed and unambiguous form.
XOUL gives you private reports with risks, emotions and important moments, always from a respectful approach.
