Privacy Policy

1. Data Controller

The data controller for the Trilingal Platform is its operator. Full legal identification (company name, registered address, and tax identification number) is being finalized and will be published in this section.
Contact for privacy matters: [email protected].

2. Applicable Legal Framework

Processing of personal data through the Platform is governed primarily by:

• Law No. 18-07 of 10 June 2018 on the Protection of Natural Persons in the Processing of Personal Data, as amended and supplemented by Law No. 25-11 of 24 July 2025, supervised by the National Authority for the Protection of Personal Data (Autorité Nationale de Protection des Données à Caractère Personnel — "ANPDP");
• Articles of the Algerian Constitution protecting private life and the confidentiality of personal data and correspondence;
• Law No. 15-12 of 15 July 2015 on Child Protection;
• Law No. 09-04 of 5 August 2009 on the Prevention and Combat of Information and Communication Technology-related Offences;
• Law No. 18-05 of 10 May 2018 on Electronic Commerce and Law No. 09-03 of 25 February 2009 on Consumer Protection and Fraud Suppression, where the processing relates to an online transaction.

3. Data We Collect

• Account data: Guardian's name, email address, and phone number; child's first name or chosen nickname and age band/grade level.
• Usage data: learning progress, quiz scores, module completion, and in-app activity.
• AI interaction data: content submitted to and generated by the AI conversation and learning modules.
• Technical data: IP address, device and browser type, and cookies (see Section 10).
• Payment data: processed directly by our payment service provider; we do not store full card numbers.
• Communications: support requests and newsletter subscription details.

4. Purposes and Legal Bases

We process personal data to: provide and personalize the learning service (performance of the contract with the Guardian); maintain account and platform security; comply with legal obligations (accounting, tax, and ANPDP requirements, and lawful requests from competent authorities); improve the service through aggregated, de-identified analytics; and, where the Guardian has given specific consent, send optional newsletters or marketing communications and set non-essential cookies.

Where the data subject is a child, processing is carried out solely on the basis of the Guardian's express, informed, and revocable consent, given as the child's legal representative, in accordance with Articles 3 and 7 of Law No. 18-07.

5. Children's Privacy — Special Safeguards

The Platform is directed at children under the Algerian age of majority (19 years). We apply the following safeguards, by design and by default, to child profiles:

• A child cannot create or control an account independently; every child profile is created and managed under a Guardian's account.
• We minimise data collected from a child: a nickname is used instead of a full legal name where possible, and we do not request a child's precise geolocation, phone number, or home address.
• We do not use a child's profile for behavioural advertising or ad targeting, and we do not sell, rent, or disclose a child's personal data to third parties for their own marketing purposes.
• AI conversation and chat features are filtered and moderated and do not allow direct, unsupervised messaging between a child and other users or unknown adults.
• In accordance with Article 10 of Law No. 15-12 and applicable Penal Code provisions protecting a child's image and personal integrity, we do not use a child's photo, video, voice recording, or testimonial for marketing or publicity without the Guardian's separate, explicit, written authorization.
• The Guardian may access, correct, export, or request deletion of the child's data at any time by contacting [email protected].
• If we discover that a child's personal data was collected without valid Guardian consent, we will delete it promptly and, where appropriate, notify the Guardian.

6. Sharing of Data and Processors

We share personal data only with service providers acting on our instructions and bound by confidentiality and security obligations, including hosting/infrastructure providers, the artificial-intelligence provider(s) used for the AI conversation module, email/newsletter service providers, and payment processors. We do not sell personal data.

Where a service provider processes data outside Algeria, such transfer takes place only where appropriate contractual and technical safeguards are in place and, where required by Law No. 18-07, following the applicable prior declaration to, or authorization from, the ANPDP.

7. Data Retention

Personal data is retained only for as long as necessary for the purposes described above, for the duration of the account, plus any additional period required by Algerian law (including accounting, tax, and limitation-period obligations). Inactive child accounts may be flagged to the Guardian for confirmation, archiving, or deletion.

8. Security

We apply technical and organizational measures appropriate to the sensitivity of the data processed, including encryption in transit, access controls, and staff confidentiality obligations. In the event of a data breach likely to affect the rights and freedoms of data subjects, we will notify the ANPDP and the affected Guardians in accordance with Law No. 18-07.

9. Your Rights

In accordance with Law No. 18-07, the Guardian, acting on behalf of the child, and any adult user, may exercise the right of access, rectification, and objection or erasure of their personal data, and may lodge a complaint with the ANPDP. Requests may be sent to [email protected]; we may request proof of identity and, where applicable, of guardianship, before acting on a request.

10. Cookies

We use strictly necessary cookies to operate the Platform (session and authentication) and, subject to consent where required, functional and analytics cookies to improve the service. Cookies can be managed through your browser settings at any time.

11. Changes to this Policy

We may update this Privacy Policy from time to time. Material changes will be notified through the Platform or by email to the Guardian. The date of the latest revision is shown at the top of this page.

12. Contact and Supervisory Authority

Data Controller contact: [email protected].
Supervisory authority: Autorité Nationale de Protection des Données à Caractère Personnel (ANPDP), People's Democratic Republic of Algeria.