Our privacy policy
PROTECTION OF PERSONAL DATA (GDPR and French Data Protection Act)
As the data controller in the context of its activities, Excello processes personal data concerning you. Excello places great importance on safeguarding your personal data. All personal data processing under this Privacy Policy complies with applicable regulations, including the amended French Data Protection Act of January 6, 1978, and the General Data Protection Regulation (EU Regulation 2016/679 of April 27, 2016), known as the “GDPR“.
In accordance with legal requirements and to ensure these rules are properly applied, Excello maintains a data registry.
This Personal Data Protection Policy may be updated on the excellolab.org website. We encourage you to review it regularly.
The Privacy Policy applies to Excello’s services when students use our applications, and when teachers and/or the child’s guardians use our platform.
This Privacy Policy is intended to inform users of Excello’s service about:
- The personal data we collect, understanding that “personal data” means “any information relating to an identified or identifiable natural person.”
- The purpose (use) of collecting these data.
- With whom we share these data.
- How long and where we store these data.
- Who is responsible for processing any collected and processed personal data.
- The rights of Users regarding their data.
- Our policy on “cookies.”
- The legal basis for processing (Lawfulness of processing).
This Privacy Policy supplements the Legal Notice and the General Terms of Use established by the data controller.
1. What Data Do We Collect?
Depending on the Excello services you use, we collect and are responsible for the following types of data:
- Identification Data for Adult Users : First Name or Alias/Login, Class, Email, Department
- Identification Data for Minor Users : First Name or Alias/Login, Class, Possible association with a teacher
- Identification Data for Teachers : Last Name, First Name, Department, School Type (e.g., REP program, non-REP), Email
- Browser and Connection Data
These data are collected when users create an account on excellolab.org (or via any path stemming from this site).
Data Collected by Excello on Our Applications and Platforms
User and Activity Data :
- User alias (pseudo)
- Students’ audio data (anonymized, not linked to identifying information)
- Verb, Result.success, Result.duration, Object
- Class code, Activity name and ID, Exercise name and ID
- Team or pair name, Team members, Team ID
- Answer, Response mode, Display mode, Gameplay mode
- Assignment ID, Hid
Progress and Interaction Data
- Session dates, Exercise session, Course session
- Course type, step, and ID
- Skills, prerequisites, and common errors in an exercise
- Percentage of correct and incorrect answers
- Activity duration, remote supervision
- Automatic course completion in “assessment mode,” Holo
Additional Data :
- Content interactions: attempts per exercise, videos watched, quizzes completed, time spent
- Feedback data: user comments or ratings
- Personalization settings: difficulty level, visual themes, languages
- Technical data: device type, operating system, browser version, screen resolution
- Connection history: login and logout dates and times
- Notification interactions: opens, clicks
- This list aims to provide full transparency regarding the types of data Excello collects and processes to enhance the educational experience and ensure efficient, secure use of our platform.
These data are collected when students engage in activities on the application or our platform.
They may evolve as needed for the proper functioning of the project and product.
2. Why Are These Data Collected?
The processing of personal data relating to users (parents, minors, and teachers)—which entails collecting and storing information about their use of Excello’s service and tools—serves the following purposes:
- Creating statistics for parents and teachers: tracking children’s/student progress, suggesting groups and adaptive learning paths
- Handling inquiries and requests from families and teachers
- Managing requests to access, correct, and object to data processing
- Ensuring platform security to prevent spam and abuse
3. Data Minimization and Relevance
We pledge to limit our data collection to what is strictly necessary for the intended processing purpose. Without these data, we would be unable to provide Excello’s services at a satisfactory level of quality.
4. With Whom Do We Share These Data?
To ensure the highest possible quality of service, we may share collected data with various authorized recipients:
- Our internal teams: Technical and functional administrators involved in developing, improving, and maintaining Excello products.
- Parents/Teachers using the service: For their own data and the data related to the children/students under their supervision.
- Minor users of the service: For their own data regarding activities, scores, and progress.
- Our subcontractors:
- Microsoft Azure for converting audio streams into text. This subcontractor is essential for voice-to-text transcription.
- AWS for server hosting. These subcontractors are central to the solution, enabling server hosting, storage, and computations.
- WordPress for the website.
- WPForms, an email tool for excello.org websites.
- Zoom, a videoconferencing tool for webinars, enabling project participants to communicate. This subcontractor provides support services.
The data controller guarantees that its subcontractors comply with GDPR regulations and that no personal data will be transferred outside the European Union.
5. How Long Do We Keep Your Data?
We store your data in our databases for the period necessary to fulfill the intended purpose. After this period, the data are either deleted or archived in accordance with current legislation.
For more details on retention periods, please see the summary table below:
| Data Type | Retention Period |
| Identification data linked to user accounts (parents, teachers, minors) | 1 year after last login |
| User activity data, user history once anonymized | Not applicable: data are anonymized. As a research-based organization, we maintain an anonymized usage database for research purposes. |
| Student activity data, student history | 1 year after last login |
| Audio data | Not applicable: these data are anonymized |
| Browser and Connection Data | 30 days after data generation |
6. What Are Your Rights to Your Data?
You have the right to access, rectify, and delete your personal data.
You can request access to or deletion of data collected about the child for whom you are responsible by sending your request to: contact@excellolab.org.
To learn more about your data protection rights: https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles
7. Minors
In accordance with the revised French Data Protection Act (reflecting GDPR requirements), which sets the “digital age of consent” at 15, and to protect the personal data and privacy of minors, we require the consent of the individual holding parental authority for any child under 15. This consent covers the collection of all data concerning them, including the child’s use of Excello applications and platforms (notably actions performed and associated voice recordings).
8. Security
We implement all technical and organizational measures necessary, in light of the nature of the personal data you entrust to us and the risks involved in processing them, to preserve the security of your data and prevent them from being distorted, destroyed, or damaged, or from unauthorized third-party access.
To this end, we use technical safeguards (firewalls) and organizational measures (a unique ID and password system for each of our internal or external collaborators, physical security measures, etc.).
The site uses an SSL certificate to ensure that the information and data transfers passing through it are secure.
An SSL (“Secure Socket Layer”) certificate secures data exchanged between the user and the site.
9. Cookies and Trackers
We may place cookies on your device for two purposes: - To maintain your session on the Excello service. - To gather statistics.
Cookies include details about:
Pages viewed, site searches, downloads, geographic origin, devices used, browser, timestamps, user ID
These measures are strictly necessary for the proper administration of the site.
10. Changes to This Privacy Policy
The data controller reserves the right to modify this policy to ensure it remains compliant with current laws.
Consequently, users are invited to check this policy regularly to stay informed of any changes made.
11. Filing a Complaint with the CNIL
If you believe, after contacting us, that your data rights have not been respected, you may submit a complaint to the CNIL (French data protection authority): https://www.cnil.fr/fr/webform/adresser-une-plainte