Privacy Policy

1. Who we are

Frim Sidekick is a French reading-comprehension library for Canadian French Immersion students in Grades 4 through 6. Parents create accounts; children sign in with a 4-digit PIN created by their parent.

2. The law that applies

We are a Canadian commercial activity and we comply with the federal Personal Information Protection and Electronic Documents Act (PIPEDA). Where a province has substantially similar private-sector privacy legislation — Alberta's PIPA, British Columbia's PIPA, Quebec's Law 25 — those laws apply to residents of those provinces and we honour them in addition to PIPEDA. We follow the ten PIPEDA fair-information principles: accountability, identifying purposes, consent, limiting collection, limiting use, disclosure and retention, accuracy, safeguards, openness, individual access, and challenging compliance.

Our accountable privacy contact is listed in section 12.

3. What we collect

From parents: email address, an encrypted password, and (optionally) a display name. We collect this to create your account and let you sign in.

From children: only a first name (or nickname) and a hashed 4-digit PIN that you, the parent, generate. We do not collect a child's last name, email, date of birth, school, photo, or location.

Activity data: which passages a child opens, their quiz answers, and quiz scores. This is used to show you progress and to suggest the right parent guide.

Billing data: if you subscribe, our payment processor (Stripe) collects payment details directly. We never see or store your card number. We store a Stripe customer ID, subscription status, and period end date.

Technical logs: standard server logs (IP address, browser type, timestamps) retained for up to 30 days for security and fraud prevention.

4. Where it's stored (data residency)

All account and child profile data, PIN hashes, reading history, and quiz attempts are stored in Canada, in the Montréal region (ca-central-1), using Supabase as our database and file-storage provider. This core personal information never leaves Canadian soil.

5. Service providers (subprocessors)

We rely on a small number of vetted service providers to run the service. Some are located outside Canada; in those cases, only the limited data described below is shared with them, and never any child personal information.

• Supabase — database, authentication, file storage. Region: Canada (Montréal). Receives: all account and activity data.
• Stripe — subscription billing. Region: United States. Receives: parent email, billing address, payment details (entered directly into Stripe).
• Cloudflare — application hosting and CDN. Receives: technical request data (IP, user-agent, URL).
• Google (Gemini API) — AI passage and guide generation. Region: United States. Receives: only the topic, grade, and reading level we ask it to write about. Never receives child or parent personal information.
• OpenAI — French narration (text-to-speech). Receives: only the public passage text. Never receives child or parent personal information.
• Plausible Analytics — privacy-friendly site analytics. Cookie-free, no cross-site tracking, no personal profiles. Aggregated pageview counts only.

If we add or change a subprocessor that handles personal information, we will update this list and notify account holders by email before the change takes effect.

5a. Cross-border processing

Stripe, Google, OpenAI, and Cloudflare process certain limited data outside Canada (typically in the United States). Information held in another country is subject to the laws of that country, which may permit foreign government access. By creating an account, you consent to this limited cross-border processing for billing, hosting, and AI content generation. The bulk of personal data — accounts, child profiles, PIN hashes, reading history, and quiz attempts — remains in Canada at all times.

6. How we use the information

• To run the service: signing you in, showing your children the library, scoring quizzes, displaying progress.
• To recommend the right parent guide based on what your child recently opened.
• To bill subscriptions (handled by our payment processor).
• To meet legal obligations and respond to your privacy requests.

We do not sell personal information. We do not show advertising to children. We do not use personal information to train AI models.

6a. How AI is used — and not used

We use AI services to generate the reading passages, illustrations, audio narration, quizzes, and parent discussion guides that you see on Frim Sidekick. AI is used as a content creation tool only.

Children never interact directly with AI on this platform. There are no chatbots, no AI assistants, and no AI-generated responses to anything a child does. AI is not used to assess, evaluate, or make decisions about a child's reading level, progress, or abilities. Reading levels are selected by parents, and any progress or recommendations are based on simple, deterministic rules that parents control.

AI has no two-way communication with children. A child's click, quiz answer, or page view does not feed back into an AI model or generate a personalized AI response.

7. Your rights

Under PIPEDA (and provincial equivalents) you have the right to access your personal information, to correct it, to withdraw consent, and to challenge our handling of it. You can, at any time, from Account & privacy:

• Download your data as a JSON file (your profile, your children's profiles, reading history, quiz attempts).
• Delete your account. Child PINs stop working immediately. After a 30-day grace period (during which you can cancel), all your data is permanently deleted. We keep a one-way hashed record of the deletion for 24 months as proof of compliance; no personal information is retained.
• Correct your information by editing your profile or your children's profiles directly in the dashboard. For anything you cannot edit yourself, email the address in section 12.
• Withdraw consent by deleting your account. Some withdrawal is incompatible with continued service (we cannot run an account without an email address).

If you are not satisfied with our response to a privacy request, you may file a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca) or with your provincial privacy commissioner (in Alberta, British Columbia, or Quebec).

8. Security safeguards

Passwords and child PINs are stored as one-way hashes — we cannot read them. Database access is restricted by row-level security so parents only see their own children's data and children cannot read parent-only material (e.g. quiz answer keys, parent guides). Data is encrypted in transit (TLS) and at rest. We follow the principle of least-privilege for administrative access.

If a privacy breach involving a real risk of significant harm occurs, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by PIPEDA's breach-reporting rules.

9. Children

Parents create and control child profiles. The information collected about a child is intentionally minimized to a first name (or nickname) and a PIN you generate. We rely on the parent's consent (recorded at sign-up) to process that information, in line with PIPEDA guidance for processing personal information about children. Children do not see ads, are not profiled for marketing, and their data is never sold or shared with third parties beyond the subprocessors listed in section 5.

9a. Retention

We retain account and activity data while your account is active. When you delete your account, data is permanently erased after a 30-day grace period. Technical logs are retained for up to 30 days. Billing records required by Canadian tax law are retained for 6 years.

10. Changes

If we materially change this policy, we will email account holders before the change takes effect.

11. Cookies and analytics

We do not use advertising or tracking cookies. We use a single first-party cookie to keep you signed in. For analytics we use Plausible, which is cookie-free and does not build cross-site profiles of you.

12. Contact / Privacy Officer

Our designated privacy contact (Chief Privacy Officer for PIPEDA purposes) is reachable at privacy@frimsidekick.ca. We respond to privacy requests within 30 days, as required by PIPEDA.