Privacy Policy

Effective Date: 1st of July, 2026

1. Introduction

Tokno is a service provided by Tokno AB ("we," "us," or "our"). This Privacy Policy explains how we collect, use, share, retain, and protect personal data when you use Tokno.

"Customer" means the parent or legal guardian, aged 18 or older, who creates and manages the account. "Student" means the person invited by the Customer to use the learning service.

2. Data Controller

Tokno AB is the data controller responsible for your personal data. If you have any questions about this Privacy Policy or your personal data, contact us at hello@tokno.com.

  • Tokno AB
  • Storehagen 3, 511 99 Sätila, Sweden
  • Company registration number 559515-6539
  • VAT number SE559515653901

3. Information We Collect

  • Customer account and contact information, including name, email address, and an optional phone number.
  • Student profile information, including phone number, name, nickname, birth year, profile description, goals, preferences, availability, and information provided by the Customer. Phone numbers and profile descriptions are encrypted at rest.
  • Homework, exam material, documents, images, text, and other study material uploaded or entered into Tokno, including content extracted from uploaded files.
  • Study topics, objectives, answers, assessments, progress, session history, and reports generated from learning activity.
  • Messages exchanged through the Tokno website, WhatsApp, or iMessage, including information voluntarily included in those messages. Messages are encrypted at rest.
  • Ratings, feedback, and testimonials that you choose to give us.
  • Browser, device, approximate location, language, referral source, campaign, page activity, cookie preference, and pseudonymous identifier data.
  • Subscription status and transaction records. Our payment provider processes complete payment-card details; Tokno does not store them.

4. Legal Basis for Processing

We process personal data only when a legal basis applies:

  • Contract: To create accounts, provide tutoring, personalize the service, process subscriptions, and provide support.
  • Consent: For optional analytics and marketing cookies, marketing email, and other processing where we specifically ask for consent. You may withdraw consent at any time.
  • Legitimate interests: To secure Tokno, prevent fraud, understand service performance, improve the learning experience, use feedback and testimonials in anonymized form in our marketing, and protect our legal rights, where those interests do not override your rights.
  • Legal obligations: To retain accounting records, respond to lawful requests, and meet other obligations under applicable law.

5. How We Use Information

  • To create, authenticate, and protect accounts.
  • To provide and personalize tutoring and study features.
  • To process study material and messages with artificial intelligence providers and generate responses, summaries, assessments, and learning recommendations.
  • To communicate service updates, answer questions, and provide support.
  • To show ratings, feedback, and testimonials in anonymized form in our marketing, on our website, and inside Tokno. We remove names and other identifying details first. Email hello@tokno.com if you want us to stop using your feedback.
  • To process subscriptions, refunds, and accounting records.
  • To analyze service usage, review conversation quality, improve Tokno, prevent misuse, and comply with legal obligations.

Tokno does not use automated processing to make decisions that produce legal or similarly significant effects.

6. Service Providers and Data Sharing

We do not sell personal data. We share only the information needed to provide, secure, and improve Tokno with service providers acting on our instructions:

  • Infrastructure providers for authentication, databases, file storage, and hosting.
  • The artificial intelligence providers used to generate tutoring responses and to translate feedback.
  • A payment provider for subscriptions, payments, and refunds.
  • An analytics provider for product and conversation analytics, which receives pseudonymized user and session identifiers, event metadata, conversation content, and the feedback you give us. Message content may itself contain personal data and is encrypted at rest.
  • Communication providers for email and SMS verification.
  • Messaging providers for the WhatsApp and iMessage account and messaging integrations.
  • A file-processing provider for converting supported uploaded documents.

We may also disclose information when required by law, to respond to valid requests from public authorities, or to establish, exercise, or defend legal claims.

7. International Data Transfers

Some service providers process data outside the European Economic Area. When required, we use an adequacy decision, the European Commission's standard contractual clauses, or another lawful transfer mechanism and apply appropriate safeguards.

8. Data Retention

We retain personal data only as long as needed for the purposes in this Policy or as required by law. The following periods apply:

  • A deleted Customer account remains recoverable for 30 days before the account data becomes eligible for permanent deletion.
  • Conversation copies stored for analytics are retained for up to 90 days.
  • Product analytics events, ratings, and feedback may be retained for up to 25 years in pseudonymized form.
  • Billing and accounting records are retained for the period required by applicable law.

Some information may remain longer in backups, security logs, or records that we must retain by law. We restrict its use until it can be deleted.

9. Your Rights Under GDPR

Depending on the circumstances, you may request access, rectification, erasure, restriction, portability, or object to processing based on legitimate interests. You may withdraw consent at any time without affecting processing that occurred before withdrawal.

To exercise a right for yourself or a Student whose account you manage, contact hello@tokno.com. We may need to verify your identity and authority before completing the request.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption at rest for phone numbers, profile descriptions, and messages, encrypted connections, access controls, and secure server environments.

11. Students Under 18

Only a Customer aged 18 or older may create the account, purchase a subscription, and invite a Student. The Customer confirms that they are the Student's parent or legal guardian and are authorized to provide the Student's information to Tokno. The Customer can manage the Student's account and make privacy requests on the Student's behalf where permitted by law.

12. Cookies and Tracking Technologies

Tokno uses essential cookies for authentication, device security, language, and recording your tracking preference. Optional analytics and marketing cookies are used only after consent.

If you accept analytics cookies, Tokno stores a random browser identifier so visits can be understood across sessions. If you reject them, or use Tokno while logged in without a stored choice, limited server-side analytics may use an identifier derived from the request IP address and user agent that changes every 20 minutes. The raw IP address is not sent to our analytics provider.

Conversation analytics are part of operating and improving the service and are not controlled by the website cookie preference. Conversation content is retained by our analytics provider for up to 90 days with pseudonymized user and session identifiers, and is encrypted at rest.

With consent, we use tag management and conversion tracking from third-party advertising platforms, processed through a server-side tagging service. Where supported, personal identifiers such as email addresses are hashed before transmission.

You can accept or reject optional cookies in the consent banner. You can withdraw consent by clearing your cookies and revisiting the site. Browser settings can also block cookies, although blocking essential cookies may prevent Tokno from working correctly.

13. Changes to This Privacy Policy

We may update this Privacy Policy when our practices, providers, or legal obligations change. We will notify Customers of significant changes by email or through the service before they take effect where required.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us at hello@tokno.com.

15. Complaints

If you believe that our processing of your personal data infringes data protection laws, you have the right to lodge a complaint with a supervisory authority. In Sweden, this is Integritetsskyddsmyndigheten (IMY).

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