Privacy Policy

Last Modified: December 3, 2024

By default, we do not collect any personal information, including audio recordings, from children under 13 without parental consent.

This Privacy Policy applies to our Service, which includes:

website talkierobie.com, including the content, features, applications, and products we offer on it;educational mobile application "Talkie Robie" for iOS and Android, also referred to as the “App”;other related websites, applications, and services that link to this Privacy Policy.

Your use of our Service is subject to this Privacy Policy and our Terms of Use. Only parents or legal guardians may create accounts, make payments, or provide consent for children's use of the Service.

Please read this Privacy Policy carefully. For questions or to exercise your data protection rights, contact us via email as specified in Section 1 (Contact Details).

We may update this Privacy Policy to comply with applicable laws. Material changes will be announced through prominent notice or direct notification. Your continued use after changes indicates acceptance of the new Privacy Policy. If required under the law, we will obtain your necessary consent.

This Privacy Policy does not cover third-party activities outside our control. Please review third-party privacy policies before sharing information with them.

1. TALKIE ROBIE CONTACT DETAILS

"We", "us" or "Talkie Robie" in this Privacy Policy refer to TALKIE ROBIE. For the purposes of data protection regulations, including the General Data Protection Regulation 2016/679 (GDPR), Talkie Robie is the controller of data received through the Service.

For privacy-related inquiries or to exercise your or your child’s data rights:

Email: info@talkierobie.com

We aim to respond to all privacy-related inquiries within 24 hours.

Contact for general Services info@talkierobie.com

2. CHILDREN'S PRIVACY

We take children's privacy seriously and maintain strict compliance with the Children's Online Privacy Protection Act (COPPA).In this Privacy Policy by a “parent” we mean the child's parent or legal guardian.

Core Privacy Protection for Children's Information

To protect privacy, the Service uses stronger privacy settings by default prior to receiving verifiable parental consent:

All speech recognition occurs locally on the user's device. No speech transcripts are collected, transmitted, stored, or shared online.

Only local notifications are enabled by default in the App; no remote push notifications or emails are sent.

Children cannot sign-up (create an account); accounts can only be created after a verified adult has given explicit parental consent.

Users cannot provide their email addresses or other credentials by default until they give explicit consent for personal information collection and complete the subscription process. This restriction applies to all App interfaces, including settings and onboarding flows.

If a child contacts us for support, we may ask them for a parent’s email address to notify their parents about their request. This is the only personal information as defined by COPPA, that we collect from children without verifiable parental consent.

Parental Gate protects sensitive features with an age screen.

Verifiable Parental Consent

The App uses two-step verification process includes:A "Direct Notice to Parent" screen that appears after clicking the Subscribe button, outlining Talkie Robie's data collection practices and parental rights.

Payment confirmation, which verifies adult status and completes the consent process.

Parental Rights

Our Services can be used by children with permission from a parent or legal guardian. Only parents should:

Install the App

Make payments

Create and manage accounts

Provide child-related information

Access privacy settings and controls

Grant or withdraw consent for data collection

Information Collection

We may collect additional Child’s information: first name, age, gender or English proficiency level.With explicit parental consent we may collect voice recordings.Parental consent also makes optional data collection features available in the App, such as:

Providing a parent’s email address for parent account creation and to enable account-related communications

Providing a parent’s email address to receive reports on a child’s progress and app updates

Enabling remote push notifications to receive lesson reminders/any other push notification messages

Voice Recording Management

Our App involves children interacting with an AI character through voice. Under COPPA, audio recordings of children's voices are considered personal information.

When enabled through Parental consent:Recording happens exclusively during specific voice exercises. No audio recording occurs outside designated voice exercises.

Data is sent to the AI model on Amazon AWS and is not stored.

Progress Data Management

The app doesn’t collect, share or transmit online children’s progress data by default, it’s stored locally on-device. Online collection begins only after obtaining explicit parental consent and account creation. Account-linked progress data stored on Google Firebase servers. Account data deletion triggers associated progress data removal.

Privacy Controls

Parents may contact us to info@talkierobie.com in order to request and review information about our privacy practices and personal information we process, including information on a child, to delete data, to manage communication preferences or prevent the further collection or use of personal information from their children, or withdraw consent at any time.

In addition,Parents may request a child's data deletion via Email to info@talkierobie.com.Parents can manage push notifications through device settings.Parents can opt out of marketing emails via unsubscribe links in email messages.

3. WHY WE COLLECT INFORMATION

Core Collection Principles

We collect and use data for these purposes:

1. Contractual Obligations:

To provide our products and Service

To process payments

2. Legitimate Business Interests:

Account management and personalization

Technical and customer support

Payment processing

Service maintenance and security

Market analysis and product development

Quality improvement

3. Provided by your consent

Service notifications and updates

Pricing information and special offers

Data Collection Scope

We only collect information that is:

Reasonably necessary for service operation

Protected by appropriate security measures

Subject to parental control and oversight

Used exclusively for improving educational services

4. INFORMATION COLLECTION

Personal Information Received From You

Account creation:

Email address

Child’s first name

Child’s age and gender

Age quiz for Parental Gate:

Your date of birth (not stored)

Service Usage Information:

Comments and feedback

Support requests

Account settings and preferences

Billing Information:

Processed by applicable payment vendors (Apple, Google) and received by us for payment processingThe billing information that you enter is not stored by us, but instead is retained by our payments processing vendor.

Information Collected After Obtaining Explicit Parental Consent

Child’s voice recordings

Push notification token

Authentication credentials such as Email address

Email address for getting reports

Automatically Collected Information

Device Information:

Cookie ID

User agent

Session data

Platform and SDK version

Device model and specifications

Operating system details

Location and Settings:

Country-level location only (from IP or device settings)

Language preferences

Time zone

No precise location tracking

Usage Analytics:

App version

Service interaction data

Learning progress

Session frequency and duration

Third-Party Information

Analytics Data:

Statistical data from marketing partners

Compliance-mode analytics

Authentication Data:

Managed through Google Firebase

No password storage by Talkie Robie

5. INFORMATION COLLECTION METHODS

Direct Collection

When you:

Create an account

Provide information through the Service

Contact support

Subscribe to emails

Comment on third-party services

Automatic Collection

Device and software information during Service navigation

Usage patterns and interaction data

Local progress data

Error reports and debug traces

Third-Party Sources

Authentication Services:

Google Sign-In (OAuth 2.0)

Firebase authentication

Payment Processing:

Transaction data from payment systems

Subscription status from app stores

Analytics and Support:

Country-level location from IP address

App usage statistics in compliance mode

6. HOW WE KEEP AND PROTECT YOUR DATA

Security Measures We Implement

Appropriate technical and organizational security measures

Personal information stored behind security networks

Limited access to authorized personnel only

Encrypted communications for internet data transfer

Secure server storage with exclusive access

Isolated database environment

No direct external internet connection

Security Limitations

While we implement robust security measures, no data transmission can be 100% secure. We kindly recommend you to access the Service only in secure environments and use strong authentication methods. Please follow device security best practices and regularly review privacy settings.

7. DATA RETENTION

Default Retention Period

We retain information only as long as necessary to fulfill the purposes outlined in this Privacy Policy or until we receive a deletion request, unless otherwise required by law. Data retention periods:

Voice recordings: automatically deleted

Progress data: stored until account deletion

Device-specific data: retained locally until app uninstallation

Payment data: retained for a period of 5 years to support fraud prevention efforts

Data Processing After Collection

When we no longer need personal information:

Data is deleted

If immediate deletion is impossible (e.g., backup archives), data is:

Securely stored

Isolated from further processing

Deleted when technically possible

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Legal Requirements

Some information may be retained longer for:

Tax purposes

Accounting requirements

Legal compliance

Service-related communications

8. HOW WE SHARE YOUR DATA

Service Providers

We share information with trusted service providers who assist in operating our Service and providing its features:

Firebase for authentication and progress data storage

AWS for secure storage of voice recordings

These providers:

Receive only information necessary for their specific functions

Are contractually bound to protect data

Cannot use data beyond specified purposes

Analytics and Technical Services

We work with analytics providers:

Firebase Analytics for basic app functionality

We do not use or disclose any personal information from children for advertising or marketing purposes.

Payment Processing Services

Payment information is handled by:

Apple App Store

Google Play Store

These processors shall request only adult (parents) payment information as a payee, never children's data.

Data Protection Agreements

You can review our service providers' Data Processing Agreements at:

Firebase: https://firebase.google.com/terms/data-processing-terms

AWS: https://d1.awsstatic.com/legal/awsgdpr/AWS_GDPR_DPA.pdf

Google Android: https://developers.google.com/terms/data-processing-terms

Apple iOS: https://developer.apple.com/support/terms/apple-developer-program-license-agreement/

AWS: https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf

All service providers operate under strict data protection agreements that prohibit the use of data for behavioral advertising or any purpose beyond what's necessary for service operation.

Legal Requirements

We may share information:

To comply with laws

To enforce our Service policies

To protect rights and safety

Only as required by COPPA or applicable laws

Business Transfers

Adult user data may be transferred during:

Mergers and acquisitions

Company asset sales

Financing arrangements

Children's personal information receives special protection during any business transfers, following COPPA requirements.

9. RIGHTS YOU HAVE

General Rights

Request information about data collection and usage

Review collected information

Modify or update information

Delete personal information

Opt out of marketing communications

Control push notification settings

Data Deletion process

You can delete personal data via the Settings menu. The data deletion process via the Settings menu is conducted in two stages:

Account Data Deletion:

If you are logged in as a parent, you can delete data by following Settings>Sign In>Delete My Account on the app.

All data associated with the account will be deleted.

Email Data Deletion:

You can request data deletion by email.

For information stored on your device, you can also manage your cookies preferences via your browser and/or device settings. The majority of Internet browsers will enable you to delete cookies from your computer’s hard drive, refuse acceptance of cookies and/or receive a specific warning before cookies are stored within your system.

You can contact Support for preference updates via email: info@talkierobie.com

Implementation Timeline

Data deletion processed within 24 hours

Marketing opt-out processed within 24 hours

Local on-device data may still exist until you delete the App.