Privacy Policy
Effective Date: June 1, 2026
Coolphabets Applications LLC | Boston, MA, USA | [email protected]
Coolphabets Applications LLC ("Company," "we," "us," or "our") operates the COOLPHABETS mobile application ("App"). This Privacy Policy explains what information we collect, how we use it, and your rights. We are committed to COPPA (Children's Online Privacy Protection Act) compliance for users in the United States and GDPR (General Data Protection Regulation) compliance for users in the European Economic Area ("EEA") and United Kingdom.
1. Information We Collect
1.1 Information You Provide
Parent/guardian email address and password (account registration).
Child profile details: name or nick-name. No photos, or contact details of children are collected.
Voice recordings: If a parent uses the "record your own voice" feature, recordings will be transferred to our servers to sync with other members in your family group.
1.2 Automatically Collected Information
Because the App functions primarily offline and is designed with child privacy at its core, we collect minimal technical data:
Device type and operating system version (for crash reporting and compatibility).
App version number.
Subscription status (to verify access to premium features).
We do NOT collect: location data, persistent device identifiers, behavioral analytics, or any other personal data from child profiles.
1.3 Payment Information
Payments are processed by Apple (App Store) or Google (Google Play) or by a payment gateway (Stripe, Dodo Payments). We do not receive or store your credit card or payment details. We receive only confirmation of your subscription status from these platforms.
2. How We Use Your Information
We use the information we collect only for the following purposes:
To create and manage your account.
To provide, maintain, and improve the App and its features.
To verify and manage subscription access.
To respond to support inquiries sent to [email protected].
To send you important updates about the App or your subscription (you may opt out of non-essential communications at any time).
We do not use any data from child profiles for advertising, profiling, or analytics purposes.
3. Children's Privacy (COPPA Compliance)
The App is directed at children and is used under parental supervision. We comply fully with COPPA:
We do not knowingly collect personal information directly from children under 13 without verifiable parental consent.
All AI-based handwriting evaluation runs entirely on-device.
No third-party advertising networks, tracking SDKs, or social media plugins are embedded in the App.
Parents may review, correct, or request deletion of their child's profile information at any time by contacting [email protected].
We will delete any personal information collected from a child under 13 upon verified parental request within 30 days.
4. GDPR Rights (EEA and UK Users)
If you are located in the European Economic Area or the United Kingdom, you have the following rights under GDPR:
Right of Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request correction of inaccurate data.
Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data, subject to legal retention obligations.
Right to Restriction of Processing: Request that we limit how we use your data.
Right to Data Portability: Receive your data in a structured, machine-readable format.
Right to Object: Object to processing based on legitimate interests.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with your local data protection authority.
4.1 Legal Basis for Processing (GDPR)
We process personal data on the following legal bases:
Contract performance: To deliver the subscription service you have purchased.
Legitimate interests: To maintain App security and improve features, in a manner that does not override your fundamental rights.
Legal obligation: Where required by applicable law.
Consent: For optional communications (e.g., product updates). You may withdraw consent at any time.
4.2 International Data Transfers
Our servers are located in the United States. If you are located in the EEA or UK, your account data is transferred to the US under applicable transfer mechanisms, including Standard Contractual Clauses (SCCs) where required. By using the App, EEA/UK users acknowledge this transfer.
5. Data Sharing and Disclosure
We do not sell, rent, or trade your personal information. We may share data only in these limited circumstances:
Service providers: Trusted third-party vendors who assist us in operating the App (e.g., cloud hosting, customer support tools), bound by confidentiality obligations. These providers are not permitted to use your data for any other purpose.
Legal compliance: If required by law, court order, or governmental authority.
Business transfers: In the event of a merger, acquisition, or sale of all or part of our assets, your data may be transferred. We will notify you before your data becomes subject to a different privacy policy.
With your consent: In any other case, only with your explicit prior consent.
6. No Advertising or Third-Party Tracking
COOLPHABETS contains no advertisements. We do not use any third party advertising related tracking tools. No data about your child's usage of the App is shared with or sold to any third party for advertising or commercial profiling purposes.
7. Data Retention
We retain your account information for as long as your account is active or as needed to provide our services. If you delete your account, we will delete or anonymize your personal data within 30 days, except where we are required to retain it for legal or regulatory reasons (e.g., financial records, which may be retained for up to 7 years as required by US tax law).
8. Data Security
We implement industry-standard technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include encrypted data transmission (TLS), access controls, and secure hosting environments.
No method of transmission over the internet is 100% secure. In the event of a data breach that affects your personal data, we will notify you as required by applicable law.
9. Data Controller
For the purposes of GDPR, the data controller is:
Coolphabets Applications LLC
Boston, MA, USA
Email: [email protected]
10. Changes to This Privacy Policy
We may update this Privacy Policy periodically. Material changes will be communicated via in-app notice or email before they take effect. The "Effective Date" at the top reflects the most recent revision. Continued use of the App after the effective date constitutes your acceptance of the updated policy.
11. Contact Us
For any privacy questions, requests, or complaints, please contact:
Coolphabets Applications LLC
Boston, MA, USA
Email: [email protected]
Website: coolphabets.com/privacy-policy
We aim to respond to all inquiries within 30 days.
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