Familulu Privacy Policy

Sichuan Yan Technology Co., Ltd. ("Company", "we", "us", or "our") is committed to protecting the privacy of you and your children. This Privacy Policy explains how we collect, use, store, and protect personal information when you use the Familulu application ("the App").

This App involves the collection and processing of personal information of minors (children). We strictly comply with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the Children's Online Privacy Protection Act (COPPA), implementing enhanced protections for children's personal information.

2.1 Parent/Guardian Information

• Account Information: Phone number (for account registration and login verification)
• Identity Information: Display name or nickname you choose to provide
• Device Information: Device model, operating system version, browser type (for compatibility optimization)

2.2 Child Information

• Basic Profile: Child's nickname, age/grade, gender (for personalized AI interaction)
• Learning Preferences: Interest areas, subject preferences, English proficiency level (for customized learning content)
• Interaction Data: Conversation content with the AI companion "Milu" (text and voice-to-text records)
• Learning Data: Homework photos (for AI analysis and learning assistance; images are not permanently stored after analysis)

2.3 Automatically Collected Information

• Log information: access times, usage duration, feature usage records
• Network information: IP address, network type

2.4 Information We Do Not Collect

• We do not proactively collect children's real names, government-issued IDs, or precise geolocation
• We do not collect children's biometric information (such as facial recognition or fingerprints)
• We do not retain raw audio recordings on our servers (voice is used only for real-time transcription; original audio is deleted after processing)

3.1 We collect information for the following purposes:

• Providing Core Services: Enabling AI interaction, generating personalized learning content and developmental assessments
• Account Management: Registration, login verification, and account security
• Product Improvement: Enhancing user experience, fixing issues, improving AI conversation quality
• Security: Identifying and preventing security risks and fraudulent activities

3.2 Regarding AI Model Training: We do not use your or your child's personal conversation data to train AI models. We may use anonymized, de-identified aggregate statistics to improve AI service quality.

3.3 We do not make automated decisions about you or your children, nor do we conduct commercial marketing based on user profiles.

4.1 We do not sell any personal information of you or your children.

4.2 We may share information in the following circumstances:

• Service Providers: We may collaborate with cloud computing providers, SMS service providers, and others to deliver product functionality. We enter into strict data protection agreements with these partners.
• Legal Requirements: As required by laws, regulations, legal proceedings, or government authorities.
• Corporate Changes: In the event of a merger, acquisition, or asset sale involving personal information transfer, we require the new holder to remain bound by this policy.

5.1 We fully recognize the importance of protecting children's personal information and strictly comply with applicable children's data protection regulations.

5.2 Guardian Consent: We require parental/guardian consent before collecting children's personal information. Creating a child profile must be done through a parent account.

5.3 Data Minimization: We collect only the minimum information necessary to provide our services. Children's nicknames can be any name — we do not require real names.

5.4 Data Access Control: Children's personal information is used only with parent account authorization. Parents can view, modify, or delete their child's profile at any time.

5.5 Content Safety: The AI companion "Milu" has built-in content safety filtering that proactively blocks topics inappropriate for minors.

5.6 Screen Time Management: We provide daily usage time limits to help parents manage their children's screen time.

6.1 Storage Location: Your personal information is stored on servers located in the People's Republic of China.

6.2 Retention Period: We retain your personal information only for the minimum period necessary to provide our services. Within 30 business days of account deletion, we will delete or anonymize your personal information.

6.3 Security Measures: We employ industry-standard security technologies to protect your information, including but not limited to data transmission encryption (HTTPS/TLS), data storage encryption, and access control.

6.4 Despite our best efforts, the internet is not an absolutely secure environment.

You have the following rights regarding your and your children's personal information:

7.1 Right of Access: You may view your and your children's personal information within the App at any time.

7.2 Right of Rectification: You may modify your and your children's personal information at any time.

7.3 Right of Erasure: You may delete your child's profile or deactivate your account to delete all personal information.

7.4 Right to Withdraw Consent: You may withdraw consent for personal information processing by deactivating your account or contacting us.

7.5 Right to Data Portability: You may request a machine-readable export of your personal information; we will respond within 15 business days.

8.1 To ensure proper functioning, we may use cookies and local storage technologies to maintain login sessions, remember preferences, and ensure security.

8.2 We do not use cookies for advertising tracking or user behavior analytics.

9.1 We may update this Privacy Policy due to changes in laws, business adjustments, or other reasons.

9.2 For material changes, we will notify you through in-app notifications or other appropriate methods and seek your consent again.

9.3 Continued use of the App after policy updates constitutes your acceptance of the updated policy.

If you have any questions, opinions, or complaints about this Privacy Policy, or wish to exercise your personal information rights, you may contact us at:

• Company: Sichuan Yan Technology Co., Ltd.
• Email: privacy@familulu.com
• In-app "Feedback" feature

We will respond within 15 business days of receiving your request.