Our Commitment to Children's Safety
At Ciornii Sergiu, we develop various mobile applications. This Children's Safety Policy applies specifically to our family safety Apps when children participate in family groups.
Note: Our general-purpose Apps (games, utilities) are designed for users aged 13 and older and are not intended for children under 13.
Our family safety Apps are designed for families of all compositions. Families may include only adults, or may include children. For families consisting entirely of adult members (18+), the child-specific restrictions described in this policy do not apply.
When children participate in our family safety Apps, we implement additional safeguards to protect their privacy and safety, as described below.
Applicable Laws and Compliance
We comply with children's privacy laws worldwide, including:
- COPPA (Children's Online Privacy Protection Act): United States federal law protecting children under 13
- GDPR-K (General Data Protection Regulation - Children): European Union regulations requiring parental consent for children under 16 (or lower age set by member states, minimum 13)
- AADC (Age Appropriate Design Code): UK children's code requiring privacy by default for children
- LGPD (Lei Geral de Proteção de Dados): Brazilian data protection law with specific provisions for children
- POPIA (Protection of Personal Information Act): South African regulations for processing children's data
We follow the strictest applicable standards to ensure all children using our Apps receive the highest level of protection, regardless of their location.
Family Safety Apps
Our family safety Apps enable families to stay connected and ensure everyone's safety. These Apps support features like family location sharing, safety alerts, and family communication.
Adult-Only Families: Families may consist entirely of adult members (18+). In this case, no child-specific restrictions apply and all features are available.
Families with Children: When children participate in family groups, they do so under the supervision and control of adult family members, with the protections described below.
How Family Apps Work
- Adult-Created Groups: Only adults (18+) can create family groups
- Parental Control: When children participate, parents maintain full control over their participation, including the ability to view, modify, and delete all data
- Closed Family Groups: All members can only interact with verified family members within their family group - no strangers can contact them
- Location Sharing: Location is only visible to family members within the group
- No Public Features: There are no public profiles or ability to connect with unknown users
Age Requirements
- Creating Family Groups: Must be 18 or older to create a family group
- Account Creation: All users create their own accounts. During registration, users must provide their age or birthdate for age verification
- Children Under 13: May create accounts and join family groups only with verifiable parental consent. Have access to limited app functionality with certain features requiring parental verification
- Teens 13-17: May create accounts and join family groups with parental approval; consent requirements vary by jurisdiction
Parental Consent Process
The following consent process applies only when a family includes members under 13 years old. Before a child under 13 can participate in our family Apps, we require parental consent. Our consent process works as follows:
How Parental Consent Works
- Age Verification: During account creation, users must enter their birthdate. If the user is under 13, the app requires parental involvement to proceed
- Parent Adds Child: Only a parent or guardian (18+) who has created a family group can add a child to that group
- Parent Email Verification: The parent provides their email address and must verify it by clicking a confirmation link
- Consent Confirmation: The parent must actively confirm that they consent to their child's participation and data collection by reviewing and accepting this policy
What Parents Are Informed About
Before providing consent, parents are informed about:
- What information we collect from their child (location, account info, messages within the family group)
- How we use the information (solely for family safety features)
- That they can review, modify, or delete their child's data at any time
- That they can remove their child from the family group at any time
- How to contact us with questions or concerns
Parental Rights
Parents maintain full control and can at any time:
- View all data collected about their child
- Modify their child's profile and settings
- Delete their child's account and all associated data
- Remove their child from the family group
- Withdraw consent for data collection
Information We Collect from Children
We follow the principle of data minimization for children, meaning we only collect information that is strictly necessary to provide the requested service.
Information We May Collect
- Account Information: Name or nickname, email address (for account login), profile picture (optional), and age/birthdate (for age verification)
- Parent's Contact Information: Parent's email address for consent and communication purposes
- Location Data: Real-time GPS location to enable family members to see each other's whereabouts (with verifiable parental consent for children under 13)
- User-Generated Content: Chat messages sent within family groups (children under 13 have limited content creation abilities and certain actions require parental verification)
- Device Information: Device type, operating system, and app version (for app functionality and troubleshooting)
- Usage Data: Basic app usage to provide and improve the service (never for advertising targeting)
Information We Do NOT Collect from Children
- Advertising Identifiers: We do not collect IDFA, GAID, or similar advertising identifiers from children's devices
- Precise Location for Advertising: We never use children's location data for advertising purposes
- Biometric Data: We do not collect fingerprints, face prints, or voice recordings from children
- Social Media Connections: Children cannot link social media accounts
- Unnecessary Personal Details: We do not ask for addresses, school names, or other sensitive information beyond what is needed for the service
How We Use Children's Information
When children participate in our family Apps, their information is used only for purposes that directly support the family safety functionality:
- Providing Family Safety Features: Enabling family location sharing and safety alerts
- Family Chat: Children can send and receive messages with family members within their family group
- Limited Content Creation: Children under 13 can view content created by other family members but have limited ability to create their own content. Certain actions require parental verification
- Family Group Participation: Maintaining the child's participation within the family group
- Safety and Security: Protecting the child from unauthorized access and ensuring app security
- Customer Support: Responding to parent or guardian inquiries
- Legal Compliance: Complying with legal requirements and responding to valid legal requests
How We Do NOT Use Children's Information
- No Behavioral Advertising: We do not use children's information for targeted or behavioral advertising
- No Profiling: We do not create behavioral or interest-based profiles of children
- No Sale of Children's Data: We do not sell, rent, or trade personal information collected from children
- No Third-Party Marketing: We do not share children's information with third parties for their marketing purposes
Advertising and Children
We take a strict approach to advertising when it comes to children:
No Advertising for Users Under 13
Users identified as children under 13 do not see any advertisements. We do not display ads to children under 13 in our family Apps.
- No Ads Displayed: Children under 13 do not see any advertisements in our Apps
- No Advertising ID Collection: We do not collect or transmit advertising identifiers (IDFA, GAID) from users identified as children under 13
- No Behavioral Tracking: We do not track or profile users identified as children for any advertising purposes
Advertising for Adult Users
Adult users (parents and guardians who are 18+) may see advertisements based on their interests and usage, subject to their consent and privacy settings. Adults can opt out of personalized advertising through their device settings.
General Advertising Standards
All advertising shown to adult users in our Apps must:
- Be clearly distinguishable from app content
- Not use deceptive or manipulative practices
- Comply with applicable advertising laws and platform policies
- Not promote products inappropriate for family contexts (gambling, adult content, etc.)
In-App Purchases and Subscriptions
Our Apps may offer premium features, subscriptions, or in-app purchases. Purchases are handled through the Apple App Store or Google Play Store, which have their own age-appropriate purchase policies.
Adult-Only Families: For families consisting entirely of adult members, there are no age-based purchase restrictions within our Apps.
Purchase Policies by Age (When Children Participate)
- Children Under 13: Cannot make in-app purchases. Purchase functionality is disabled for users identified as under 13 based on their birthdate during account creation
- Teens 13-17: May make purchases subject to device parental control settings and platform policies
- Adults 18+: May make purchases without restrictions
Device-Level Purchase Protections
Apple and Google provide device-level purchase protections that parents can configure on their children's devices:
- Apple: Screen Time and Family Sharing allow parents to require "Ask to Buy" approval for all purchases
- Google: Family Link allows parents to approve or block app downloads and in-app purchases
We recommend parents configure these settings on their children's devices for additional protection.
Parental Responsibility
Parents are responsible for:
- Managing their children's participation within our family Apps
- Monitoring their children's purchases and app usage
- Optionally configuring device-level parental controls (Screen Time, Family Link) for additional protection
- Any purchases made by their children
Data Security for Children
We use industry-standard security measures to protect children's information. Our Apps use Google Firebase for backend services, which provides enterprise-grade security:
- Encryption in Transit: All data transmitted between the App and our servers is encrypted using TLS (Transport Layer Security)
- Encryption at Rest: Data stored in Firebase (Firestore, Storage) is automatically encrypted at rest using Google's encryption standards
- Access Controls: Firebase security rules restrict data access to authorized users only (e.g., family members can only access their own family's data)
- Authentication: Secure user authentication through Firebase Authentication
- Infrastructure Security: Firebase runs on Google Cloud Platform, which maintains SOC 1, SOC 2, SOC 3, and ISO 27001 certifications
For more information about Firebase security practices, see Firebase Privacy and Security.
Data Retention for Children
We maintain a written data retention policy. We retain children's information only for as long as necessary to fulfill the purposes for which it was collected:
- Active Accounts: Data is retained while the child's account remains active within a family group
- Location History: Location data is retained for up to 10 days for family safety features, then automatically deleted
- Chat Messages: Family chat messages are retained for up to 30 days, then automatically deleted
- Removal from Family Group: When a parent removes a child from a family group, the child's association with that group is removed immediately
- Account Deletion: Each user is responsible for deleting their own account. When a user deletes their account, we delete their personal information within 30 days
- Inactive Accounts: Accounts inactive for 12 months are automatically deleted
- Legal Requirements: Some data may be retained longer if required by law (e.g., for legal proceedings)
We delete children's data once it is no longer necessary to provide the service for which it was collected. We do not retain children's data indefinitely.
Cookies and Persistent Identifiers
We take a strict approach to tracking technologies for children:
- No Marketing Cookies: We do not use marketing, advertising, or tracking cookies for children under 13
- No Advertising Identifiers: We do not collect IDFA, GAID, or similar advertising identifiers from children's devices
- Essential Identifiers Only: We may use strictly necessary identifiers (such as authentication tokens) to keep children logged in and provide the service
- Firebase Analytics: For children under 13, we disable personalized analytics and do not track user behavior for profiling purposes
Any persistent identifiers used for children are solely for providing the family safety service and are never shared with advertisers or used for marketing purposes.
Data Breach Notification
In the event of a data breach affecting children's personal information, we will notify affected parents and relevant authorities as required by applicable law.
Fair Design Practices
We are committed to fair design practices that protect children:
- No Dark Patterns: We do not use deceptive design, manipulative language, or "dark patterns" to trick children into sharing more information or making purchases
- No Urgency Tactics: We do not use countdown timers, scarcity messaging, or pressure tactics that could manipulate children
- Clear Language: All prompts and consent requests use simple, age-appropriate language
- Easy Opt-Out: It is as easy to decline data collection as it is to accept
- Privacy by Default: Children's privacy settings are set to the most protective levels by default
Parental Rights and Controls
Parents and legal guardians have comprehensive rights regarding their children's information and account:
Your Rights as a Parent
- Right to Review: Request and receive a copy of all personal information we have collected from your child
- Right to Delete: Request deletion of your child's personal information at any time
- Right to Refuse: Refuse to permit any further collection or use of your child's information
- Right to Withdraw Consent: Withdraw your consent at any time, which will result in deletion of your child's account and data
- Right to Correct: Request correction of any inaccurate information about your child
- Right to Limit: Limit or restrict how your child's information is used
Parent Controls
Parents can manage family group membership from their own device:
- Family Member Management: Add or remove children from the family group
- Consent Management: Grant or withdraw consent for a child's participation
Child's Device Settings
Each user controls their own app settings on their own device. When a child sets up the app, they must:
- Grant Location Access: Allow the app to access their device's GPS for location sharing
- Enable Notifications: Allow notifications to receive alerts from family members
- Set Up Their Profile: Enter their name/nickname and other profile information
Parents should assist their children with these settings during initial setup. The child's device permissions are controlled by the device's operating system settings, not by the parent's app.
How to Exercise Your Rights
To exercise any parental rights, you can:
- Use the app to add or remove your child from the family group
- Email us at sergiu1203@proton.me with "Children's Privacy Request" in the subject line
- Include your name, your child's username, and a description of your request
We will verify your identity as the child's parent before processing any request. We will respond within 30 days (or sooner if required by applicable law).
Safety Features
Our family Apps include features specifically designed to protect children:
Communication Safety
- Closed Family Groups: Children can only communicate with approved family members
- No Public Profiles: Children's profiles are never visible to anyone outside their family group
- No Friend Requests: Unknown users cannot send friend requests or contact children
- Content Filtering: Inappropriate content is automatically filtered in family communications
Location Safety
- Family-Only Visibility: A child's location is only visible to verified family members
- Parent-Controlled Sharing: Parents decide who can see their child's location
- No Location Advertising: Children's location is never used for advertising
- Emergency Features: Safety and emergency features may be available to help keep family members safe
Account Safety
- Strong Authentication: Secure login methods to prevent unauthorized access
- Session Management: Parents can view and terminate active sessions
- Activity Logs: Parents can review account activity
- Suspicious Activity Alerts: Automatic alerts for unusual account activity
Reporting Concerns
We take all safety concerns seriously. If you have any concerns about:
- Inappropriate content or behavior involving children
- Potential violations of children's privacy
- Safety concerns about a child using our Apps
- Any other child safety issue
Please contact us immediately:
We investigate all reports promptly and take appropriate action, which may include removing content, suspending accounts, and reporting to law enforcement if necessary.
Emergency Situations
If you believe a child is in immediate danger, please contact your local emergency services (911 in the US) immediately. Do not rely solely on contacting us in emergency situations.
Third-Party Services
We carefully vet any third-party services that may process children's data:
- COPPA-Compliant Vendors: We only work with vendors who are COPPA-compliant or agree to comply with COPPA requirements
- Contractual Protections: All vendors sign agreements prohibiting them from using children's data for their own purposes
- Data Minimization: Vendors only receive the minimum data necessary to provide their service
- No Advertising Partners for Children: We do not share children's data with advertising networks
- Regular Audits: We regularly review third-party practices to ensure ongoing compliance
Third-Party Services We May Use
- Cloud Infrastructure: Secure cloud providers for data storage (no children's data is sold or shared for marketing)
- Analytics (Limited): Aggregate, anonymized analytics to improve app functionality (no personal identifiers from children)
- Push Notifications: Notification services for family alerts (device tokens only, no personal information)
International Considerations
We serve families around the world and comply with local children's privacy requirements:
- European Union: We comply with GDPR requirements for children's data, including obtaining parental consent for children under 16 (or the applicable age in each member state)
- United Kingdom: We follow the UK Age Appropriate Design Code (Children's Code) principles
- California: We comply with CCPA/CPRA requirements for children's data, including the prohibition on selling data of children under 16
- Other Jurisdictions: We apply the highest applicable standard to protect all children using our Apps
Changes to This Policy
If we make material changes to how we collect, use, or share children's personal information, we will:
- Update this Children's Safety Policy with a new effective date
- Notify parents via email before the changes take effect
- Obtain new parental consent if the changes affect previously collected data
- Give parents the opportunity to review the changes and withdraw consent if desired
We encourage parents to review this policy periodically.
Resources for Parents
We recommend the following resources for parents seeking more information about children's online safety:
Filing Complaints
If you are not satisfied with our response to your privacy request or have concerns about our children's privacy practices, you have the right to file a complaint with regulatory authorities:
- USA (Federal): Federal Trade Commission (FTC) at ftc.gov/complaint
- California: California Privacy Protection Agency at cppa.ca.gov
- UK: Information Commissioner's Office (ICO) at ico.org.uk
- EU: Your national Data Protection Authority