Privacy Policy

Head and Preamble

CoFlows Limited (hereinafter referred to as “we,” “us,” or “our”) operates the LoroBuddy mobile application and related services (hereinafter collectively referred to as the “Services”). This Privacy Policy (hereinafter referred to as the “Policy”) describes how we collect, use, store, protect, share, and otherwise process information when you and your child use the Services.

We are a company incorporated under the laws of the Hong Kong Special Administrative Region (hereinafter referred to as “Hong Kong”). We are committed to protecting the privacy of children and families and to handling information in compliance with applicable data protection laws, including but not limited to the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, the Children’s Online Privacy Protection Act of the United States (“COPPA”), the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the United Kingdom GDPR (including Article 8 concerning children’s consent, “GDPR-K”), the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”) and the California Age-Appropriate Design Code, and other applicable legislation in the jurisdictions in which we operate.

LoroBuddy is a reading and learning application designed for children (recommended for ages 2–12) and the parents and guardians who care for them. Because the Services are directed to children, we have built them to be privacy-protective by design and to collect as little information as possible.

It shall be specially noted that LoroBuddy is designed with an on-device processing architecture. The core functions of the Services — including optical character recognition (scanning a printed page), text-to-speech (reading aloud), and offline voice command recognition — are performed entirely on your device. Under normal circumstances, your child’s camera images, drawings, recordings, scanned text, and family messages are not transmitted to our servers or to any third party. Such content is stored locally on the device and, where you grant the relevant permission, in the device’s own photo gallery.

Please read this Policy carefully. The Services are intended to be set up and supervised by a parent or guardian. By downloading, installing, accessing, or allowing a child to use the Services, the supervising adult acknowledges that they have read, understood, and agreed to this Policy. If you do not agree with any part of this Policy, please cease using the Services and uninstall the application from your device.

I. Definitions

For the purposes of this Policy, the following terms shall have the meanings set forth below:

• “Personal Information” or “Personal Data” means any information relating to an identified or identifiable natural person, including but not limited to name, email address, device identifiers, and online identifiers. Under COPPA it also includes persistent identifiers used to recognise a user over time and across services.
• “Child” means a user under the age of 13 (or such higher age as may apply in your jurisdiction, for example under 16 in parts of the European Economic Area).
• “Parent” or “Guardian” means the adult who downloads, configures, supervises, and is responsible for a Child’s use of the Services.
• “On-Device Processing” means the processing of data entirely on the user’s device without transmitting such data to any external server, cloud service, or third party.
• “Sensitive Permissions” means device permissions that grant access to potentially sensitive resources, including camera access, microphone access, and access to the device’s photo library or media storage.
• “Entitlement” means the record of whether a device has an active ad-free subscription, used to unlock the corresponding features.

II. How We Collect and Use Information

i. Overview

We adhere to the principle of data minimisation. The Services do not require an account, do not ask a child to provide personal details, and are engineered so that the content your child creates stays on your device. We collect information only to the limited extent described below.

ii. Information You Provide Directly

(1) Support Communications. If a parent or guardian contacts us for support or feedback, we receive the information provided in that communication, such as an email address and the content of the message. We ask that you do not include a child’s personal information in support correspondence.

(2) On-Device Content and Preferences. Your application settings, dictation and word lists, reading preferences, rewards and progress, and the drawings, recordings, photos, and messages created within the Services are stored locally on your device (using local storage and, for some items, the device’s photo gallery). These data are not transmitted to our servers.

(3) Purchase Information. If you purchase the ad-free subscription, the transaction is processed by your application store provider (Apple App Store or Google Play Store). We receive a purchase receipt and Entitlement status from the store provider to verify your subscription and unlock features. We store Entitlement data locally on your device. We do not receive or store your payment card details, billing address, or other financial information.

iii. Information Collected Automatically

(1) Device Information. We may process limited device-level information, such as device model, operating system version, application version, and language or locale settings, for the purpose of ensuring compatibility, delivering the correct voice and language model files, and operating the Services. Such information is processed in anonymised or aggregated form.

(2) Advertising Data (Free Tier). When the Services are used without an active subscription, they display banner advertisements served by Google AdMob. Because the Services are directed to children, AdMob is configured for child-directed treatment and serves only non-personalised, contextual advertisements. We do not use advertising identifiers to build advertising or behavioural profiles of children, and we do not permit interest-based or personalised advertising to children. AdMob processes a limited set of data necessary to serve, cap, and measure non-personalised ads and to prevent fraud, in accordance with Google’s Families policies.

(3) No Analytics or Tracking. The Services do not integrate third-party analytics, advertising attribution, crash-reporting, or behavioural tracking software development kits. We do not track your child across other apps or websites.

iv. Information We Do Not Collect

To make the scope of our practices clear, we expressly declare that we do not collect, store, or transmit the following:

• Camera images and scanned pages. Optical character recognition is performed on-device. Images captured by the camera or selected from the gallery for scanning are processed in device memory and are not stored on, or transmitted to, our servers.
• Microphone audio. Voice command recognition is performed on-device and the audio is discarded immediately after processing. Voice messages your child records are saved locally on your device (and, with permission, your gallery) and are never uploaded to us.
• Drawings, photos, and family messages. Content created in the messages feature is stored on your device and, where you grant media permission, saved to the device’s own photo gallery so it is not lost if the app is reinstalled. It is never transmitted to us or shared by us with any third party.
• Precise location. We do not collect GPS or other precise geolocation data.
• Contacts, call logs, or messages. We do not access your device’s contacts, call history, or SMS.
• Biometric data. We do not perform facial recognition, voiceprint analysis, or any biometric identification. On-device speech recognition transcribes words only and does not create or store biometric templates.
• Personalised advertising profiles of children. See Section II.iii(2) and Section VII.

III. Third-Party Services

We engage only the following third-party providers in the operation of the Services:

• Google AdMob — to serve non-personalised, child-directed banner advertisements on the free tier. Google’s privacy policy is available at policies.google.com/privacy.
• Apple App Store / Google Play Store — for application distribution, updates, and in-app purchase transaction processing. These providers receive standard distribution data and purchase receipts under their own policies.
• Content delivery for model files — voice and language model files used for on-device reading and recognition may be downloaded over a secure connection from our content delivery network or the platform’s services. These requests do not include your child’s content or personal information.

We do not sell, rent, lease, or trade personal information to any third party, and we do not permit any third party to use children’s information for their own purposes. We require our providers to handle data only as necessary to provide their service and in accordance with applicable law.

IV. Device Permissions and Sensitive Features

The Services request certain device permissions only at the time the related feature is used, with an explanation of why the permission is needed. You may decline or later revoke any permission in your device settings; some features may then be unavailable.

i. Camera

Used to scan a printed page, book, or worksheet so that Loro can read it aloud. Images are processed on-device for text recognition and are not stored or transmitted by us.

ii. Microphone

Used to record voice messages for the family and to operate offline voice commands. Audio is processed and stored on-device only.

iii. Photos and Media Library

Used to attach a photo to a family message and to save your child’s drawings, recordings, and photos to your device’s gallery so they survive reinstalling the app. We access only the items you choose, and saved media remains under your control.

iv. Notifications

If you enable them, notifications are used for gentle, optional reminders. They are not required to use the Services.

V. Data Retention

On-device content (settings, lists, drawings, recordings, photos, messages, progress) is retained on your device until you delete it within the application or uninstall the app. Media you have saved to your device gallery remains there until you remove it, even after uninstalling.

Third-party data handled by Google (AdMob) and the app stores is retained according to their respective policies. We do not maintain a central database of your child’s personal information, and therefore hold no such records to retain.

VI. Data Security

Because content is processed and stored on your device, your information benefits from the security controls of your device and operating system. Entitlement data is held in encrypted local storage, and network requests for model files are made over encrypted (HTTPS) connections. No method of storage or transmission is completely secure; however, by minimising what we collect and keeping content on-device, we substantially reduce privacy and security risk.

VII. Children’s Privacy

LoroBuddy is intended for children, and we take children’s privacy seriously. The Services are designed to comply with COPPA, the GDPR/GDPR-K (including Article 8), the California Age-Appropriate Design Code, and other applicable children’s privacy laws.

We do not knowingly collect personal information from children. By design, the Services do not require an account, do not ask a child for name, email, phone number, or other contact details, and process the content a child creates entirely on the device.

No behavioural advertising to children. Advertisements on the free tier are non-personalised and child-directed. We do not use persistent identifiers to build advertising profiles of children or to serve interest-based ads, and we do not disclose children’s information to third parties for advertising purposes.

Parental controls and the parental gate. Setup and purchases are intended to be performed by a parent or guardian. A parental gate (an adult-only challenge) protects in-app purchases and any links that would leave the child-safe area of the app, so that children cannot make purchases or navigate away without an adult.

Parental rights and control. Because a child’s content is stored on your device, a parent or guardian can at any time review it within the app, delete any item, stop further creation of content, or remove all of it by uninstalling the application. Given the limited, on-device nature of our processing, no personal information is collected from a child that would require separate verifiable parental consent for non-exempt purposes; where any consent is appropriate, the parent or guardian who configures and operates the Services provides it. If you have questions or wish to exercise these rights with our help, contact us using Section XI.

If you believe a child has provided us with personal information (for example, within a support email), please contact us and we will promptly delete it.

VIII. Regional Privacy Rights and Compliance

i. European Economic Area and United Kingdom — GDPR

Our legal bases for the limited processing described above are: the performance of the Services you request and our legitimate interests in operating, securing, and supporting them; and, where required, consent. For children, we rely on the authority of the parent or guardian under Article 8. You have the rights of access, rectification, erasure, restriction, objection, and data portability, exercisable as described in Section VII (most data is on your device and within your direct control). You may also lodge a complaint with your local supervisory authority.

ii. United States — COPPA and CCPA/CPRA

Consistent with COPPA, we provide this notice of our practices, limit collection from children, and give parents control over their child’s content. Consistent with the CCPA/CPRA and the California Age-Appropriate Design Code, we disclose the categories of information involved (device and advertising data as described above) and confirm that we do not “sell” or “share” personal information as those terms are defined, and in particular never sell or share the personal information of children. California residents may exercise the rights to know, delete, and opt out, and will not be discriminated against for doing so.

iii. Hong Kong — Personal Data (Privacy) Ordinance

We handle personal data in accordance with the Data Protection Principles of the Personal Data (Privacy) Ordinance (Cap. 486), including in relation to purpose, use, security, and access and correction.

iv. Other Jurisdictions

Where other data protection laws apply (such as Brazil’s LGPD or Canada’s PIPEDA), we comply with their applicable requirements. Some features or advertising behaviour may differ by region or platform to meet local legal requirements.

IX. International Data Transfers

We are based in Hong Kong. The limited third parties we rely on (Google and the app store providers) operate globally and may process data in countries other than your own. Where such transfers occur, they are governed by those providers’ own safeguards and contractual mechanisms (such as standard contractual clauses) as applicable.

X. Changes to This Policy

We may update this Policy from time to time. When we make material changes, we will revise the version number and effective date above and, where appropriate, provide additional notice within the application. Your continued use of the Services after an update takes effect constitutes acceptance of the revised Policy.

XI. Contact Us

If you have any questions, concerns, or requests regarding this Policy or your child’s privacy, please contact us:

CoFlows Limited (Hong Kong)
Email: hello@lorobuddy.com

XII. Miscellaneous

This Policy is published in English, which is the governing language; any translation is provided for convenience only. If any provision of this Policy is held to be invalid or unenforceable, the remaining provisions shall continue in full force and effect. Headings are for convenience only and do not affect interpretation.