Children Privacy Notice

Effective date: 29 April 2026    Last updated: 2026-04-20    Version: 1

This Children's Privacy Notice explains, in one place, how Learning Time Digital Limited (Hong Kong Business Registration No. 79301879-000-12-25-4) handles information about children who are featured in a parent's or guardian's Learning Time account. It complements — and does not replace — our full Privacy Policy and Terms of Service.

If anything in this Notice conflicts with the Privacy Policy, the Privacy Policy governs.

For Indonesian-resident users: the binding version of this Notice is published in Bahasa Indonesia at https://www.learningtime-id.com/pages/pemberitahuan-privasi-anak, in accordance with Article 31 of Law No. 24 of 2009. The English version below is provided for reference.

Who this Notice is for

Learning Time is built for parents and adult guardians of young children. It is not a service that children themselves use. If you are a parent or guardian considering — or already using — Learning Time to track your child's development, this Notice is for you.

1. Children Do Not Have Accounts

• Children do not sign in to Learning Time.
• Children do not create content in Learning Time.
• Children do not receive notifications, emails, or any direct communication from Learning Time.
• The only personal data we hold about a child is the information you, the parent or guardian, provide about them.

2. What Information About Your Child We Hold

We do not collect: your child's location, biometric data, health records from Apple Health or Google Fit, contacts, microphone or camera recordings, or any advertising identifier.

3. How We Use It

We use your child's data only to deliver the Learning Time service to you: to personalise the developmental framework, to generate the weekly recap, to suggest appropriate activities, and to produce an AI-generated narrative for your progress view.

We do NOT:

• Show advertising to you or to your child
• Use your child's data to profile the child for any third-party purpose
• Sell, rent, or share your child's data with advertisers or data brokers
• Use your child's data to train any third-party AI model
• Track your child across other apps or websites

4. AI Processing — How We Minimise Child Data

When we generate a narrative for your progress view, we send only de-identified developmental signals to our AI provider (Alibaba Cloud International / Qwen, hosted in Singapore):

• Your child's age in months
• The pillar being summarised (e.g., Physical, Cognitive, Language)
• Up to three recent observation summaries

We do not send your child's name, date of birth, sex, or photo to the AI provider. The provider is contractually prohibited from using the data for any purpose other than producing the narrative for you, and from retaining it beyond the duration of the request.

5. Security

Your child's data is:

• Encrypted in transit (TLS 1.2 or higher)
• Encrypted at rest (AES-256)
• Isolated at the database row level (Row-Level Security) so that only you can read or modify information about your child
• Stored in Singapore (Supabase ap-southeast-1)
• Never exposed to Learning Time staff for casual browsing — administrative access is limited, multi-factor-authenticated, and logged

Full details are in Section 10 of the Privacy Policy.

6. Your Rights as a Parent or Guardian

You control your child's data. At any time you may:

• See it all — Settings -> Privacy -> Export my data returns a JSON file of everything we hold.
• Correct it — edit any profile field or observation from within the app.
• Delete it — Settings -> Account -> Delete account removes your account and all child records within 30 days from production systems and 90 days from backups.
• Ask us to pause processing — write to privacy@learningtime.com.hk and we will suspend further processing while any dispute is resolved.
• Complain to a regulator — see Section 12 of the Privacy Policy for the authority in your jurisdiction.

7. Age of Digital Consent and COPPA-Aligned Handling

Learning Time does not directly collect information from children. Because a parent or guardian always provides the child's data in Learning Time, the age-of-consent thresholds (13 under COPPA, 13-16 under GDPR, 13 in Singapore and Indonesia under UU PDP) do not gate the child's use.

We require the account holder — you — to confirm you are at least 18 years old and the child's parent or legal guardian before we process any child data.

Although Learning Time is not submitted to the Apple App Store "Kids Category", we voluntarily follow its core principles:

• No third-party advertising
• No third-party analytics that profile children
• No links or in-app purchases directed at children
• No collection of behavioural data from children themselves

For users accessing the Service from the United States who provide information about a child under 13, we handle that information consistently with the principles of COPPA.

8. Questions or Concerns

If you have any question or concern about how we handle your child's data, please contact us:

Email: privacy@learningtime.com.hk

We aim to acknowledge your message within 3 business days and to provide a substantive response within 30 calendar days. You have the right at any time to lodge a complaint with your local data-protection authority — a list is in Section 12 of the Privacy Policy.