Privacy Policy

1. Who This Privacy Policy Applies To

This Privacy Policy applies to visitors to the Picobuddy website, adult users who create an account or purchase a subscription, people who contact Picobuddy for support, billing, legal, or other inquiries, and learner-facing use of the kid space, quizzes, and similar activities made available by an Account Holder.

Picobuddy is designed for use by adult Account Holders. Children do not create independent Picobuddy consumer accounts.

A “Learner” is a child or student whose profile is managed by an adult or who accesses a learner-facing quiz, kid space, or similar activity provided by an Account Holder. Learners do not contract directly with Picobuddy.

The adult-account confirmation records that the Account Holder declares they are an adult and authorized to manage the account. It is not identity or age verification, a child’s consent, or permission for every possible use of learner data.

2. Information We Collect

We collect information in the following categories.

2.1 Information You Provide Directly

• account information such as your name and email address, where made available through your login provider;
• profile information associated with your account, including your selected role and onboarding choices;
• the date, policy version, and source of the required adult-account confirmation;
• billing information such as billing name, billing country, tax/VAT information, subscription details, and transaction-related metadata;
• prompts, topics, instructions, grade selections, preferences, and other Input you submit to generate content;
• Generated Content such as passages, questions, quizzes, collections, saved items, favorites, and related materials;
• communications you send to us, including support messages, feedback, bug reports, and legal notices; and
• any information you choose to include in forms, emails, or other communications with Picobuddy.

2.2 Learner-Related Information

Learners do not create ordinary Picobuddy consumer accounts. An Account Holder may create a learner profile, limited kid access, or a learner-facing activity. Picobuddy may then process information connected to that learner or activity.

• a learner label, nickname, initials, profile ID, or other identifier entered by the Account Holder or user of a link;
• a preset avatar, grade or level, language, interests, preferences, groups, and assigned practice paths;
• quiz responses, answer selections, scores, feedback, completion data, and conversation or practice history where the feature provides it;
• timestamps and activity records associated with learner profiles, kid access, quizzes, practice attempts, and learning paths;
• access and security records needed for kid sessions, pairing codes, shared links, revocation, rate limiting, and abuse prevention; and
• technical data associated with learner access, such as device/browser information, IP address, session information, diagnostics, and security logs.

2.3 Content and AI Inputs

• topics, prompts, instructions, grade selections, answers, and other text submitted to create or review educational material;
• generated passages, questions, feedback, illustrations, audio, summaries, conversations, and other output;
• AI provenance such as provider or model family, generation time, prompt-template version, review status, and publication status where implemented; and
• moderation, validation, error, token-usage, and performance information needed to operate and improve the feature.

2.4 Information Collected Automatically

• IP address;
• browser type, device information, operating system, and language settings;
• pages viewed, links clicked, features used, and other usage events;
• referring pages, timestamps, approximate location based on IP, and session data;
• cookie and similar technology data; and
• diagnostics, crash information, and security-related logs.

2.5 Information from Third Parties

• authentication providers such as Google and Microsoft;
• payment providers such as Stripe;
• analytics providers such as Google Analytics; and
• other technical, infrastructure, communication, hosting, storage, and AI service providers we use to operate the Services.

3. How We Use Information

We do not use learner profiles, answers, scores, kid credentials, or activity histories for targeted advertising or to build learner marketing profiles.

Input and Generated Content may be processed to provide, secure, validate, moderate, troubleshoot, and improve the Services as described here and in our Terms. Public or promotional use is governed by the content’s visibility, the Terms, and applicable law; private learner records are not public content.

• to provide, operate, maintain, and improve the Services;
• to authenticate users and manage account access;
• to generate passages, quizzes, collections, and other educational materials;
• to enable public Library publication, private hosting, downloads, links, and learner activities;
• to process subscriptions, payments, renewals, billing support, and related transactions;
• to communicate with you about your account, purchases, support requests, updates, and service-related notices;
• to send newsletters, product updates, promotional emails, and occasional short questions about material you downloaded or created, where permitted by law and each subject to its own opt-out;
• to analyze usage, monitor performance, troubleshoot issues, and improve user experience;
• to detect, investigate, prevent, and address fraud, abuse, misuse, moderation issues, and security incidents;
• to enforce our Terms of Service and other policies;
• to comply with legal obligations and respond to lawful requests; and
• to protect Picobuddy, our users, Learners, service providers, and the public.

4. Legal Bases for Processing

The appropriate legal basis depends on the purpose, relationship, user location, and facts. The adult-account declaration is not used as a generic consent for analytics, marketing, AI processing, or child data.

• Contract: where processing is necessary to provide the Services you requested, including account access, subscriptions, billing, content generation, downloads, and learner-facing links;
• Legitimate Interests: where processing is necessary for service improvement, security, fraud prevention, moderation, analytics, product development, diagnostics, recordkeeping, support, and protection of our business and users;
• Consent: where required, for example for certain cookies, optional marketing communications, or other optional processing activities;
• Legal Obligation: where processing is required to comply with tax, accounting, consumer protection, law enforcement, or other legal obligations.

5. AI Processing and Personalization

Picobuddy uses AI providers to generate and review educational materials. AI-generated content can be inaccurate, biased, incomplete, or unsuitable, so an adult should review it for accuracy and age appropriateness before use or sharing.

For supported features using a saved learner, Picobuddy is designed to replace known learner names with a temporary placeholder before sending the request to the AI provider and to restore the saved display name after the response returns. The temporary mapping is request-local and is not added as a separate analytics property.

Picobuddy blocks recognizable email addresses and phone numbers in supported free-text AI fields. These controls cannot reliably detect every manually typed name, address, diagnosis, school record, or other personal detail. Account Holders must not enter unnecessary child personal data or sensitive information.

Member-facing Genkit AI observability is configured to send operational metadata such as provider, model, token usage, latency, status, and errors to PostHog without the raw prompt or generated response. AI providers still receive the minimized prompt needed to perform the requested generation. Admin-only and batch workflows may have separate documented controls.

6. Public Library, Private Content, and Visibility

If an account is deleted, canceled, or otherwise closed, public Library passages may remain available to the community, attribution to the original account may be removed or anonymized, private passages may remain hosted by Picobuddy, and associated personal data will be deleted, anonymized, or de-linked as described in this Privacy Policy, except where retention is required or permitted by law.

• Unless created through Private Mode where available, passages generated through the Services are published to the Picobuddy Library by default and may be used by the community.
• Where available, users may also choose profile settings, such as Anonymous Mode, that limit whether their profile identity is displayed alongside publicly available passages.
• Where offered on a paid plan, Private Mode means a passage is private, meaning it is not published to the public Library and is intended to be accessible only to the account owner or authorized accounts.
• Private passage illustrations are stored behind authorization controls. An owner or authorized administrator may receive time-limited access, and a valid practice session may display the illustration through a revocable route.
• Private Mode does not mean offline storage or immediate deletion. Private content may still be hosted by Picobuddy and accessible to the account owner, authorized accounts, internal service functionality, authorized personnel, and processors for operational, safety, moderation, legal, or support reasons.

7. Children’s Privacy and Learner Data

Picobuddy is not designed for children to create direct consumer accounts.

Children may access a limited kid space or quiz made available by an adult Account Holder, signing in with a learner credential the Account Holder creates and can revoke. Kid access does not include a child email address, password, billing profile, subscription, or ordinary account settings.

Picobuddy prefers that Learners be identified by nicknames or initials rather than real names. Account Holders must not intentionally submit unnecessary personal information about children in prompts, passage descriptions, learner fields, or other free-text inputs.

The Account Holder can view and manage learner profiles and associated activity. Removing a learner profile closes its kid access, but linked historical attempts, vendor records, and backups may follow separate deletion processes.

If Picobuddy becomes aware of prohibited, excessive, or inappropriate child personal data, or content that creates privacy, safety, legal, or moderation risk, we may review, edit, unpublish, restrict, disable, or delete the relevant content, links, or associated account access.

The Account Holder is responsible for:

• how learner-facing links are shared and used;
• obtaining any authorization or consent required for their use case;
• choosing what learner information is entered into the Services; and
• complying with applicable child privacy, education, and consumer protection laws.

A short, learner-friendly explanation is available at /learner-privacy.

8. Cookies, Analytics, and Learner-Facing Routes

Picobuddy uses cookies and similar technologies for core functionality, security, sign-in, analytics, and related service purposes.

Where required by law (for example in the European Union and the United Kingdom), analytics and marketing technologies are only activated after you give consent through our cookie banner. In other regions they are active by default and you can opt out at any time.

You can review or change your choice at any time via the "Privacy choices" link in the footer of every page. Your choice is stored for up to 12 months, after which we may ask again.

Learner-facing kid, practice, and join routes use a stricter setting: marketing and advertising tracking, retargeting, social pixels, third-party session replay, and learner person profiles are disabled. An adult browser choice does not switch those tools back on during a learner activity.

Minimal technical information may still be processed for authentication, fraud prevention, rate limiting, availability, diagnostics, and security. It is not used to build a learner marketing profile.

• essential cookies or similar technologies needed for authentication, security, session management, and core site functionality (these do not require consent);
• analytics technologies used in eligible adult-facing areas to understand how users interact with the Services and improve them, including Google Analytics, PostHog, and Microsoft Clarity where configured; and
• marketing technologies used to measure the effectiveness of our own outreach, such as a Meta (Facebook) conversion pixel. We do not sell personal data and do not run third-party advertising networks on the Services.

9. When We Share Information

Picobuddy does not sell personal data in exchange for money.

• with service providers and processors that help us operate the Services, such as hosting, storage, database, analytics, authentication, billing, email delivery, infrastructure, security, and AI-related providers;
• with payment providers such as Stripe to process subscriptions and transactions;
• with authentication providers such as Google and Microsoft when you choose to sign in using those services;
• with analytics providers such as Google Analytics;
• with product analytics and operational monitoring providers such as PostHog and Sentry, subject to the context and controls described above;
• with communication providers such as Brevo for email delivery;
• with hosting and infrastructure providers such as Google Cloud and Firebase;
• with AI and media providers such as Google Gemini, OpenAI for limited admin image workflows, and ElevenLabs for supported audio generation;
• where necessary to comply with law, regulation, legal process, or lawful requests;
• where necessary to investigate, prevent, or address fraud, abuse, security issues, or violations of our Terms or policies;
• in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction; and
• where you direct us to share information, such as by using shareable links or publicly publishing content.

10. International Data Transfers

Picobuddy is operated from the Netherlands, but the Services may rely on providers located in other countries, including the United States and other jurisdictions.

As a result, personal data may be transferred to, stored in, or accessed from countries outside your own jurisdiction. Where required by law, we rely on appropriate safeguards for international transfers.

11. Data Retention

Picobuddy is documenting and testing its end-to-end deletion and backup-expiry processes. We do not promise a fixed deletion period for a data set until that period is approved and technically implemented. You may contact us for information about a specific account or learner record.

• account data is retained while your account is active and for a limited period afterward as needed for support, security, fraud prevention, backups, and legal compliance;
• billing, tax, and transaction records may be retained for as long as required by applicable tax, accounting, and financial reporting laws;
• public Library passages may remain available after account deletion without account attribution;
• private content, learner profiles, kid access records, quiz attempts, and practice data are retained while needed for the requested account or educational purpose and may follow different deletion paths;
• expired or revoked access stops future use of the credential but does not by itself prove that the underlying activity record has been deleted;
• operational, security, AI-provider, analytics, email, and backup records follow the applicable provider and system lifecycle; and
• where account deletion occurs, personal data associated with the deleted account will be deleted, anonymized, or de-linked so that it is no longer reasonably attributable to an identified person, except where retention is legally required or technically necessary for limited backup, security, fraud-prevention, or similar purposes.

12. Security

Picobuddy uses reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

However, no internet-based service or storage system can be guaranteed to be completely secure. You are responsible for maintaining the security of your devices, account access methods, and connected third-party sign-in accounts.

13. Your Rights and Choices

Depending on where you live, you may have rights regarding your personal data, subject to applicable law.

You may also update certain account information through your account or sign-in provider, unsubscribe from marketing emails using the unsubscribe link in those messages, and stop using the Services or cancel your subscription at any time, subject to the Terms of Service.

We may need to verify your identity before responding to certain requests.

For a request involving learner information, contact [email protected] or [email protected] from the adult account email where possible. Do not send passwords, kid access codes, health information, or unnecessary identity documents.

• access personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request deletion of your personal data;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent;
• request portability of certain personal data; and
• lodge a complaint with a competent data protection authority.

14. Third-Party Services and External Links

Picobuddy may contain links to third-party websites, platforms, or services, or may rely on third-party functionality for sign-in, payment processing, analytics, communications, hosting, storage, or AI-related features.

The Explore the World feature loads interactive map tiles from OpenFreeMap using OpenStreetMap data. When the map loads, your browser connects directly to that map service and shares ordinary network information such as your IP address and browser request data. Picobuddy does not send account details or learner activity to the map provider and does not use browser geolocation for this feature.

This Privacy Policy does not govern the privacy practices of third parties. Your use of third-party services may also be subject to their own terms and privacy policies.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make changes, we will post the updated version on the Picobuddy website and update the Last Updated date above. If we make a material change, we may provide additional notice where appropriate, such as by email or in-product notice.

16. Contact Us