Privacy Policy and Terms of Use
TalkBuddy is an educational mobile game where children can talk to AI-powered characters using voice and touch controls. This page provides clear, plain-language notice under KVKK, GDPR, and (for US users) COPPA about what data we collect, why we process it, your rights, and parental controls.
1. About the app
In TalkBuddy, children can:
- Talk to characters in a scene (by voice or via the text/command panel),
- Give gesture commands such as waving or clapping,
- Join activities such as coloring together and multiple-choice quizzes,
- Use the full UI when voice is unavailable.
The game is designed to produce child-safe responses. Settings and child profile editing are protected by a parent gate (simple math verification).
2. Data we collect
2.1 Data stored on device
- Neutral age verification: Optional date of birth (day / month / year) requested on first launch. Stored only on your device. Used to tailor the experience and to determine whether Firebase Analytics measurement collection may be turned on only when age 13 or older is indicated. Measurement remains off for under-13 age bands.
- Child profile: Optional name and age (whole number 1–17). Stored only on your device; used so characters can address the player appropriately for their age.
- Session preferences: Sign-in state, trial start time, neutral-age onboarding completion flags, etc.
2.2 Account and authentication
Sign in with Google (Firebase Authentication) may be required for subscription and account features. Your Google account email, display name, and Firebase user ID may be processed.
2.3 Voice interaction
If you grant microphone permission, your speech is recorded briefly (up to about 10 seconds), sent to a server for speech-to-text (STT), and used to generate an AI response. The response may optionally be read aloud (TTS). If the microphone is denied, the game continues in touch/UI-only mode.
2.4 AI and our own server infrastructure
Voice/text chat, STT, and TTS are handled through AgentWorkspace, our own backend infrastructure that we developed; it is not a third-party application. Messages you send, generated replies, conversation IDs, and character rig context (animation/bone structure summary) may be stored on our servers. This is used only to provide the game experience; it is not used for advertising profiling.
2.5 Subscriptions and purchases
TalkBuddy Pro subscriptions are managed through RevenueCat and the relevant app store (Google Play / App Store). Payment details are processed directly by the store; card information is not sent to the app developer's servers.
2.6 Third-party services
Aside from subscriptions and authentication, the app may use these third-party providers:
| Service | Purpose |
|---|---|
| Firebase Authentication (Google) | Account authentication when you use Google sign-in. |
| Firebase Analytics / Google Measurement | Analytics used for app usage and stability. Collection is enabled only if you indicate age 13 or older through the in-app date-of-birth onboarding; it remains off for under-13 age bands as described in this policy. |
| RevenueCat | Subscription status and entitlement management |
3. How we use data and data minimization
- To provide and personalize the game experience (age/name-appropriate dialogue),
- To understand voice commands and generate safe AI responses,
- To manage subscriptions, trials, and customer support,
- To monitor app performance and errors,
- To comply with legal obligations.
In line with GDPR and COPPA, we collect only data necessary for stated purposes and do not require more personal information than reasonably needed for an activity.
4. Children, parents, and regulatory compliance (GDPR / COPPA)
TalkBuddy may be configured for broader age targets (including approximately ages 1–17 consistent with storefront audience selections). A neutral age verification screen collects date of birth on-device to support compliant experiences and age-gated Firebase Analytics measurement. Supervised use remains important for younger users (especially under 13).
4.1 GDPR (EU) — children's data
Under the EU General Data Protection Regulation (GDPR), services offered directly to children require parent/guardian consent for users below 16 (member states may set the threshold between 13 and 16). In TalkBuddy, account, subscription, and server-side chat features are protected by parent Google sign-in and a parent gate for profile/settings changes. Information for children is kept clear and plain.
4.2 COPPA (US) — under 13
Under the US FTC Children's Online Privacy Protection Rule (COPPA), operators must provide direct notice to parents and obtain verifiable parental consent before collecting personal information from children under 13. In TalkBuddy:
- Child profile (name, age) stays on device; saving requires the parent gate.
- Server-side account/chat data is managed through the parent's account (Google sign-in).
- Parents may review, delete, and stop further collection (Profile page or email).
- We do not require more personal information than reasonably necessary for an activity.
- We do not sell children's personal information.
4.3 In-app safeguards
- Parent verification is required to save a child profile or change settings.
- Neutral age onboarding (day/month/year birth date) is stored only on the device; Firebase Analytics measurement is not enabled unless age 13+ is indicated.
- The child's name and age stay on device; they may indirectly reach servers through chat (text/voice).
- We encourage parents to teach children not to share personal details (full name, address, school, phone, etc.) in chat.
5. Data sharing
Server-side chat and account data is processed on our own infrastructure. Beyond that, your data is shared only with third-party providers needed to run the app (Google/Firebase, RevenueCat, app stores). We do not sell your data for advertising purposes.
6. Retention
- Profile data and neutral age birth date on device remain until you delete the app or clear app storage.
- Chat history and server logs may be kept for reasonable periods for service operation and legal requirements.
- Subscription records are subject to RevenueCat and store policies.
7. Security
We use HTTPS, access controls, and secure authentication to protect your data. No system is 100% secure; absolute security cannot be guaranteed.
8. Your rights (GDPR and applicable law)
Depending on your jurisdiction (including GDPR in the EU/EEA and KVKK in Türkiye), you may have the following rights. We respond to requests without undue delay, generally within one month.
- Access: Know whether your data is processed and obtain information about it,
- Rectification: Request correction of inaccurate or incomplete data,
- Erasure: Request deletion (Profile → My Account or email),
- Restriction: Request limitation of processing in certain cases,
- Data portability: Receive your data in a structured, commonly used format (where applicable),
- Objection: Object to processing based on legitimate interests,
- Withdraw consent: Withdraw consent at any time for consent-based processing (without affecting prior lawful processing),
- Complaint: Lodge a complaint with your supervisory authority (in Türkiye: KVKK; in the EU/EEA: your national data protection authority).
For data deletion and account closure, use Profile → My Account in the app first. Further requests: caner.unutkan@gmail.com
9. Legal bases (GDPR)
We process personal data on the following legal grounds:
- Contract performance: Providing the game, subscriptions, and account management,
- Legitimate interests: Security, debugging, and abuse prevention (balanced with child safety),
- Consent / notice: Microphone/voice features; Firebase Analytics measurement linked to the date-of-birth onboarding (enabled only when age 13 or older is indicated on the device).
- Legal obligation: Tax, accounting, and official requests.
10. International data transfers
Our servers and third-party providers (Google/Firebase, RevenueCat, AI infrastructure) may process data outside Türkiye or the EU/EEA. Transfers rely on applicable law and appropriate safeguards (e.g. standard contractual clauses, adequacy decisions).
11. Automated decision-making and AI
TalkBuddy's AI chat generates in-game, child-friendly responses. We do not use solely automated decision-making that produces legal or similarly significant effects. Parents may supervise chat content and exercise deletion rights.
12. Data breach notification
If we detect a personal data breach, we will notify the relevant supervisory authority as required by law (under GDPR, typically within 72 hours where applicable) and affected individuals when there is a high risk. Technical and organizational measures are in place to reduce breach risk.
13. Terms of use
- TalkBuddy is for personal, non-commercial entertainment and education only.
- AI responses are informational; they are not medical, legal, or emergency advice.
- Misuse, harmful content, or attempts to bypass security measures are prohibited.
- Subscription terms, pricing, and cancellation follow the relevant app store rules.
- The app and its content are protected by copyright; unauthorized copying or distribution is prohibited.
14. Third-party links and services
The app or this page may link to third-party services. We are not responsible for their privacy practices.
15. Policy changes
We may update this text. The effective date will change for material updates. Continued use of the app means you accept the updated policy.
16. Contact
For questions about privacy or terms of use:
- Email: caner.unutkan@gmail.com
- Data controller: InfınıtyMe94 Apps
Note: Microphone, Google account, and subscription features are optional. When voice is unavailable, TalkBuddy can be used entirely through the touch interface.