Privacy Policy

Last Updated: March, 2026

1. Introduction and Our Commitment to Children's Privacy

Welcome to DannyTalks, developed and published by D4N1 Technologies Pty Ltd ("we," "our," or "us"). We are deeply committed to protecting the privacy of children who use our application. DannyTalks is an AI voice application designed to help children develop and practice conversational skills in a safe, engaging environment.

This Privacy Policy describes our practices regarding information in connection with your use of DannyTalks on Apple iOS devices. It has been written to comply with:

• The Children's Online Privacy Protection Act (COPPA)
• The California Consumer Privacy Act (CCPA)
• The General Data Protection Regulation (GDPR) and UK GDPR
• Apple App Store Guidelines for apps directed at children
• Apple's App Tracking Transparency (ATT) framework

Please read this Privacy Policy carefully. If you have any questions, please contact us.

2. Who This App Is For

This application is designed for use by children under the supervision of a parent or guardian. Children under the age of 13 in the United States (or the applicable age of digital consent in your jurisdiction) must have verifiable parental consent before using this app. By allowing a child to use DannyTalks, you as the parent or guardian acknowledge and agree to this Privacy Policy.

3. Information We Collect — And What We Do Not Collect

3.1 Our Core Privacy Principle: Minimal Data

We have designed DannyTalks with a privacy-first architecture. We do not require account registration to use the app. We do not ask for any personally identifiable information ("PII") from the child or the supervising adult. Children and adults may use the app entirely anonymously.

3.2 Conversation Data

Voice inputs and conversation exchanges that occur within the app are processed in real time by our AI models (described in Section 6) solely for the purpose of generating conversational responses. Conversation history is stored only on your physical device ("local storage") and is never transmitted to, or stored on, our servers or any remote database. You may delete your conversation history from your device at any time through the app's settings.

3.3 Adult Age Gate

Certain areas of the application require adult supervision and include an age verification gate to confirm the supervising adult is of appropriate age. The age value entered at this gate is used solely for the purpose of that verification check. It is not stored on your device, transmitted to our servers, or retained in any form after the verification is complete.

3.4 Subscription Transaction Data

To determine whether a user is entitled to access the app's features, our remote backend server stores Apple's unique transaction identifiers ("Transaction IDs") associated with in-app subscription purchases. These Transaction IDs are generated and provided exclusively by Apple and are used solely to verify subscription entitlement. Critically:

• Transaction IDs are non-personally identifiable. They cannot be used to identify, locate, or contact any individual user or child.
• We do not store names, email addresses, payment card details, Apple IDs, or any other personally identifiable information on our servers.
• We do not link Transaction IDs to any user profile or account, as account registration is not required to use the app.
• Our remote server database is backed up regularly to ensure continuity and reliable delivery of app services. Backups are subject to the same access controls and data minimisation principles as our primary database.

3.5 What We Do NOT Collect

We want to be explicit about what we do not collect:

• No names, email addresses, phone numbers, or other contact information
• No photos, videos, or biometric data
• No precise or approximate location data
• No device identifiers used to track individual users across apps or websites
• No behavioral analytics, usage patterns, or in-app activity logs
• No payment card numbers, bank details, or full payment information (all payment processing is handled exclusively by Apple)
• No social network profiles or connections
• No health or sensitive personal data

4. In-App Subscriptions and Purchase Transactions

4.1 Subscription Requirement

Access to DannyTalks's features requires an active in-app subscription. A free trial is available to new users, with one free trial permitted per user. After the free trial period ends, a paid subscription is required to continue using the app.

4.2 Payments Processed by Apple

All subscription purchases, billing, renewals, and refund requests are handled exclusively by Apple through the Apple App Store and Apple's in-app purchase system. We do not process, receive, or store any payment information. When you make a purchase, your payment details are submitted directly to Apple and are governed by Apple's Privacy Policy and Terms of Service.

4.3 Subscription Entitlement Verification

Upon a successful subscription transaction, Apple provides our backend server with a unique Transaction ID to confirm the purchase. Our server stores only this Transaction ID for the sole purpose of verifying your entitlement to use the app. No other data from the transaction is stored on our servers. The Transaction ID does not contain, and cannot be used to derive, any personally identifiable information.

4.4 Free Trial Eligibility

One free trial is available per user. Eligibility for a free trial is determined by Apple based on the Apple ID associated with the device making the purchase. We do not independently track free trial eligibility on our servers; this determination is made and enforced by Apple's systems. We receive only the Transaction ID resulting from the subscription initiation, regardless of whether it originated from a trial or a paid purchase.

4.5 Subscription Management, Cancellation, and Refunds

You can manage, pause, or cancel your subscription at any time through your Apple ID settings on your device. Cancelling a subscription prevents future renewals but does not entitle you to a refund for the current billing period unless Apple's refund policies apply. All refund requests must be submitted directly to Apple, as we do not have the ability to issue refunds for App Store purchases.

To manage your subscription on iOS: go to Settings > [Your Name] > Subscriptions, then select DannyTalks and choose your preferred option.

5. Advertising Attribution and COPPA-Compliant Analytics

5.1 COPPA Compliance and SKAdNetwork

We use Apple's SKAdNetwork framework for ad attribution, which is a privacy-preserving, aggregate-level measurement solution provided by Apple. SKAdNetwork does not collect or transmit any personally identifiable information or device identifiers.

• No advertising identifiers (such as Apple's IDFA) are collected or used.
• No cross-app or cross-website tracking occurs.
• Attribution data received is aggregated and anonymous; it cannot be used to identify any individual user or child.

6. AI Models

6.1 How AI Processing Works

To deliver conversational responses, the app transmits voice input audio to our AI models for real-time processing. These models are hosted on our cloud server infrastructure. The models return a text or voice response, which is then presented to the user. This processing is transient — it occurs in the moment of the conversation, and no input data is retained after a response has been generated.

6.2 Our AI Infrastructure

DannyTalks uses AI models developed and maintained by D4N1 Technologies Pty Ltd. These models are hosted exclusively on our cloud server infrastructure. All AI processing remains within our own controlled environment, subject to our own privacy practices and security controls as described in this Policy.

6.3 Voice Input Data Retention

Our AI models do not store your child's voice input data. Voice audio processed by our models is used exclusively for the purpose of generating a conversational response in real time. Once a response has been generated, the input data is immediately discarded and is not retained in any form.

Specifically:

• Voice input data is processed transiently and is not written to persistent storage at any point during or after AI processing.
• Our AI models do not use voice input data submitted through DannyTalks to further train, fine-tune, or otherwise update any AI model.
• Input data is not shared with any third party for any purpose.
• The sole use of voice input data by our AI models is to return the requested conversational response to the app in real time.

6.4 Compliance and Data Handling Standards

All AI processing performed by our models is conducted in compliance with applicable privacy laws, including COPPA, GDPR, and UK GDPR. Our cloud server infrastructure is subject to the same access controls, encryption standards, and security measures described in Section 8 of this Policy.

7. Parental Rights and Controls

As a parent or guardian, you have the right to:

• Review any personal information we have collected from your child — in this case, because we collect no PII, there is no such information to review.
• Delete conversation history stored on the device at any time via the app's settings menu.
• Manage or cancel the in-app subscription at any time through Apple ID settings (see Section 4.5).
• Request information about what data is associated with the subscription Transaction ID stored on our servers by contacting us.
• Refuse further use of the app and uninstall it at any time.
• Contact us with questions or concerns about our privacy practices.

Because we do not collect any personal information from children or adults beyond non-identifiable Transaction IDs, there is no personal account to delete and no PII to request from us. All conversation data stored by the app is stored locally on your device and is under your full control. Transaction IDs stored on our servers will be retained for as long as necessary to verify entitlement and will be deleted in accordance with our data retention schedule described in Section 9.

Please contact us about parental rights or privacy concerns.

8. Data Security

We take the security of our app and all data we handle seriously. Our security measures include:

• All communications between the app and our AI models, and between the app and our backend server, are encrypted in transit using TLS/HTTPS.
• Conversation history stored on-device is subject to the security protections of the iOS operating system and the user's device security settings (e.g., device passcode, Face ID).
• Our remote backend server, which stores only non-identifiable Apple Transaction IDs, is access-controlled and monitored. Access is restricted to authorised personnel only.
• Our server database is backed up regularly using industry-standard backup procedures to ensure service continuity and data integrity. Backup data is subject to the same security controls as the primary database.
• We do not store payment information, PII, or any data that would constitute a high-risk dataset under applicable privacy regulations.

While we implement reasonable security measures, no system is completely secure. If you believe your privacy has been compromised in connection with our app, please contact us immediately.

9. Data Retention and Deletion

We retain data only for as long as necessary to fulfil the purposes for which it was collected. Our retention practices by data type are as follows:

• Conversation history: Stored locally on your device. Retained until you manually delete it within the app settings or uninstall the app. We have no access to this data.
• Age gate input: Never stored. Discarded immediately after the verification check is complete.
• Apple Transaction IDs (subscription entitlement): Stored on our remote backend server. Retained for the duration of the subscription and for a reasonable period thereafter to handle any entitlement disputes or service continuity needs. Upon a valid deletion request, or following a defined post-subscription retention period of 30 days, Transaction IDs will be permanently deleted from our servers and backups.
• Attribution data (SKAdNetwork): Aggregated and anonymised attribution signals are retained by Apple in accordance with their data retention policies. No PII is involved.

To request deletion of the Transaction ID associated with your subscription, please contact us. As Transaction IDs are non-identifiable on their own, you may need to provide your Apple Order ID (available in your Apple purchase receipt) to help us locate the relevant record.

10. International Users

Our app is distributed through the Apple iOS App Store and may be used by children and families around the world. We are committed to complying with applicable privacy laws in the jurisdictions where the app is available, including COPPA (United States), GDPR (European Union), UK GDPR (United Kingdom), PIPEDA (Canada), and the Australian Privacy Act.

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have additional rights under GDPR/UK GDPR, including the right of access, rectification, erasure, restriction of processing, and the right to lodge a complaint with a supervisory authority. The lawful basis for our processing of Apple Transaction IDs is the performance of a contract (i.e., verifying your entitlement to the subscription service you have purchased). Because we do not store PII, the exercise of most of these rights in practice is accomplished by deleting the app from your device and contacting us to request deletion of the associated Transaction ID.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the features of the app. If we make material changes, we will notify users through a notice within the app and update the "Last Updated" date at the top of this policy. We encourage parents and guardians to review this policy periodically.

Continued use of the app after any changes constitutes acceptance of the updated policy. If you do not agree with any changes, please discontinue use of the app and uninstall it from your device.

12. Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy, our privacy practices, or your subscription data, please contact us:

D4N1 Technologies Pty Ltd
Email: support@d4n1technologies.com
Mailing Address: 81–83 Campbell Street, Surry Hills, NSW 2010, Australia
Website: www.d4n1technologies.com

We will respond to all privacy-related inquiries within 30 days.