Children's privacy notice

How children use Owl

Owl is made for parents. There are two ways a child can be part of a family's Owl:

• Only through the parent. A parent adds a child's details to organise their day. The child doesn't use Owl, and nothing is collected from them.
• Kids mode on the child's own device. A parent pairs a phone or tablet with the family by scanning a code from the parent app. The child can then see their day, tick off chores, earn points, and send requests such as “30 more minutes”. A parent must give consent before this starts.

Children can't create an account, invite anyone, contact people outside their family, or make anything public. There are no ads, no chat with strangers, and no in-app purchases in Kids mode.

What parents tell us about children

A parent may add a child's first name, birthday or age, school year and school, a colour, an optional photo, and the child's activities, places, chores, homework, routines, payment reminders, documents and an optional care card with health information. This information comes from the parent, not from the child. We use it only to run the family's Owl, and handle it as our Privacy policy describes.

What we collect from children

When a child uses Kids mode, and only after a parent has given consent, we collect the following. Features marked optional stay off until a parent turns them on for that child.

We don't collect a child's email address, phone number or contacts, voice recordings, advertising identifiers, or any information that a child could make public. Voice commands aren't available in Kids mode, so we never collect audio from children.

How parents give consent

Before Kids mode collects anything from a child, the parent sees the notice below in the parent app and chooses whether to agree. Because we don't disclose children's information to third parties (as COPPA defines that), we use the “email plus” method that the COPPA Rule allows for services like ours:

1. The parent is signed in to their own account, with a confirmed email address.
2. The parent reads the notice and gives consent in the parent app.
3. We immediately email the parent to confirm the consent.
4. We send a second confirmation email at least 24 hours later, explaining how to withdraw consent.

If a parent doesn't give consent, Kids mode stays off and nothing is collected from the child. A parent can withdraw consent at any time. Kids mode then stops on that child's device, and we delete what was collected from the child. If we ever wanted to disclose children's information to a third party, we would ask for separate consent using a stronger verification method first.

Our notice to parents before Kids mode

This is what we tell a parent in the app before they turn on Kids mode for a child:

• We have your email address because you gave it to us to create your Owl account. We use it here to ask for, and confirm, your consent.
• We need your consent before we collect, use or disclose any personal information from your child, and we won't do so without it.
• If you agree, Kids mode will collect the information listed in “What we collect from children” above, and use it only to run your family's Owl. Features marked optional stay off until you turn them on.
• We share it only with the adults you choose in your family and with our service providers, who process it for us and may not use it for anything else. We don't disclose it to any other third party, so there's no separate disclosure for you to agree to.
• You can read this full notice at owlbell.com/children.
• You give consent by tapping Agree, and we confirm it by email twice (see “How parents give consent”).
• If you don't agree, Kids mode stays off and nothing is collected from your child.

How we use children's information

We use information collected from a child only to:

• show the child their own day, chores, routines and points;
• let the adults the parent chooses see what the child did, answer requests, and receive check-ins and safety alerts;
• run the screen-time limits, bedtime and school-mode settings the parent chooses;
• keep Kids mode secure and working, and fix problems.

We never use children's information for advertising, build profiles of children, sell or rent it, send it to our AI provider, use it to train AI models, or use it to encourage a child to spend more time in the app.

Who we share it with

We don't disclose children's information to any other third party. Children can't make any personal information publicly available in Owl.

Persistent identifiers

Kids mode uses a random identifier for each app installation, together with the app version. We use it only for internal operations: to keep the device paired with the right family, deliver notifications and keep the service secure. Kids mode sends no crash reports to any service.

To make sure it's never used to contact a child, for behavioural advertising, or to build a profile: Kids mode contains no advertising or analytics software; the identifier isn't combined with information from other services; only a small number of staff can access it, for support and security, and that access is logged.

Location, screen time and the child's view

Owl's safety and screen-time features are built so a child is never monitored in secret:

• They're off by default, and a parent turns them on for one child at a time.
• When location or screen time is on, the child's device shows it clearly. Kids mode includes a page that shows the child what their family can see.
• A live view of a child's location lasts 15 minutes, then switches off. The child sees when a parent is viewing.
• We don't keep a trail of a child's movements. See the retention policy below.

As children get older, they reasonably expect more privacy. We encourage parents to talk with their children about which features are on, and to review them as children grow.

Retention policy for children's information

This is our written retention policy for information collected from children, as the COPPA Rule requires. We keep each item only as long as reasonably necessary for the purpose it was collected for, and never indefinitely.

When a parent removes a child, withdraws consent or deletes the family, we delete the information collected from that child within 30 days. It drops out of our encrypted backups within a further 35 days. We delete information securely, so it can't be accessed or used during or after deletion.

Parents' rights

A parent can, at any time:

• review the information collected from their child, in the parent app or by asking us for a copy;
• have it deleted: a single item, the child, or the whole family;
• refuse any further collection or use by turning off an optional feature or Kids mode, or by withdrawing consent;
• change which adults can see the child's information.

In the app, go to Family, choose the child, then Privacy. Or email privacy@owlbell.com from the email address on your Owl account. We'll confirm that you're the child's parent in the family before acting on the request, and respond as quickly as we can: within 45 days.

Designed for children

We follow the UK Information Commissioner's Age Appropriate Design Code, one of the strictest standards for children's privacy, for every child under 18. In Owl this means:

• Best interests and a DPIA: we assessed Owl's risks to children before launch and keep that assessment up to date.
• High privacy by default: location, screen time and chore photos are off until a parent turns them on, and nothing is ever public.
• Only what's needed: each feature collects only what it needs, and each is a separate choice.
• No sharing, profiling or nudges: we don't share children's information beyond the family and our service providers, don't profile children, and don't use design tricks to get more data or more screen time.
• Location and parental controls in the open: the child sees an obvious sign whenever location or screen time is on, and a live view ends after 15 minutes.
• Explanations children understand: Kids mode explains in simple words what the family can see, at any time. Its Help screen shows children how to ask a parent, how to contact us without going through a parent, and free helplines: Childline (0800 1111) in the UK and Childhelp (1-800-422-4453) in the US. Owl never blocks or reports these.

A note for children

Hi. This part is for you. Owl helps your family keep track of the day: school, clubs, chores and things to bring.

• Your parent chose to use Owl and said yes to Kids mode on your device.
• Owl keeps the chores you tick, your points, and the requests you send, so your family can see them.
• If your parent turns on location or screen time, your device will show it. You'll always know.
• Owl doesn't show you ads, doesn't let strangers see you, and doesn't sell anything about you.
• If something worries you, talk to your parent or another adult you trust. You can also ask them to email us at privacy@owlbell.com.

Changes

If we change how we collect, use or share children's information in a material way, we'll tell parents first and ask for consent again before the change applies to their child. The date at the top of this notice shows when it last changed.

Contact us

The operator responsible for children's information in Owl is:

• Company: Yarqat (SMC-Private) Limited (registered in Pakistan, number 0355440)
• Post: 304, Plaza 11, Sector C, Bahria Enclave, Islamabad, Pakistan
• Email: privacy@owlbell.com
• Phone: +92 339 0800030