Privacy Policy

1. Introduction

FAMMO ("Service"), available at fammo.app ("we", "us", "our"), is operated by a company registered in Latvia. We are the data controller for the purposes of the General Data Protection Regulation (GDPR). Full legal entity details are available in our Legal Notice.

This Privacy Policy explains how we collect, use, and protect your information and your child's information when you use our Service. Because FAMMO processes data about children, we take extra care to minimize data collection, protect children's privacy, and ensure transparency.

2. Children's Data — Our Approach

FAMMO is a parental monitoring tool. By design, it processes data about minors (your children) under your parental authority. We are committed to protecting children's privacy and follow these principles:

• Data minimization: We collect only the data necessary to provide the Service.
• Purpose limitation: Children's data is used solely to generate insights and reports for their parent/guardian.
• No profiling for marketing: We never use children's data for advertising, marketing, or profiling for commercial purposes.
• No selling of data: We never sell or share children's data with third parties for their own purposes.
• Parental control: Parents have full control over their child's data and can request deletion at any time.

Legal Basis for Processing Children's Data

Under GDPR Article 8, processing personal data of a child below 16 years of age (or the lower age set by the child's Member State, but not below 13) in relation to information society services requires consent given or authorized by the holder of parental responsibility.

By creating a FAMMO account and linking your child's data, you, as the parent or legal guardian, provide this consent and authorize the processing of your child's data as described in this policy. You may withdraw this consent at any time by deleting the child's profile or contacting us (see Section 12).

3. Information We Collect

3.1 Parent Account Information

When you create an account, we collect your email address and password (stored as a bcrypt hash). If you subscribe to a premium plan, Stripe processes website payments and Google Play processes Android in-app payments. RevenueCat verifies store purchases and synchronizes subscription access. We do not store your card details. We keep provider customer identifiers, subscription status, billing periods and transaction references to manage your family's access. RevenueCat receives a pseudonymous family identifier, purchase and subscription data, and technical data from its SDK; we do not send it children's monitoring content.

For new website purchases, we keep a dated copy of the offered terms, price and trial details, checkout acknowledgement, and the acceptance confirmed by the payment provider. Contract confirmations include the terms and model withdrawal form. If you submit a withdrawal statement, we record your name, chosen confirmation email address, statement, contract or subscription reference, submission time, and related support correspondence. We also keep confirmation email content and sending status so failed messages can be retried. Family billing administrators can access these records; authorized Fammo support staff use them to handle the case.

Legal basis: Performance of a contract (GDPR Article 6(1)(b)) — this data is necessary to create and maintain your account and provide the Service.

3.2 Child Profile Information

When you add a child to your account, you provide their name (or nickname) and age. You may optionally add additional context to help the AI provide better insights.

Legal basis: Consent of the holder of parental responsibility (GDPR Articles 6(1)(a) and 8).

3.3 Activity Data

Depending on how you configure the Service, FAMMO may process:

• App and screen time usage data from your child's device
• Website browsing summaries (domains visited, not full page content)
• Notification summaries
• Location data (if enabled by you)
• Communication metadata (message counts, contact frequency — not message content unless you specifically enable this feature)
• AI chatbot conversation content only if you specifically enable conversation capture for a child profile

Sensitive categories such as location, call logs, SMS, social-media monitoring, chatbot conversation capture, and driving safety have dedicated controls and are disabled by default. Other baseline activity categories are controlled through the parent setup, feature availability, and device rules shown in the Service.

Legal basis: Consent of the holder of parental responsibility (GDPR Articles 6(1)(a) and 8).

3.4 AI-Processed Data

Activity data is sent to our AI processing pipeline to generate:

• Daily and weekly activity summaries
• Well-being insights and alerts
• Usage pattern analysis

Text and activity insights are processed on our behalf by OpenAI. We limit that data to what is needed and remove direct child identifiers where technically feasible. If screenshot analysis is enabled and available, OpenAI's Moderation API may process the screenshot image for safety classification. Screenshots can contain direct identifiers or sensitive visible content and cannot be described as pseudonymized in the same way as minimized text/activity fields.

Legal basis: Consent of the holder of parental responsibility (GDPR Articles 6(1)(a) and 8).

3.5 Technical and Analytics Data

We collect standard technical data including:

• IP address
• Device type and operating system
• Browser type and version
• Pages visited within FAMMO
• Session duration and interaction data

We use PostHog Cloud's EU region for product analytics through our first-party t.fammo.app reverse proxy. Analytics configuration differs by surface and is minimized where practical.

Legal basis: Legitimate interest (GDPR Article 6(1)(f)) — maintaining and improving the Service. For any analytics beyond strictly necessary functionality, we rely on your consent.

3.6 Error and Performance Monitoring

We use Sentry to track application errors and performance. Sentry may receive technical data about errors including device information, browser state, and anonymized usage context. No child activity data is intentionally sent to Sentry.

Legal basis: Legitimate interest (GDPR Article 6(1)(f)) — ensuring Service reliability and resolving technical issues.

3.7 Waiting List

If registration is not yet open and you join the Fammo waiting list, we collect your email address, language preference, signup time, confirmation status, beta-invite eligibility, launch-offer eligibility, and basic technical information used to prevent abuse. We use double opt-in email verification before sending launch announcements, beta invitations, or promotional offers.

Legal basis: Consent (GDPR Article 6(1)(a)) — you can unsubscribe at any time from waiting-list emails.

4. How We Use Your Information

• To provide the core Service: generating AI-powered insights and summaries for parents
• To process payments and manage subscriptions through Stripe, Google Play and RevenueCat
• To send transactional emails: account verification, password resets, billing notifications, and alert emails (via AWS SES)
• To send waiting-list verification, launch announcements, beta invitations, early-access updates, and promotional offers if you explicitly opt in
• To monitor and improve the Service's performance and reliability
• To respond to support inquiries
• To comply with legal obligations

5. Data Sharing and Sub-Processors

We share data with the following service providers who act as data processors on our behalf (unless otherwise noted):

We may disclose information if required by law or to protect our rights and the safety of our users.

6. International Data Transfers

Your data is primarily stored and processed within the European Economic Area (Germany).

Where data is transferred outside the EEA (including to OpenAI and Sentry in the United States), such transfers are protected by appropriate safeguards, including:

• The EU-US Data Privacy Framework (where the recipient is certified), or
• Standard Contractual Clauses approved by the European Commission (GDPR Articles 44–49)

Regarding OpenAI text processing: Activity data used for summaries and insights is minimized before transmission, with direct child identifiers removed where technically feasible. Browser AI activity summaries use provider and evidence metadata; recognizing a service does not itself send browser conversation text for semantic analysis.

Regarding OpenAI Moderation: When screenshot analysis is enabled and available, a screenshot may be transferred for safety classification. Unlike minimized text/activity data, the image itself may contain faces, names, messages, or other direct identifiers. We apply feature, plan, and daily processing limits and use the result only to provide the requested Fammo safety-review feature.

You may request information about the specific safeguards in place by contacting us at [email protected].

7. Data Retention

You may request earlier deletion of data by contacting us (see Section 12).

8. Data Security

We implement appropriate technical and organizational measures to protect your data and your child's data, including:

• HTTPS/TLS encryption for all data in transit
• Provider-side storage protections where available, with application-level encryption at rest tracked as launch hardening for sensitive activity data
• Bcrypt hashing for passwords
• Access controls limiting child data to authorized members of the linked family and tightly controlled service personnel where required
• Security review and infrastructure-monitoring controls
• Minimization and pseudonymization of text/activity data before AI processing where technically feasible; screenshot images are handled under the separate disclosure above

No system is 100% secure. We cannot guarantee absolute security, but we are committed to promptly notifying affected users in the event of a data breach, as required by GDPR Articles 33–34.

9. Local Storage and Cookies

The Service uses local storage (browser-based storage similar to cookies) to maintain your session, preferences, and application state. This is strictly necessary for the Service to function.

We use essential cookies for authentication and session management. These do not require consent as they are strictly necessary.

We do not use advertising cookies or advertising pixels. PostHog analytics is delivered through our first-party reverse proxy to PostHog Cloud's EU region; the SDK may use first-party browser storage to maintain analytics state. We review consent requirements when analytics scope or storage behavior changes.

10. Automated Decision-Making

The Service uses AI to generate summaries and insights about your child's digital activities. These are informational outputs intended to assist you as a parent — they are not automated decisions with legal or similarly significant effects on your child.

We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects any individual (GDPR Article 22).

If you believe an AI-generated insight is inaccurate, you can disregard it and contact us to report the issue.

11. Your Rights (GDPR)

As a parent/guardian and data subject in the European Economic Area, you have the right to:

• Access your personal data and your child's data
• Rectify inaccurate data
• Request deletion ("right to be forgotten") of your data and your child's data
• Object to or restrict processing based on legitimate interest
• Data portability — receive your data in a structured, machine-readable format
• Withdraw consent at any time (this does not affect the lawfulness of processing before withdrawal)
• Lodge a complaint with the supervisory authority

Your child's rights: Children are data subjects with their own rights under GDPR. As the holder of parental responsibility, you exercise these rights on behalf of your child. As your child matures, they may exercise their own data protection rights.

The relevant supervisory authority is the data protection authority in Latvia.

12. Contact and Data Requests

For privacy-related questions, data access requests, or to exercise any of your rights, contact us at:

• Email: [email protected]
• General support: [email protected]

We will respond to data subject requests within 30 days. If a request is complex, we may extend this by an additional 60 days with notice to you.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes — especially those affecting how we process children's data — will be communicated via email to registered users with at least 30 days' notice before taking effect. Continued use of the Service after the effective date constitutes acceptance.

For significant changes to children's data processing, we may require you to re-confirm your consent.