1. Information We Collect

We collect both personal information and non-personal information as necessary to provide and improve the Service. We limit our collection of personal information from children to only what is reasonably necessary for the Service. The types of information we collect are:

Account Holder (Parent/Guardian) Information

When a parent registers for Starlett, we collect the parent's name, email address, and authentication credentials. If a subscription or purchase is made, we (or our payment partners) collect billing information such as payment card details and billing address if needed.

Child Profile Information

When you set up a child's profile, we ask for the child's first name and birth date. You may also add an avatar or character and the child's interests, so that we can tailor content.

Voice and Audio Data

Starlett is a voice-based tutoring service that processes audio of the user's voice (parent or child) when they speak to Starlett. During sign-up, we ask for your permission to store your child's conversations, so that Starlett can remember recent sessions and so that you can review them. We do not currently use them to train any model. If we ever use them to train our own models, it will be only for purposes we describe to you at the time, only with your consent, and subject to the retention limits in Section 4. We do not sell them or use them for advertising. Stored conversations are kept for no more than 90 days unless you opt in to keep more, and for 30 days by default; you can adjust the period within that limit, or delete any conversation at once, in your parent settings. See Section 4 for the full retention policy.

Photos and Images

The Service does not currently offer any feature that captures or uploads a photograph or video of your child. Features that would use photographs are optional, not yet offered, and described in the next section.

Optional Features Using Images or Biometric Data (Not Currently Offered)

The Service does not currently include any feature that collects images of a child, or biometric identifiers of anyone, and nothing described in this section is collected unless and until you turn on a specific optional feature and give the specific consent it requires. We set out the rules here in advance so that, if we ever offer such a feature, you know how it would be governed, and so that enabling it later does not change anything you have already agreed to. A biometric identifier means data derived from a person's body that can identify them, such as a voiceprint or a scan of face geometry.

Before any such collection begins, we will give you a written notice describing the specific feature, the specific purpose for which the data is collected and how long it will be kept, and we will obtain your written consent: verifiable parental consent for anything relating to a child, and a written release from any adult whose own image or voice is involved. Turning on one feature does not turn on another, and you can turn each one off at any time, which stops further collection for that feature.

Retention and destruction. Data collected for such a feature is permanently destroyed when the purpose for collecting it has been satisfied, when you turn the feature off, or when you delete the account, whichever comes first, and in every case no later than the outer retention limit in Section 4, or sooner where the law of your state requires. This schedule applies to every such feature; a feature's own notice may set a shorter period, but not a longer one.

What we will not do with it. We will not sell, lease, trade or otherwise profit from any biometric identifier or image. We will not disclose it to anyone outside the service providers who process it for us under written contract, and not without your consent. We will protect it using at least the same standard of care we apply to our other sensitive data. We will not use it to train any model unless you have separately consented to that use.

Service Usage Data

We automatically collect certain information about how the Service is accessed and used:

• Device Information: Technical information about the device, such as device type, operating system, browser type, app version, IP address and other device identifiers, and general device settings.
• Technical Logs: When you or your child use Starlett, or when anyone visits our public website, our systems and our hosting provider keep technical records of requests, such as when a request was made, which part of the Service or website it was for, and the device's IP address. We use these records to operate, secure and fix the Service and the website, and to meet legal requirements.
• Progress and Performance Data: We keep track of the child's learning progress, as well as the child's preferences or interests as inferred from their interactions.
• Approximate Location: We may infer the user's general location (country, and possibly state/region) from information you provide. We do not currently collect precise device location.
• Cookies and Similar Tech: We use cookies and local storage to keep you signed in and to remember your preferences. We do not use tracking cookies for advertising, and neither the Service nor our public website currently uses analytics cookies. Because we do not currently track users across other websites or services, neither of them responds to browser "Do Not Track" signals. Our service providers receive information as described in Section 3; we do not currently allow any other company to collect personal information through the Service about users' online activities over time and across other websites or services.

Support and Contact Info

If you contact us for help or feedback, we will collect your contact information and the content of your communication to respond to you and improve our services.

Our Website and Waitlist

Our public website is intended for parents and other adults. If you join our waitlist, we collect your email address, along with information about how you reached us (such as the link or referral code you used) and general information about your device and browser. We use this to tell you about Starlett's availability, to understand how people find us, and to recognise people who joined before launch. We keep it only for as long as it serves those purposes, and you can ask us to remove it at any time. Our service providers receive information as described in Section 3; we do not currently allow any other company to collect personal information through our website about your online activities over time and across other websites.

Newsletter and Promotional Communications (Optional)

If you opt-in to our parent newsletter or updates, we will collect your email for that purpose. We may send promotional emails from time to time about new features, educational content, or special offers. This is entirely optional and you can unsubscribe at any time via the unsubscribe link in any email or by contacting us.

2. How We Use the Information

We use the information we collect for the following purposes:

• To Provide and Operate the Service: We use personal information to create accounts, authenticate users, and allow you and your child to use Starlett's features.
• Personalization: Starlett's core feature is to tailor the experience to each child. We use data about your child's interests, performance, and preferences to recommend or create content that suits them.
• Creating User-Generated Content: Voice recordings and text you provide (with consent) are used by our AI to produce the content you asked for. The Service does not currently offer any feature for photographs or video of a child; the optional features that would are described in Section 1 and are off unless you enable them.
• Support for Internal Operations: We collect device identifiers and other technical data, such as the sign-in cookie and the IP address in our technical logs, to support the internal operations of the Service: keeping you signed in, maintaining and securing the Service, debugging and fixing errors, preventing fraud, and meeting legal requirements. To keep these identifiers from being used to contact or build a profile of a specific individual, or for advertising, we do not currently run advertising or analytics services in the Service, we limit access to these records to the people and systems that need them for those operations, and our agreements with service providers govern how they may use them.
• Communication with Parents: We use parent contact information (email) to send important account or transaction communications. We may also send promotional emails about new features, educational content, or special offers if you have opted in. We do not contact children directly.
• Customer Support: When you reach out with questions or issues, we use your information to resolve your problem and improve the Service.
• Improvement: We may use aggregated information that does not identify any individual to understand how the Service is performing and to improve it. The Service does not currently use a third-party analytics service.
• Research and Development: We may use aggregated usage statistics that do not identify any individual to understand how the Service is used and to design new educational content. We do not currently use your child's personal information to train AI models. If we do so in future, it will be only for purposes we describe to you at the time, only with your consent, and subject to the retention limits in Section 4.
• Legal Compliance and Safety: We may use your information to comply with legal obligations, to detect or prevent fraud, and to enforce our Terms of Service.

We do not use personal information for any purpose that is incompatible with the purposes outlined above without obtaining your consent. In particular, we do not use children's personal data for advertising or marketing beyond the operation of our Service.

3. How We Share or Disclose Information

We understand the importance of keeping your and your child's information safe and private. We do not sell, rent, or share your personal information or your child's personal information with independent third parties for their own use. We share information only in the following limited situations:

With Service Providers and Vendors

We use trusted third-party companies to help us operate and provide the Service and our public website, including its waitlist. Examples include cloud hosting and storage providers, email and notification services, and AI and speech providers. These service providers receive the information they need to perform their functions. We require them to use reasonable measures to maintain the confidentiality, security and integrity of the information, and to use it to provide and secure their services for us.

With Other Users (Approved Sharing)

The Service does not currently include any social or sharing features, and no information about your child is shared with other users. If we add such a feature in future, it will be off by default, activated only by you, and any sharing will require the approval of every parent involved.

Business Transfers

If Starlett Inc. is involved in a merger, acquisition, sale of assets, or reorganization, your personal information may be transferred to the successor entity. We will notify you of any change in ownership or control of your personal information.

Legal Requirements

We may disclose information if required to do so by law or legal process, or if we have a good-faith belief that such disclosure is necessary to comply with applicable laws, enforce our Terms of Service, detect fraud, or protect the rights, property, or safety of Starlett, our users, or the public.

With Consent

Aside from the cases above, we will ask for a parent's consent before sharing personal information in any new way.

When we share information, we share what is needed for the purpose. We do not share children's personal information for marketing or advertising purposes. We do not allow third-party advertising networks to collect info on our Service for targeted ads.

4. Data Retention and Deletion

Retention Period: We retain personal information only for as long as is reasonably necessary for the purpose it was collected for, and not indefinitely. Your child's stored conversations are kept for no more than 90 days unless you opt in to keep more, and for 30 days by default. You can choose a shorter or longer period within that limit in your parent settings, or delete any conversation immediately. If you opt in to keep more history, we keep it for as long as your account is active and the setting is on, up to the limit shown in your parent settings and not beyond the outer limit below, and delete it when you turn the setting off, delete it, or your account closes or goes unused for the inactivity period described below. All other personal information is kept no longer than the account it belongs to, subject to the inactivity rule below, and is deleted sooner once it is no longer needed for the purpose it was collected for. While your account is active, we keep the information associated with it so that the Service functions properly. If an account is not used for 18 months, we may contact you first, and if it remains unused we delete the account and the personal information associated with it. You can extend that period in your parent settings. Outer limit: whatever the setting, nothing is kept beyond three years after your last interaction with the Service.

Website and Waitlist: Information you give us only through our public website, such as by joining the waitlist, does not belong to an account and is kept as described under “Our Website and Waitlist” in Section 1.

Parental Deletion Requests: As a parent, you have the right to request deletion of your child's personal information at any time. Upon such request, we will delete the child's personal data from our active systems, unless retention is required for a lawful reason.

Manner of Deletion: When we delete personal information, we use reasonable measures to protect against unauthorized access or use of the information in connection with its deletion.

5. Parents' Rights and Choices

As a parent or legal guardian, you have a number of important rights regarding your and your child's personal information. We are committed to upholding your rights and helping you exercise control over your child's data.

• Right to Review Information: You have the right to know what personal information we have collected from your child. You can request access to your child's personal data that we have on file.
• Right to Request Correction: If any personal information about you or your child is incorrect or outdated, you can request that we correct or update it.
• Right to Delete (Erasure): You can request deletion of personal information we've collected from your child at any time.
• Right to Consent or Withdraw Consent: You have the right to consent to the collection and use of your child's personal information, and to withdraw that consent later. Optional features that use images or biometric data each require their own separate consent, and each can be turned off individually without affecting the rest of the Service.

Exercise of Rights: To exercise any of these rights, you can contact us at our designated contact. For access or deletion requests, we will take steps to verify your identity as the parent/guardian. We will respond to such requests within a reasonable timeframe and in accordance with applicable law.

We will not charge you for exercising your rights unless the requests are manifestly unfounded or excessive.

6. Data Security

We are committed to protecting your and your child's personal information with security measures appropriate to the sensitivity of that information, to safeguard it against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: Data is encrypted in transit (TLS), and sensitive data is encrypted at rest where our storage providers support it.
• Access Controls: Access to personal information is limited to the people and systems that need it to provide the Service.
• Updates: We keep the software and services we rely on updated to address known security vulnerabilities.
• Incident Response: In the event of a data breach affecting your or your child's information, we will notify you as required by law.

Despite all measures, no security system is perfect. We cannot guarantee absolute security of data. You also play a role: protect your account credentials and notify us immediately if you suspect any unauthorized access to your account.

7. Children's Privacy and COPPA Details

Because our Service is specifically directed to children (with parental consent), we want to provide additional transparency about our children's privacy practices in compliance with COPPA:

• No Third-Party Advertising: We do not allow third-party ads on our child-directed Service. We do not use information collected from children to advertise or market to them.
• A Profile for Personalisation, Not for Advertising: With your consent, we keep a profile for your child — the details you provide, such as first name and birth date, together with their interests and learning progress — in order to personalise the Service, as described in Section 1. We use that profile for the purposes described in this Policy. We do not use persistent identifiers or other information to build profiles of children for advertising or marketing, and we do not track children across other websites or services.
• Parental Consent Verification: We obtain verifiable parental consent, using a method recognised under COPPA, before we collect any personal information from a child, except as described under “Before Consent Is Given” below. The sign-up flow describes the method in use.
• Parental Notice: This Privacy Policy serves as the comprehensive description of our practices. We also provide a direct notice in the sign-up flow that highlights the key COPPA disclosures.
• Per-Feature Consent: Any feature that would collect a new category of data from your child, including images or biometric identifiers, is presented to you as a separate choice with its own notice and consent.
• Before Consent Is Given: Until you have given consent, we collect no personal information about your child except as COPPA permits, such as an IP address or other technical identifier needed to run and secure the Service. Your own contact information, collected to give you notice and obtain your consent, is deleted if you do not give consent within a reasonable time.

8. Other Regions

The Starlett Service is currently only available to residents of the United States. If we offer it in other countries or regions, we will update this Policy to reflect the privacy and online-safety laws that apply there before doing so.

9. Links to Other Websites

Our website and the Service may link to websites run by other companies. When you follow such a link, you leave our website or the Service, and that website's own privacy policy, not this one, applies to what it collects. Information collected through our website or the Service, including by the service providers described in Section 3, is covered by this Policy.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we do, we will notify you as required: for significant changes, we will provide a clear notice (e.g., via email to the parent's address on file and/or a pop-up notice in the app) explaining the changes.

If we plan to make any material changes in the way we collect, use, or share a child's personal information, we will obtain verifiable parental consent for those new practices if required by law.

For changes that do not affect how we collect, use, or share a child's personal information, your continued use of Starlett after the updated Policy is posted and notice is given constitutes your acceptance of it. Material changes to our children's data practices take effect for your child only after we have obtained your verifiable parental consent to them.

11. Contact Us

If you have any questions, concerns, or comments about this Privacy Policy or our data practices, or if you wish to exercise any of your rights as described above, please contact us:

Starlett Inc. – Privacy Team
Attn: Privacy Inquiries
1600 N. Milwaukee Ave. #1027
Vernon Hills, IL 60061
United States

Email: privacy@starlett.ai
Telephone: +1 (267) 827-5388 (1-AM-STARLETT)

For COPPA-specific inquiries or any issues regarding your child's information, please include "COPPA Privacy Request" in the subject line of your email so we can handle it with priority. You can also reach out via postal mail at the address above.

We will respond to your inquiries as soon as reasonably possible, and at most within any timeframe required by law. Your family's privacy is extremely important to us, and we welcome feedback or questions that help us ensure we are doing the best job possible.

Thank you for reading our Privacy Policy and for helping us protect your child's privacy. By working together – through parental supervision and our commitment to compliance – we can provide a safe, fun, and enriching learning experience for your child with Starlett.