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Balance — Children's Privacy Notice and Direct Notice to Parents

Effective date: 19 July 2026 Last updated: 19 July 2026

Applies to: every kid whose Android device has been paired with a parent's Balance account, regardless of the country the parent lives in.

This document is the Children's Privacy Notice that accompanies our Privacy Policy and the Direct Notice to Parents required under the U.S. Children's Online Privacy Protection Act ("COPPA"). It also satisfies the parent-notice obligations of the UK Age Appropriate Design Code ("UK Children's Code"), Article 8 of the EU/UK GDPR ("GDPR-K"), Article 16 of Chile's Law 21.719, and Articles 6 and 7 of Colombia's Law 1581 read together with the "superior interest of the minor" doctrine.

It is written for parents and legal guardians. The kid does not see, sign or click "I agree" on this document, on our Privacy Policy, on our Terms of Service, or on anything else inside Balance. The parent — a verified adult — makes every consent decision in Balance on the kid's behalf.

If you only have a moment, read Section 2 (the one-page summary) and Section 11 (how to refuse, review, correct or delete the kid's data).


1. Who is collecting and using your kid's data

Operator / data controller BabaYaga Program, TOO — a limited liability partnership organised under the laws of Kazakhstan.
Registered address ul. Ongarsynova 10, kv. 175, Esil district, Astana 010000, Kazakhstan.
Business identification number (BIN) 260540024651.
App Balance — Android package com.babayagaprogram.balance, sold and updated through Google Play.
Authorised signatory , Director.
General help
Privacy / data-protection enquiries (named privacy contact)
Child-safety reports and security incidents (named child-safety contact)
Telephone

EU representative under Article 27 GDPR. For families in the European Union and EEA, our appointed representative is Prighter EU Rep GmbH. Address: Schellinggasse 3, 1010 Vienna, Austria. Intake form: https://app.prighter.com/portal/12736305032.

UK representative under Article 27 UK GDPR. For families in the United Kingdom, our appointed representative is Prighter Ltd (UK). Address: 20 Mortlake High Street, London SW14 8JN, United Kingdom.

For other countries (the full list is in Section 14 of this Notice and in Section 18 of the Privacy Policy), the local regulator and complaint route are published in the country annexes that travel with this Notice.


2. One-page summary for parents

The rest of this Notice is the long-form version of those promises.


3. Why a separate Children's Privacy Notice exists

Balance has two real users in every household: a parent (an adult who creates the account, configures everything, and is the controller-side counterparty in our consent record) and a kid (a minor whose Android device the parent pairs to the account, and whose personal data is the subject of most of our processing). Because the kid is a minor, several jurisdictions require us to publish a notice specifically about how the kid's data is handled, separately from the general Privacy Policy. That is this document. It does not replace the Privacy Policy — it complements it.

This Notice also serves as the Direct Notice to Parents required by 16 CFR § 312.4(c) for U.S. families covered by COPPA. The Privacy Policy at privacy.html serves as the online notice required by 16 CFR § 312.4(d).


4. What information Balance collects about your kid

Because Balance is parent-gated, anything described below is collected only after you, the parent, have created the kid profile and paired the kid's device by completing the in-app pairing flow. Nothing in this list is collected before that step.

We organise this Notice by category — the same categories used in our Privacy Policy. Adding a new technical field to one of our databases does not change what you read here unless that field introduces a new category of personal data (for example, location data), and we have no plans to introduce one.

4.1 Information you give us when you create the kid profile

We do not ask you for the kid's real surname, school, address, photo, government identifier, social-network handle, or any other identifier beyond the items above.

4.2 Information from the kid's paired Android device

The kid's device generates and transmits the items listed below. The kid does not type, click, or choose any of these — they are automatic outputs of the parental-control function the parent enabled.

We do not record: - what the kid types on the keyboard; - what the kid sees on the screen (screenshots, screen-content, or screen-recording); - which websites the kid visits, or the kid's browser history or search queries; - which YouTube videos the kid watches (we count only that the YouTube app was foreground for N minutes; we do not look at the video URL, title, or recommendation history); - the kid's chats, messages, notifications from other apps, contacts, or address book; - the kid's voice or microphone audio outside of the active proof-video capture screen (see § 4.3); - the kid's location.

4.3 End-to-end-encrypted proof media (only when you configure a task to require photo or video)

You can configure a task so that the kid must submit a photo or video to mark the task done — for example, "show me your homework page". When the kid taps Capture, the kid's device opens the camera. Audio is captured only as the soundtrack of a proof-video (the photo path does not record audio). Nothing is uploaded until the kid hits Submit.

When the kid submits, the following happens on the kid's device, before any byte leaves the phone:

  1. The kid's device generates a fresh per-file encryption key (a "file encryption key" or FEK).
  2. The kid's device encrypts the photo/video with XChaCha20-Poly1305 (AEAD) using that FEK.
  3. The FEK is then wrapped to your parent device's X25519 public key (and to each of your authorised parent devices, if you have more than one).
  4. The kid's device requests a short-lived (5-minute) signed upload URL from our backend and uploads the resulting ciphertext directly to our storage provider, Google Cloud Storage, bypassing our application servers entirely.
  5. The kid's device retains the proof for the time necessary to confirm the upload completed, then wipes the original plaintext from the device's cache.

The upshot is: our backend never sees the plaintext content of the photo or video, and our storage provider Google Cloud Storage never sees it either. Neither we nor any sub-processor can view, recover, transcribe, hash, or hand over plaintext proof media. Only the parent's authorised device(s) can decrypt the file. See Section 9 of the Privacy Policy for the cryptography in more detail.

There is no gallery picker — only on-device capture, so we know proof media originates on the device.

We do not use the kid's proof media for any purpose other than letting the parent review and approve/decline the linked task. We do not: - show the proof media to anyone outside the family; - analyse its content; - index, search, transcribe, or generate metadata from it; - repurpose it for product improvement of any kind.

Encrypted proof media is automatically deleted 30 days after the linked task closes (approved, declined, revoked, missed, or cancelled). The parent can delete sooner from inside the app.

4.4 Verification and security data about the parent that touches the kid record

A few items are technically attached to the parent (because the parent holds the account) but are listed here for completeness because they are part of the protection layer around the kid's data:

4.5 Operational technical data

When the kid's device contacts our backend we receive standard HTTP request data — method, route, response status, error code, request timing — which is kept in our server logs (retained per Section 8 of the Privacy Policy). For authentication-sensitive requests we also temporarily process the request's IP address to throttle abuse. The kid's device does not transmit a phone number, SIM identifier, Android Advertising ID, or any other persistent device identifier beyond the random deviceId described in § 4.2.

4.6 What we explicitly do not collect from your kid

To remove any ambiguity, Balance does not collect or process any of the following from your kid:


5. How we use the kid's data, and the lawful basis for it

We use the categories in Section 4 for one purpose only: to run the parental-control service the parent purchased. That means, concretely:

Lawful basis (per jurisdiction):

In every one of these countries, the monitoring, screen-time limits, task, and reward features of Balance are performed at the parent's direction, strictly for the safety, well-being, and parental supervision of the kid, and are never used for advertising, profiling, or any other commercial purpose. This is the "safety of the child" purpose recognised by Part B of the Fourth Schedule to India's DPDP Rules 2025, the parental-supervision-tool framing of Indonesia's GR 17/2025 ("PP Tunas") and Brazil's ECA Digital (Lei 15.211/2025), the competent-person consent model of South Africa's POPIA §35, and the legal-representative consent model of South Korea's PIPA art 22-2.

We do not rely on the kid's consent for any of the processing in Section 5. The kid is a data subject under Balance, not a consenter.


6. We do not show advertising to the kid, and we do not profile the kid

Restated here because it is the single most important promise of this Notice:

In several countries, this is also a statutory command we embrace: Brazil's ECA Digital (Lei 15.211/2025), Indonesia's GR 17/2025 ("PP Tunas") ban on the commercial profiling of children, and India's DPDP Act 2023 §9(3) prohibition on tracking, behavioural monitoring, and targeted advertising directed at children all prohibit what Balance already refuses to do.


7. Disclosures of the kid's data — sub-processors

We use a small number of service providers to run Balance. Each is bound by a written data-processing agreement that requires them to follow our instructions, keep your kid's data secure, and not use it for their own purposes. Below is the list specifically as it touches the kid's data:

Provider Role Region What they can see about the kid
Emergent Labs Inc. (USA), using MongoDB Atlas (MongoDB, Inc., USA) for the production database and additional managed cloud providers operated by Emergent Hosting our backend and database United States Everything in § 4.1 + § 4.2 + § 4.4 + § 4.5 except: plaintext proof media (never reaches the backend — end-to-end encrypted on the kid's device before upload), plaintext OTPs (we only hold peppered hashes), unwrapped media-encryption keys (which never leave your device unwrapped). Application logs (route, status, timing, IP at authentication-sensitive endpoints) retained per Emergent's published content-deletion and log-retention policy (Emergent ToS §§ 3.3 and 9.4). MongoDB Atlas operates under its own published Data Processing Agreement with EU Standard Contractual Clauses, available at https://www.mongodb.com/legal/dpa, which covers the storage layer where the kid's data actually sits at rest.
Google LLC via Google Cloud Storage (USA) Storing the end-to-end-encrypted proof media United States Opaque ciphertext only. Neither Google Cloud Storage nor we can read it.
Google LLC via Google Cloud (USA) Periodic (daily) backups of our operational database United States A copy of the kid's operational record as held in the database (§ 4.1, § 4.2, § 4.4, § 4.5 — name, age, usage totals, installed-apps catalogue, tasks and earned-time ledger, device identifier, push token), other than the items that never reach our backend in readable form (plaintext proof media and unwrapped media-encryption keys).
Google LLC via Firebase Cloud Messaging (USA) Delivering push notifications to the kid's device United States The push token attached to the kid's device, plus the short body+title of each push at the moment of send. We deliberately keep push bodies free of sensitive content (no proof-media preview, no message body, no kid's full name).
Google LLC via Firebase Crashlytics (USA) Anonymised crash-diagnostics from the kid's Balance build United States Stack trace, device model, OS version, locale, Balance app version, and a Firebase installation identifier. No kid name, no email, no proof-media content, no task text, no screen content. No custom data is written into Crashlytics.
Prighter Group (Prighter EU Rep GmbH, Austria; Prighter Ltd (UK), United Kingdom) Our EU and UK Article 27 representative EU + UK The contents of any data-subject-rights request a parent in the EU/UK routes through Prighter. Prighter forwards the request to us.

We do not use Resend (our email sub-processor) to send anything to the kid — only to the parent.

We do not embed any third-party advertising SDK, attribution SDK, behavioural-profiling SDK, or social-login SDK directed at the kid in the Balance app. The kid build embeds only one Google diagnostic SDK — Firebase Crashlytics — for crash-diagnostics only. The kid's device makes network calls to: (a) our backend; (b) Google Cloud Storage for the encrypted-media upload; (c) Google Firebase Cloud Messaging for push delivery; and (d) Google Firebase Crashlytics on app crash. There is no analytics SDK on the kid build. Firebase Analytics is present on the parent build only — never on the kid build — and even on the parent build it is off by default and collected only with the parent's opt-in consent (see § 3.5 and § 6 of the Privacy Policy). Analytics plays no part in how we handle the kid's data.

We do not sell, rent, or trade the kid's personal data. We do not "share" the kid's personal data for cross-context behavioural advertising as defined in any applicable U.S. state privacy law.

For families in the EU/EEA and UK, the international-transfer mechanisms that protect the cross-border movement of the kid's data are described in Section 7 of the Privacy Policy.


8. How long we keep the kid's data — retention schedule

This is the COPPA-mandated written retention schedule applied to the kid's data.

Category of kid data Maximum retention
Kid account record (name, age, optional birthday, optional avatar, settings, ledger) Until the parent deletes the kid; then within 1 hour of the in-app confirmation (or under the statutory deadlines in Section 11 for email/manual requests)
Per-app daily screen-time totals (§ 4.2) 90 days, then automatically deleted
Installed-apps catalogue on the kid's device (§ 4.2) Refreshed continuously; deleted when the kid is deleted
Notifications addressed to the kid 30 days, then automatically deleted
Encrypted proof media (photos/videos) and their thumbnails (§ 4.3) 30 days after the linked task closes, then automatically deleted; the parent can delete sooner from the app
Encrypted media keys (per-device per-pair) Same lifecycle as the kid they protect; deleted in the kid-deletion cascade
Reconnect codes used to re-pair the kid's device 15 minutes, single-use, automatically deleted
Operational server logs touching the kid's device Retained by our hosting provider Emergent Labs Inc. according to Emergent's published content-deletion and log-retention policy (Emergent ToS §§ 3.3 and 9.4)
Operational database backups Two layers: (a) our hosting provider's own operational snapshots, governed by that provider's published backup-retention policy; and (b) our periodic (daily) backups of the operational database stored with Google Cloud, kept on a 30-day rolling window and then automatically deleted. Once a backup rotates out, deleted personal data in it becomes unrecoverable.

We do not keep the kid's data after the kid's record is deleted, except (a) in the operational-backup window noted above, which then expires automatically, and (b) where a law in the parent's country requires us to retain a specific record (in which case we retain only what the law requires, for only as long as it requires, and in isolated archival storage).


9. Security measures protecting the kid's data

We use, at minimum, the following technical safeguards for the kid's data. The Privacy Policy's Section 9 contains the canonical description; this Notice repeats the items most relevant to a parent.

If a personal-data breach affects the kid's data, we will notify the competent supervisory authority and, where required by law, you, in line with GDPR Articles 33 and 34, the U.S. state breach-notification regimes that apply to your state, and the equivalent rules elsewhere.


10. Your rights as parent

As the parent, you can exercise the following rights at any time, on your behalf and on your kid's behalf:

These rights are concurrent: exercising one (for example, deletion) does not waive the others.

Country-specific mechanics: in Mexico these rights are exercised as ARCO requests under the LFPDPPP (2025); in India through the grievance channel of the DPDP Act 2023, within the statutory response timelines of the DPDP Rules 2025; in South Korea the legal representative (the parent) exercises the under-14 kid's rights under PIPA art 22-2. The country annex for your country names the route.


11. How to refuse, review, correct or delete the kid's data — concrete steps

We have tried to make every action you might want to take possible from inside the app, in a small number of taps.

Inside the app — fastest route:

  1. Open Balance on the parent's device.
  2. Sign in.
  3. Open the in-app privacy settings.
  4. Choose one of: - Export data — generates a downloadable JSON archive of your family record (see Section 12 of the Privacy Policy for the format). - Delete kid — pick the kid; you will be asked to confirm; after confirmation we immediately stop collection from that kid's device, set the kid record to pending_deletion, and run the deletion cascade once the 1-hour in-app cool-off elapses (email/manual requests are honoured under the statutory deadlines in Section 11). The encrypted proof media for that kid is deleted in the same cascade. - Delete account — deletes the parent account and every kid profile attached to it (full cascade as described in the Privacy Policy).

By email — for jurisdictions where you prefer an evidentiary trail, or if the in-app flow is unavailable:

Write to from the email address you used to register the account, and include: - the kid's first name and (if you set one) avatar — enough for us to find the right record; - the action you want us to take (review / correct / delete / restrict / port); - where you live (so we apply the correct statutory deadline).

We will reply within the following maximum deadlines: - Under GDPR / UK GDPR: 30 calendar days from the date we receive the request (extendable to 90 days for complex requests, with notice). - Under most U.S. state privacy laws (CCPA/CPRA, VCDPA, CPA, CTDPA, UCPA, TDPSA, and others): 45 calendar days, extendable by 45 more with notice. - Under COPPA (FTC's Direct-Notice rule): without unreasonable delay, in practice within 10 business days for verified parental deletion requests.

We may ask you to confirm the email address on file — by entering an OTP we send to that address — before we act on a deletion or access request, to make sure we are talking to the actual account holder and not someone impersonating you.

Refusing further collection without deleting anything:

You can refuse a future category of collection by simply not enabling the feature that produces it. For example: do not enable photo-proof on any task, and Balance will collect no media from the kid's device. Disable a task type, and Balance will stop collecting the data that task type produces.


12. Child safety, reporting, and our cooperation with authorities

Balance is a parental-control app, not a social network. We do not host public profiles, public posts, friend lists, chat, comments, or any other surface where the kid could be contacted by a stranger or could publish content publicly. Proof media is private to the family and is end-to-end encrypted (Section 4.3).

If you ever want to raise a child-safety concern — either about Balance itself, or about something that has happened on the kid's device and relates to Balance — please write to (named child-safety contact: ). We treat child-safety reports as our highest-priority queue and aim to acknowledge within one business day.

The Balance app also offers an in-app reporting button on every proof-media screen, so a parent or a paired kid device can submit a concern directly from the place it arises. (This feature lands in app version Phase 3.4 — for the latest status, see the in-app About screen.)

Where applicable law requires us to report Child Sexual Abuse Material (CSAM) or other forms of child sexual exploitation and abuse (CSAE) to a competent national authority (for example, the U.S. National Center for Missing & Exploited Children, NCMEC, under 18 U.S.C. § 2258A; or to your national hotline within the EU under the proposed CSAE Regulation), we will report and cooperate as the law requires. Because proof media is end-to-end encrypted, the only data we are in a position to share with such authorities is the metadata around an encrypted object (size, timing, the parent's account); we cannot share plaintext content we cannot read.


13. Changes to this Notice

We may update this Notice from time to time. If we make a material change to the kid-data section — for example, if a new sub-processor would be able to see kid data, or if a retention period for a kid-data category gets longer — we will:

We will not retroactively reduce protections that already apply to kid data we hold without an opt-in from the parent first.


14. Country annexes

This Notice is the global, universal version. For each country we publish a short annex naming the country's regulator, the parental-complaint route, the country-specific age threshold under that country's law, and any additional country-specific rights you have. The country-annex set is:

For the countries in the last line above, the statutory consent-age thresholds are summarised in the consent-age table in Section 5.6 of the Privacy Policy. In Balance the parent — a verified adult — consents on the kid's behalf regardless of the threshold, so every threshold is satisfied by design.

Inherited territories (Puerto Rico, Guam, US Virgin Islands; Bermuda, Cayman Islands, Channel Islands, Isle of Man, Gibraltar; the French overseas departments and territories; Greenland; Aruba and the BES; Åland) follow the privacy regime of their parent country, and the parent-country annex applies.

The annex set is published alongside this Notice at children.html and is incorporated by reference.


15. Quick-reference contacts


End of Children's Privacy Notice and Direct Notice to Parents.

International country annexes

The annexes below add the country-specific disclosures, rights, and contact channels required by local law on top of this document. They form part of this Policy and are incorporated by reference. Open the annex for your country of residence.