Privacy Policy for Cleverly Kids

Cleverly Learning Hub Philippines (“we,” “our,” or “us”) operates the Cleverly Kids mobile application (the “App”). We are dedicated to providing a safe, fun, and educational digital environment for children, parents, and educators.

This Privacy Policy explains how we handle information in connection with the App and outlines our compliance with children’s privacy standards, including the Children’s Online Privacy Protection Act (COPPA), the Data Privacy Act of 2012 (Republic Act No. 10173 of the Philippines), and the Google Play Families Policy.

1. Children’s Privacy & COPPA Compliance

Cleverly Kids is specifically designed for toddlers, preschoolers, and early elementary learners (ages 3–6). Protecting young learners’ privacy is our highest priority:

• No Personal Data Collection: We do not knowingly collect, store, share, or sell personally identifiable information (PII)—such as full names, home addresses, phone numbers, email addresses, or precise geolocation—from children under the age of 13.
• No Mandatory Account Registration: Children can access and use all learning activities, phonics games, math modules, and drawing canvases without creating an account or providing personal details.
• Offline-First Play: Gameplay progression, star counts, and completed activity records are stored locally on the user’s device and are never transmitted to external cloud servers.

2. Information We Collect and Process

A. Device & Technical Information (Non-Identifiable)

The App may process basic, non-personally identifiable technical information locally to ensure smooth operation, rendering performance, and audio playback. This may include:

• Device model and hardware specifications
• Operating system version
• App performance metrics and crash logs (processed anonymously to fix technical bugs)

B. Camera, Gallery & Storage Permissions

• Artwork Saving (Paint Studio & Coloring Carnival): The App may request access to save screenshots or images of artwork created by the child directly into the device’s local photo gallery.
• Local Processing Only: Any saved photos, drawings, or tracings remain strictly on your local device storage. We do not access, view, upload, or share personal photos or gallery contents.

C. Voice & Text-to-Speech (TTS)

• Audio prompts, phonetic sounds, and number counting are generated using local device Text-to-Speech engines or bundled pre-recorded audio assets.
• The App does not record, capture, or store the child’s voice.

3. Advertising and Commercial Content

• No Targeted or Behavioral Ads: Cleverly Kids does not display third-party interest-based, behavioral, or retargeted advertisements.

4. Third-Party Services and SDKs

• We only use core mobile framework components (such as Flutter and standard Android system libraries) necessary for application stability, audio rendering, and canvas interaction.
• We do not integrate third-party analytics or ad SDKs that track user identities across different applications or collect personal data from children.

5. Data Retention and Deletion

Because all user progress (e.g., stars earned, levels unlocked, custom artwork) is stored entirely on the local device:

• You can permanently delete all stored data and progress at any time by clearing the application storage in your device settings or by uninstalling the App.
• We do not maintain remote databases holding user-generated profiles or learning history.

6. Changes to This Privacy Policy

• We may update this Privacy Policy periodically to reflect enhancements to our educational modules or adjustments to regulatory requirements. Any updates will be posted directly to this URL with an updated “Last Updated” date.

7. Contact Us

• If you are a parent, guardian, or educator and have questions, feedback, or concerns regarding this Privacy Policy or our data practices, please contact us:
• Entity: Cleverly Learning Hub Philippines
• Website: https://cleverlyph.com
• Email: hello@cleverlyph.com