Privacy Policy — Star AI Tutor by SunnyAcademy Inc.

Effective Date: April 15, 2025
SunnyAcademy Inc.
16192 Coastal Highway, Lewes, DE 19958, USA
www.sunnyacademy.com

1. Introduction

At SunnyAcademy, we care deeply about your children’s privacy.
This Privacy Policy describes how we collect, use, and protect information related to children aged 5–16 who use our mobile application Star AI Tutor and related services, in accordance with the Children’s Online Privacy Protection Act (COPPA), the General Data Protection Regulation (GDPR-K), and the privacy rules of Apple and Google Play.

This policy applies to our mobile application Star AI Tutor (the “App”) and our website.

2. Who We Are

Star AI Tutor is an AI-powered language learning app developed and operated by SunnyAcademy Inc.
The app is designed specifically for children aged 5–16, offering personalized, child-safe educational experiences in full compliance with global data protection laws and app store guidelines.

3. What Information We Collect

We collect only the minimum amount of personal data needed to deliver our educational services through Star AI Tutor.

From the child:

• First name or nickname
• Age (not a birth date)
• Learning goals
• Lesson progress and quiz scores
• Interactions with the AI avatar
• Anonymous usage metrics (e.g., session length)

From the parent:

• Email address
• Contact phone number
• WhatsApp (for consent and communication)

From the device:

• Device type and operating system
• Browser type (for web use)
• Crash logs
• IP address (used only to infer region, not to identify)

❗ We do not collect: exact location, camera access, device IDs, advertising IDs (IDFA/GAID), contact lists, or biometric data.

4. How We Use the Information

We use the collected data to:

• Deliver personalized language learning content
• Adapt the AI avatar’s responses
• Monitor learning progress and engagement
• Communicate with parents (e.g., reports, alerts)
• Improve app performance and fix bugs
• Comply with legal obligations

🚫 We do not serve personalized ads, perform behavioral profiling, or sell any data to third parties.

5. Voice Interactions and Microphone Access

Star AI Tutor includes interactive speaking exercises powered by an AI avatar.
To enable this functionality, we request access to the device’s microphone.

• Voice input is processed only in real time to analyze the child’s pronunciation
• No voice recordings are stored or transmitted externally
• The avatar replies using text-to-speech (TTS) to create a natural dialogue
• Microphone access is active only during speaking lessons

🎙 Parents can manage microphone permissions via device settings.

6. Parental Rights & Control

We obtain verifiable parental consent through email confirmation before collecting any data from children under 13 (in the US) or under 16 (in the EU).

Parents or legal guardians can:

• Review the data collected about their child
• Request corrections or deletions
• Withdraw consent and deactivate the account
• Request a copy of all stored data

Parental requests may be sent to: privacy@sunnyacademy.com

7. Data Sharing

We only share data with:

• Trusted service providers (e.g., cloud infrastructure) under strict privacy agreements
• Legal authorities, when required by law

❌ We never share data with advertisers or third parties for marketing or profiling.

8. Analytics & Tracking

To improve educational outcomes, Star AI Tutor uses anonymized analytics:

• Firebase (Google) — app performance and crash reporting
• Amplitude — feature usage and engagement flow
• Cloudflare — secure content delivery

✅ We do not collect or use advertising IDs (IDFA/GAID).
✅ We do not track users across other apps.
✅ We comply with Apple’s and Google Play’s family safety policies.

9. In-App Purchases

Star AI Tutor may offer optional in-app purchases (e.g. advanced lessons) processed securely by the App Store or Google Play.
These purchases are protected with parental gates and are never accessible directly by children.

💳 We do not store or process any payment details ourselves.

10. Data Retention

We retain personal data only as long as necessary to:

• Provide educational services
• Meet legal or regulatory obligations
• Support parental access or deletion requests

Child accounts are deleted:

• Upon verified parental request
• Or after 12 months of inactivity

After deletion, all data is either anonymized or permanently erased.

11. Data Security

We use industry-standard security measures to protect your data:

• SSL/TLS encryption
• Isolated, access-controlled servers (in the US and EU)
• Internal audit logging
• Regular system and infrastructure reviews

12. International Data Transfers

Some data may be processed in the United States and/or the European Union.
We use Standard Contractual Clauses (SCCs) and appropriate safeguards in accordance with GDPR for international transfers.

13. Platform & Category Compliance

Star AI Tutor is listed in the Education category of the Apple App Store and Google Play.
It is designed for children aged 5–16 and fully complies with:

• COPPA (Children’s Online Privacy Protection Act)
• GDPR-K (Children’s data processing in the EU)
• Apple’s App Store privacy rules
• Google Play Families policies

14. Changes to This Policy

We may update this Privacy Policy to reflect legal changes or platform requirements.
Any material changes will be communicated via in-app notification or by email.

15. Contact Us

📧 privacy@sunnyacademy.com
📍 SunnyAcademy Inc.
16192 Coastal Highway, Lewes, DE 19958, USA

16. Summary for App Store Listing

✅ No third-party ads
✅ No user tracking
✅ Verifiable parental consent
✅ No access to camera or contacts
✅ COPPA & GDPR-K compliant
✅ Age rating: 5–16
✅ Listed as an educational app under the name Star AI Tutor