Children’s Privacy Policy
Last Updated: [20260901]
This Children’s Privacy Policy is a supplement to our general Privacy Policy. It highlights how DINO INNOVATION LIMITED (“we”, “our” or “us”) handles personal information relating to children who use the DN-ENG41 (“Product”). It is written for Parents and children and should be read together with the general Privacy Policy.
A short note for children. Your Parent creates and manages your profile. When you speak to Product, your voice information is kept on the Product and the part needed to answer you is sent to OpenAI for processing. Our Product does not keep a separate copy of your voice content on its own servers. We do not sell your information or use it for targeted advertising. You can ask your Parent to manage or delete your information.
1. Who This Policy Applies To
This Policy applies when a child uses our Product that has been set up and managed by a parent or legal guardian (“Parent”). In the United States, “child” generally means a person under 13 for purposes of the Children’s Online Privacy Protection Act (“COPPA”). In the European Economic Area and the United Kingdom, Parent authorization may be required where the child is below the age at which the child can validly consent to an online service under local law.
The Parent creates or accesses the Parent Account, links the Product, creates the Child Profile and manages available controls.
2. Information We Collect
Information provided by the Parent. When creating or managing a Child Profile, the Parent may provide information such as the child’s nickname, age or date of birth, preferences and Product settings. The exact fields shown in the Parent interface control what information is requested.
Information generated when the child uses the Product. When the child uses Product, it processes the child’s voice input and, where needed to provide a response, the text or other content derived from that input. We ask children not to include unnecessary personal details in their requests.
This supplemental Policy focuses on information relating to the child. Information about the Parent, purchases, customer support and general technical operation is described in our general Privacy Policy.
3. How the Information Is Processed
On the Product. The Child Profile information and child interaction information described above are stored locally on the Product. The Parent can manage or delete locally stored information through the available Parent controls or by resetting the Product, as applicable.
By AI service provider. When the child uses an AI feature, the Product sends the part of the child’s voice input or related content needed to understand the request and generate a response to OpenAI, our AI service provider. OpenAI processes that information to provide the requested AI function and related safety controls, and the response is returned to the Product.
4. Parent Notice, Consent and Controls
Where COPPA applies, we provide direct notice to the Parent and obtain verifiable parental consent before enabling the collection, use or disclosure of personal information from a child, unless a limited legal exception applies. The notice explains that the AI feature requires relevant child input to be processed by OpenAI as an integral part of providing the requested response. If the Parent does not provide the required consent, the child cannot use the feature that requires that information.
Where European or UK data protection law requires Parent authorization because of the child’s age, we take reasonable steps to verify that authorization. Acceptance of the Terms of Service does not by itself replace any separate Parent notice or authorization required for the child’s information. The Parent may withdraw authorization or stop further use of the relevant feature at any time.
5. U.S. Processing, Retention and Security
OpenAI may process the information described above in the United States. Where European or UK data protection law applies, we use an applicable transfer safeguard, such as an adequacy mechanism or approved contractual clauses, together with additional measures where required.
Information stored on the Product remains there until the Parent deletes the relevant Child Profile or information, resets the Product, or the information is otherwise removed through the Product’s controls. OpenAI processes and retains information only for the limited period permitted by the applicable API configuration, our agreement and legal requirements.
We use reasonable measures designed to protect children’s information and require our service provider to maintain appropriate safeguards. No Product, network or service can be guaranteed to be completely secure.
6. Parent Rights and Choices
A Parent may review and correct the Child Profile information available on the Product, delete locally stored information, withdraw consent, stop further collection by disabling the relevant feature, or ask us to assist with a request relating to information processed by our service provider. Depending on applicable law, additional rights may include access, deletion, restriction, portability, objection and the right to complain to a data protection authority.
If we learn that child information has been collected without required Parent authorization, we will take reasonable steps to stop the processing and delete the information, including by working with the Parent and the relevant service provider where necessary, unless retention is required by law.
7. Changes and Contact Us
We may update this Policy to reflect changes in the Product, our practices or legal requirements. We will update the “Last Updated” date and provide additional notice where required. If a material change requires new Parent consent, we will obtain that consent before applying the change to previously collected child information.
Controller: DINO INNOVATION LIMITED
Address: 37 CROYDON ROAD, BECKENHAM, UNITED KINGDOM BR3 4AB
Privacy Email: service@gigglepal.com
Support Email: service@gigglepal.com
Website: www.gigglepal.com