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# TinyNova Thinkers: Privacy Policy, Terms of Use, Credit and Refund Policy
This page has three parts: **Part 1 Privacy Policy**, **Part 2 Terms of Use** and **Part 3 Credit and Refund Policy**. The same page is linked from Google Play as both the privacy policy and the Terms of Service.
# Part 1: Privacy Policy
**TinyNova Thinkers** (the "App")
Operated by **Half World Tech** [LEGAL ENTITY NAME, ABN and registered address to be inserted] ("we", "us", "our")
Last updated: [DATE]
> DRAFT for legal review. Items in [BRACKETS] must be completed or confirmed before publishing. This policy must be published as a public web page (not a PDF), linked in Google Play Console, and available inside the App.
## 1. Who we are and how to contact us
Half World Tech develops and operates the TinyNova Thinkers app, which helps parents and guardians create short stories, facts, reading practice and craft ideas for their children.
Privacy contact: **admin@halfworldtech.com** (please put "Privacy" in the subject line).
[Postal address]
You can ask us to access, correct or delete personal information, ask a privacy question, or make a complaint at the address above. We will respond within [30] days.
## 2. Who the App is for
The App is designed for children to use **together with a parent or guardian**. Accounts, purchases and settings are intended to be managed by an adult. We do not knowingly allow a child to create an account on their own. The child's name and age are entered by the parent or guardian and do not need to be real or exact; a nickname and approximate age are fine. If you believe a child has given us personal information without a parent or guardian's involvement, contact us and we will delete it.
The App does not show advertising and does not include advertising or behavioural-tracking SDKs. [Confirm before each release.]
## 3. What information we collect and why
| Information | Where it comes from | Why we use it |
|---|---|---|
| **Account details**: name, email address, a unique account ID and sign-in method (Microsoft or Google sign-in) | You, through the sign-in provider | To create and secure your account and show your credit balance |
| **Child profile**: child's first name or nickname, age, favourite colour, reading voice and speed | You, entered in the App | To personalise stories and the App's appearance. Colour and voice settings stay on your device. The name and age are also sent to our servers when you ask for a story |
| **Requests and generated content**: the activity you choose, the child's name and age used in the request, and the story, title, summary and picture we create. **For the Craft Lab, the photo you choose to upload of the craft or materials**, and the ideas we create from it. The Craft Lab is not available to every account at present; this applies only if it is available to you | Created when you use the App | To produce the content, show it to you, and give you support |
| **Credit and purchase records**: credit balance, top-ups, promo codes you redeem, usage history, and Google Play order and purchase identifiers | You and Google Play | To run the credit system, prevent duplicate or fraudulent credit, and handle refunds. We do **not** receive or store your payment card details; Google Play processes the payment |
| **Support requests**: your name, email, message, any screenshot, photo or video you choose to attach, and technical details (app version, device model, operating system, language, time, and IP address where available) | You and your device | To answer your request and fix problems |
| **Technical and security logs**: request times, error messages, request identifiers and the child's age used in a request (we do not write the child's name to logs) | Our servers | To keep the service running, find faults and prevent misuse |
We collect only what we need to run the App. We do not collect your location, contacts, microphone recordings, or your device's advertising ID. [Confirm against the final permissions list.]
## 4. Who we share information with
We **do not sell** personal information and do not share it for advertising.
We share information only with the following service providers, who process it on our behalf to provide the App:
- **OpenAI** (United States). The child's name and age, and the text we generate, are sent to OpenAI's services to write stories and create pictures. We do not send your email address or account ID to OpenAI. [Confirm OpenAI data retention settings and terms for apps used by children.]
- **Microsoft** (Microsoft Entra External ID for sign-in, and Microsoft Azure for hosting, storage and monitoring). Our servers and stored data are hosted in Australia (Azure Australia East). [Confirm region for sign-in and monitoring services.]
- **Google** (Google Play for payments and purchase verification; Google sign-in if you choose it).
- **Our email provider** [name], to deliver your support requests to us.
We may also disclose information where the law requires it, to protect safety or rights, or as part of a sale or restructure of our business with notice to you.
### Overseas disclosure
Some providers above (including OpenAI) are in the United States or may process data outside Australia. We take reasonable steps to make sure they handle personal information in line with the Australian Privacy Principles, and we remain responsible for it.
## 5. How we protect information
- Data is sent over encrypted connections (HTTPS).
- Our servers use managed identities and access controls. Access to stored data is limited to people who need it.
- Stored data is encrypted at rest by our hosting provider.
- We regularly review the providers and software we use. If a data breach is likely to cause serious harm, we will notify affected people and the Office of the Australian Information Commissioner as required by law.
No system is completely secure. Please keep your account sign-in details private.
## 6. How long we keep information (retention)
[These periods are proposals; confirm each before publishing.]
| Information | Kept for |
|---|---|
| Account details and child profile data on our servers | While your account is active, and deleted after you delete your account (see section 7) |
| Generated stories, pictures, Craft Lab photos and request records | **90 days** after creation, or until you delete your account, whichever is sooner. A deletion job runs every day |
| Credit and purchase records | [7 years] after the transaction, because we must keep financial records. If you delete your account, we remove or anonymise the personal identifiers and keep only what the law requires |
| Support requests and attachments | **24 months** after the request was made |
| Technical and security logs, and usage and cost records linked to your account | **90 days**, deleted by the same daily job |
We delete or de-identify information we no longer need.
## 7. Deleting your account and data
You can ask us to delete your account and the personal information linked to it at any time:
- **In the App:** Settings > Delete my account (or Delete my data, which keeps your account).
- **On the web:** [public URL of /legal/delete-account], or email **admin@halfworldtech.com** with the subject "Delete my account".
When you delete your account we permanently delete your saved child profile, generated content, support requests and usage records, except the credit and purchase records we must keep by law (described in section 6). Your Microsoft or Google sign-in account is managed by that provider and is not deleted by us. Freezing or deactivating an account is not deletion, and we do not treat it as such.
Unused credit stays on the retained credit record and is not refunded on deletion. See Part 3 (Credit and Refund Policy).
## 8. Your rights
Under the Australian Privacy Act 1988 you can ask to see the personal information we hold about you and to have it corrected. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (www.oaic.gov.au). If you are in another country, you may have additional rights and we will respect them where the law requires.
## 9. Children's privacy
- We ask for a child's first name (or nickname) and age only to personalise stories.
- **The name and age do not have to be real or exact.** You can enter a nickname and an approximate age, or any value you prefer. The stories are written by an AI model that works on probabilities, so it uses these details only as a loose guide and does not need exact or true information to work. If you do not enter them, the App uses a default name ("friend") and age (7). [Default values to be built.]
- We do not ask for a child's surname, address, school or contact details. Please do not enter them. The Craft Lab (where available) asks you to upload a photo of a craft or materials; please do not include a person's face or other identifying details in it.
- A parent or guardian can ask us at any time to see, correct or delete a child's information.
- **Parents' rights.** A parent or guardian can at any time review the personal information we hold about their child, withdraw consent so that we stop collecting or using it, and ask us to delete it. To do this, use [Settings > Child data in the App] or email **admin@halfworldtech.com** with the subject "Child's data". We may ask you to confirm that you are the parent or guardian.
- **Who else handles children's information.** The companies listed in section 4 handle the child's name and age for us as service providers. Their contact details: [OpenAI: address, email]; [Microsoft: address, email]; [Google: address, email]. [Or name one contact who will answer all parents' questions.]
- Before a child's name and age are entered, the App asks the parent or guardian to read a notice and give consent. [Consent step to be built.]
- We design the App to meet Google Play's Families policy and applicable Australian children's privacy rules, including the Children's Online Privacy Code when it comes into force. [Confirm with legal advice.]
## 10. AI-generated content
Stories, facts and pictures are created by third-party AI services and can contain mistakes or content you find unsuitable. We apply safety instructions and filters, but we cannot guarantee every result. A parent or guardian should supervise use. You can report a problem from the App's Help and Support page. [Add an in-app "Report this content" option; required by Google Play's AI-generated content policy.]
## 11. Changes to this policy
We may change this policy at any time. The latest version is always the one published at [public URL of the privacy policy page], so please check that page for the current policy. We will post changes on this page and update the date. If a change is significant we will tell you in the App before it takes effect.
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# Part 2: Terms of Use
## T1. Agreement
By creating an account or using the App you agree to these Terms, the Privacy Policy (Part 1) and the Credit and Refund Policy (Part 3). If you do not agree, do not use the App.
## T2. Who can use the App
- You must be **18 or older** to create an account and to buy credit. The App is for children to use with a parent or guardian.
- You are responsible for the account, for the child's use of the App, and for keeping your sign-in details private.
- Do not enter a child's surname, address or contact details. A nickname and approximate age are fine.
## T3. The service
The App creates stories, facts, reading practice and craft ideas using third-party AI services. We may add, change or remove activities, and we may limit or suspend access to some features for some accounts.
## T4. AI-generated content
- AI content can contain errors or content you find unsuitable. We apply safety measures but cannot guarantee any result.
- A parent or guardian should supervise a child's use.
- Generated content is for personal, non-commercial family use. [Confirm ownership and licence wording with the lawyer.]
- You can report a problem with content through Help and Support. We may remove content or restrict an account to keep children safe.
## T5. Credit and payments
Credit is bought and used under Part 3. Prices are in A$ [and include GST]. Credit has no cash value.
## T6. Acceptable use
You must not: misuse or attack the service; use it to create unlawful, harmful or sexual content, or content that exploits children; try to get free credit by fraud, sharing or reselling promo codes; copy or reverse-engineer the App except as the law allows; or use automated tools to make requests.
## T7. Availability and changes
We try to keep the App available but do not promise it will always work without interruption. We may update these Terms. We will tell you in the App before significant changes take effect, and continuing to use the App means you accept them. The latest version is always the one published on this page.
## T8. Ending your account
You can delete your account at any time (see section 7 of the Privacy Policy). We may suspend or close an account that breaches these Terms. Unused credit is handled under Part 3.
## T9. Our responsibility
Nothing in these Terms excludes, restricts or modifies any right or remedy you have under the **Australian Consumer Law** or other law that cannot be excluded. Subject to that, to the extent the law allows, we are not liable for indirect or consequential loss, or for loss caused by third-party AI or hosting services being unavailable or producing unexpected content. [Lawyer to settle this clause.]
## T10. Governing law
These Terms are governed by the laws of [STATE], Australia, and the courts of [STATE] have jurisdiction. This does not limit any rights you have under consumer law where you live.
## T11. Contact
Half World Tech, admin@halfworldtech.com [address]
---
# Part 3: Credit and Refund Policy
> Open question for the lawyer: whether the 12-month expiry in C3 is permitted under the Australian Consumer Law gift card rules (ACL ss 99A-99G), and whether Apple's rules allow purchased credit to expire.
## C1. What credit is
"Credit" is a balance in Australian dollars (A$) that you use to create stories, facts and other content in the App. Each request uses an amount of credit shown in the App. Credit has **no cash value**, cannot be transferred, sold or exchanged for money, and is used only inside the App.
## C2. Buying credit
- You buy credit as packs through Google Play [and the Apple App Store]. The price is shown in A$ [and includes GST] before you buy.
- Payment is handled by the store. We do not see or keep your card details.
- The credit you receive for a pack is shown on the purchase screen. The full amount appears in your balance.
- Purchases are made by an adult. The App asks a parent check (phone PIN, biometric or a "grown-ups only" question) before a purchase, but the account holder is responsible for purchases made on the account.
- Credit is added after the store confirms your payment. If a payment is pending, credit is added when it completes.
## C3. When purchased credit expires
- Purchased credit expires **12 months after the date you bought it**.
- The App shows the expiry date of your credit on the purchase screen and in your wallet.
- Credit that expires first is used first.
- We will send you a reminder in the App [and by email] about [30] days before credit expires. A reminder is a courtesy and is not a condition of expiry.
- Expired credit is removed from your balance and cannot be restored. [If the law requires a longer period for purchased credit, the longer period applies.]
## C4. Promotional credit
- Promotional credit (for example from a promo code) is free, has no cash value and is never refundable.
- Each promo code states how it can be used: a "redeem by" date, and, where stated, a period after redemption or after first use within which the credit must be used. Unused promotional credit disappears when its period ends.
- Promotional credit is used before purchased credit.
- A promo code can be used once. We may cancel codes that are shared, sold or used to abuse the service.
## C5. Refunds
Purchases are non-refundable **except as required by the Australian Consumer Law or other applicable law**, or as set out below. Nothing in this policy limits your rights under the Australian Consumer Law.
1. **Nothing used.** If you have not used any of the credit from a purchase, we can ask the store to refund the whole purchase. Contact us within [14] days of purchase. Store refunds can only be made for a whole purchase.
2. **Partly used.** If any credit from a purchase has been used, we cannot refund part of it through the store, so the remaining credit is not refunded. We will remind you to use it before it expires.
3. **Store refunds.** If Google or Apple refunds a purchase (for example at your request, or after a dispute), we remove the matching credit from your account. If you have already used some of it, your balance can go below zero, and you will need to add credit before making more requests.
4. **Faults.** If a request fails, we do not charge for it. If you were charged for something that did not work, contact us and we will correct it.
5. **Making a request.** Email **admin@halfworldtech.com** with your account email and the purchase receipt or order number.
## C6. If we change or close the service
- We may change prices, packs or how much credit a request uses. Changes apply to future requests and purchases, and we show the amount in the App before you buy or generate.
- If we decide to **close the App**, we will give at least [90] days' notice in the App [and by email] so you can use your credit. If credit remains after the service ends, we will refund purchased credit that you have not used, in a way the stores allow, or as required by law.
## C7. Deleting your account
If you delete your account, unused credit is not refunded. Our credit and purchase records are kept as described in section 6 of the Privacy Policy. Please use your credit first if you can.
## C8. Contact
Half World Tech, admin@halfworldtech.com [address]
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