Privacy Policy

We take privacy seriously. These are our commitments in plain English:

Single purpose: We only use you and your child’s data to provide the services you use: we’ll never sell it, advertise based on it or use it as training data.

Data minimization: We only record audio when intentionally requested to (e.g., pressing the device button). We retain audio and message content for 90 days or less.

No eavesdropping: We don’t listen to user recordings unless you specifically ask us for help and give us permission or if we are compelled by law.

No location tracking: We don’t track you or your child or the device’s location in any way. The parent provided city location is used to provide local information such as the weather or local time.

The full legal details of our privacy practices are described in the content below. If you have any questions please reach out to us at legal@talkpoppy.com.

Full Policy

Last Updated: February 10, 2026

At Poppy Devices Inc, we take your privacy seriously, especially so because our service is intended for use by minors. Please read this Privacy Policy to learn how we treat personal data. By using or accessing our Services in any manner, you acknowledge that you, and any minors to which you are a legal guardian and have provided access to our Services, accept the practices and policies outlined below, and you hereby consent that we will collect, use and share user data as described in this Privacy Policy.

Remember that your use of our Services is at all times subject to our Terms of Service which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

1. What this Privacy Policy covers

This Privacy Policy covers how we treat Personal Data that we gather when you, and any minors to which you are a legal guardian and have provided access to our Services, use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

2. Personal Data

Categories of Personal Data We Collect

This list details the categories of Personal Data that we collect and have collected over the past 12 months:

Profile or Contact Data
Examples of Personal Data We Collect:

Guardian Profile or Contact Data

• First and last name
• Email
• Phone number

Minor Profile or Contact Data

• Full name
• Gender
• Date of birth
• City

Contact List Data
Examples of Personal Data We Collect:

• Phone contact list (including contact ‘friendly’ names)
• Poppy contact list (including contact ‘friendly’ names)

Recordings and Message Contents
Examples of Personal Data We Collect:

• Recordings or contents of conversations with digital assistant
• Recordings or contents of messages to contacts
• Recordings of phone calls

Usage Data
Examples of Personal Data We Collect about your usage of the Services, such as:

• Number of conversations
• Number of sent messages
• Number of received messages
• Number of outgoing calls
• Number of missed calls
• Call minutes

Payment Data
Examples of Personal Data We Collect:
Payment card type

• Last 4 digits of the payment card

Device/IP Data
Examples of Personal Data We Collect:

• IP address
• Device ID
• Type of device/operating system/browser used to access the Services

Web Analytics
Examples of Personal Data We Collect:

• Web page interactions
• Referring webpage/source through which you accessed the Services
• Non-identifiable request IDs
• Statistics associated with the interaction between device or browser and the Services

Geolocation Data
Examples of Personal Data We Collect:

• IP-address-based location information
• User provided city location

Other Identifying Information that You Voluntarily Choose to Provide
Examples of Personal Data We Collect:
Identifying information in free form text provided on the Services or in emails or letters you send us

3. Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:‍

When you or minors under your legal care who you have given access to Services provide such information directly to us:

• When you create an account or use our Services.
• When you or minors under your legal care voluntarily interact with the Services
• When you send us an email or otherwise contact us

When you use the Services and such information is collected automatically.

• Through cookies
• If you use a location-enabled browser, we may receive information about your location and mobile device, as applicable.

Third Parties Vendors
We may use analytics providers to analyze how you interact and engage with the
Services, or third parties may help us provide you with customer support.

Advertising Partners
We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements, or communications.

4. Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing, and Improving the Services

• Creating and managing your account or other user profiles.
• Processing orders or other transactions; billing.
• Providing you and minors under your legal care who you have given access to the Services with the products, services, or information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics, and product development.
• Personalizing the Services, website content, and communications based on your preferences.
• Doing fraud protection, security, and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.

Marketing the Services

• Marketing and selling the Services.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Poppy Devices Inc or the Services.
• Sending emails, SMS/MMS, phone calls and other communications according to your configured settings.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order, or other legal processes, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property, or safety of you, Poppy Devices Inc, or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice. ‍We do not sell or rent Personal Data to third parties for their own marketing or other purposes.

5. How We Share Your Personal Data

‍
We disclose your Personal Data to the categories of service providers and other parties listed in this section.

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

• Security and fraud prevention services
• Hosting, technology, and communication providers including:
  • OpenAI
  • Twilio
  • Google Cloud Platform
• Support and customer service vendors.

Commerce and Payment processors:

• Our e-commerce Shopify, Inc. (“Shopify”) collects your voluntarily provided information necessary to purchase products and services.
• Our payment processing partners (either Shopify or Stripe, Inc. (“Stripe”) collects your voluntarily provided payment card information necessary to process your payment.
• Please see Stripe’s and Shopify’s terms of service and privacy policy for information on its use and storage of your Personal Data.

Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.

Parties You Authorize, Access, or Authenticate‍ ‍

• Other users.

6. Legal Obligations

‍
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

7. Business Transfers

‍
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.‍

8. Data that is Not Personal Data‍

We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

9. Data Security and Retention

‍
We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

10. Personal Data of Children

As noted in the Terms of Service, we may collect Personal Data about children under 16 years of age for whom you have enabled access to our Services. It is your responsibility to manage access to the Services such that it is only children you are the legal guardian of and consent to use who access the Services. If we learn we have collected Personal Data from a child under 16 years of age whose legal guardian has not consented to their use of our Services, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us for which their legal guardian(s) did not consent, please contact us at support@talkpoppy.com.

11. Personal Data Use and Processing Grounds

‍The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.· Profile or Contact Data· Payment Data
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties: Profile or Contact Data; Payment Data; Device/IP Data; Contact List Data; Recordings and Message Contents; Web Analytics; Geolocation Data; Other Identifying Information that You Voluntarily Choose to Provide· We may also de-identify or anonymize Personal Data to further our legitimate interests.‍Examples of these legitimate interests include (as described in more detail above):· Providing, customizing, and improving the Services.· Marketing the Services.· Corresponding with you· Meeting legal requirements and enforcing legal terms.· Completing corporate transactions.
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

12. Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

13. Delete Personal Data

You can request that we erase some or all of your Personal Data from our systems. To do so, please email support@talkpoppy.com.

14. Transfers of Personal Data

The Services are hosted and operated in Canada and the United States (“Operating Countries”) through Poppy Devices Inc and its service providers, and if you do not reside in the Operating Countries, laws may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you or minors under your legal care, regardless of whether provided by you or obtained from a third party, is being provided to Poppy Devices Inc in the Operating Countries and will be hosted on Operating Countries servers, and you acknowledge that Poppy Devices Inc may transfer, store and process your information to and in the Operating Countries, and possibly other countries. Personal Data stored in the U.S. may be accessible to U.S. authorities or courts under applicable laws.

15. Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Poppy Devices Inc website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

16. Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: legal@talkpoppy.com