Privacy Policy

Processing and protection of personal data

This Policy explains what personal data is processed when FamilyGuard is used, for what purposes, on what grounds, to whom it may be transferred, and how to exercise rights over personal data. Operator: Nikolenko Evgeniya Alekseevna, self-employed (professional income tax payer), location: Russian Federation, Krasnodar Krai, Krasnodar. Personal data contact: familyguard.notify@gmail.com.

1 Scope and legal grounds

1.1. This Policy applies to the FamilyGuard Android application, linked accounts, server components, and support. The processing of website visitors’ data is disclosed separately to the extent of the tools actually used on the website.

1.2. The Operator processes data in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other applicable rules. Confidentiality, use for specified purposes, data minimization, accuracy, and limits on retention periods are taken into account.

1.3. The grounds may be performance of a contract to which the data subject is a party or a beneficiary, valid consent, a statutory obligation, or another directly applicable ground. There must be an appropriate ground for each purpose; a statement about a child’s safety does not, by itself, replace this assessment.

1.4. This Policy provides information about processing. Downloading the application, accepting the Public Offer, or reading this Policy does not, by itself, constitute consent to any and all processing. Where consent is used, it is given separately and specifies the data, purposes, and conditions.

1.5. Acceptance of the User Agreement and Public Offer may be recorded using a single checkbox on first launch. Consent to data processing is confirmed using a separate checkbox for a separate text, by explicitly pressing “Continue”. Android permissions provide technical access and do not replace the appropriate legal ground.

2 Whose data is processed

2.1. Data may relate to an adult User, a parent or other legal representative, a child using a linked device, another family member who has voluntarily joined, or a person who contacts support.

2.2. Messages, photos, videos, audio, screenshots, and files may contain other people’s data. The application’s access to a file or device does not mean that the Operator and the User acquire an unrestricted right to process all information stored there.

2.3. When obtaining consent from a legal representative, the Operator verifies their authority. The verification method and the information required are explained before that information is obtained. Access to an email account, code, or device does not, by itself, prove a family relationship.

2.4. For a child, the specific profile or device and the representative confirming consent, where required, are identified. A parent’s consent concerning their own data is not automatically considered consent on behalf of any child or another adult in the group.

3 Categories of data and purposes of processing

3.1. Account and family: email address or other login identifier, name or chosen display name, account identifier, information about roles and device links, family group membership, and a profile photo if added. Purposes: creating an account, signing in, linking devices, managing family access rights, and displaying members.

3.2. Device and connection status: application and device identifiers to the extent used, model, Android and application versions, permission settings, connection and battery status, and technical events. Purposes: operating features, delivering notifications, compatibility, security, and diagnostics.

3.3. Geolocation: coordinates, time of determination, available accuracy, location history, address derived from coordinates, and information about movement and geofences. Purposes: displaying the location of a linked device, history, geofence events, locating the device, and sharing coordinates with the family. Background location access is disclosed when this feature is configured.

3.4. Communication: messages, voice messages and attachments, sending and delivery information, participants, and technical information about family calls. Purposes: private and family chats, audio and video communication, and displaying interaction history.

3.5. Microphone and ambient sound: audio stream from the child’s device, requested recordings, time, and session information. Purpose: providing the enabled feature for remotely listening to and recording the surroundings for lawful parental control. This is a separate use case from an ordinary conversation between a parent and a child.

3.6. Camera and screen: requested photos, camera video stream and recordings, screenshots and screen recordings, and session information. Purpose: providing the corresponding enabled feature on a linked device where permissions and legal grounds are in place.

3.7. Accessible device files: media files selected or requested within a supported feature, and necessary information about them. Purposes: viewing, transferring, downloading, or deleting a file through an authorized action. This access is not permission to collect all device data outside the selected feature.

3.8. Family commands and events: SOS, requests from the child, acceptance statuses, time, and coordinates relating to the event. Purposes: notifying the family, displaying event status, and communicating with the child.

3.9. Subscription and payments: selected plan, order, amount, date, payment status, necessary transaction identifiers, and consent to renewal. Purposes: fulfilling the order, accounting for payments, cancelling charges, refunds, and complying with legal requirements. Actual list of payment data and providers: —.

3.10. Support and diagnostics: content of the request, contact details for a reply, application version, device model, time of the error, and the log relating to it. Purposes: responding, resolving the problem, checking security, and handling claims. Necessary technical events and the information they contain: —.

3.11. Advertising and analytics, if used: —. Optional advertising processing and mailings are not automatically included in consent for core features. Any necessary separate consent may be withheld or withdrawn.

4 Obtaining data and enabling features

4.1. Data is received from the User, from lawfully linked devices when enabled features are used, from communication participants, payment providers, and support requests, to the extent necessary.

4.2. Before requesting access to geolocation, the microphone, camera, screen, or files, the purpose of that access is explained to the User. The feature is used within the selected settings, permissions, and applicable ground for processing.

4.3. Access to a child’s data is arranged with the involvement of a legal representative and with regard to the child’s rights, age, and applicable requirements. The representative must explain the nature of the application’s features to the child in an understandable way.

4.4. Confirming consent does not automatically enable all remote features. Access to them depends on their configuration and the necessary permissions. Mandatory system confirmations and indicators must not be bypassed.

4.5. For the SMS channel, if used, information also passes through the telecommunications operator and is sent to the selected linked number. The categories of information transmitted and its purpose are disclosed before the channel is enabled. Charges for telecommunications services are determined by the telecommunications operator.

4.6. Creating profiles for biometric identification and processing special categories of data are not covered by general consent for features. If such a separate use case is introduced, an applicable ground, the required form of consent, and advance information are necessary.

5 Storage, infrastructure, and recipients

5.1. Data may be processed on participants’ devices, in server components, and by engaged processors to the extent required by the selected feature. Actual allocation of processing: —.

5.2. Countries and locations of the databases and infrastructure used: —. Processing when collecting data on citizens of the Russian Federation must comply with localization requirements; general consent does not override these requirements.

5.3. Family members are provided only with data available to them under their role, settings, and lawful ground. Inviting a new member may change the recipients; the User must take this into account before granting access.

5.4. Hosting, push notification delivery, maps and geocoding, communications, payments, support, and diagnostics services may be engaged for operation. Actual entities, data categories, and purposes for each recipient: —. Transfers must be necessary and properly documented in accordance with the law.

5.5. Data is transferred to authorized government bodies where there is a lawful ground and to the extent provided for by law. A request from an outside person does not, by itself, provide grounds to disclose family data to them.

5.6. Information about actual or planned cross-border transfers: —. If such transfers take place, the procedures and restrictions provided for by law are observed. This Policy does not replace the required notifications and checks.

6 Retention periods and deletion

6.1. Data is retained for no longer than necessary for the stated purpose, unless a different period is established by law or an applicable contractual ground. The absence of a period in a particular form does not give a right to retain data indefinitely.

6.2. Retention periods by category: account and family links - —; geolocation and routes - —; messages and attachments - —; audio recordings, photos, videos, and screen recordings - —; SOS events and family statuses - —; technical logs and requests - —; payments and evidence of confirmations - —.

6.3. The User is provided with an accessible way to delete data or submit a request. Data that remains subject to an independent statutory retention obligation may be retained to the necessary extent for that period; it must not continue to be used for incompatible purposes.

6.4. Procedure for deletion from operational systems and backups, including backup update periods: —. Backups are not used as grounds to retain deleted data indefinitely.

6.5. Cancelling a subscription, uninstalling the application, deleting an account, and withdrawing consent have different consequences. Cancelling a subscription is not the same as deleting an account. When an account is deleted, the data deletion rules apply, while payment obligations and refunds are handled under the Public Offer and the law.

7 Rights and procedure for requests

7.1. The data subject or their duly authorized representative has the right to obtain information about processing, request rectification, blocking, or destruction of data where grounds exist, withdraw consent, request the cessation of processing in cases provided for by law, and challenge the Operator’s actions.

7.2. Requests may be submitted through the available section of the application, to familyguard.notify@gmail.com. Necessary information may be required to associate the request with an account. The extent of identity and authority verification must be proportionate to the request.

7.3. Requests are considered and the necessary actions are taken within the time limits established by the applicable legal rules. The general support response time does not replace the specific time limits for personal data matters.

7.4. Refusing or withdrawing optional consent does not automatically end processing if another independent lawful ground remains for the specific data. The Operator explains material consequences for features and does not replace a missing ground with a general reference to a contract.

7.5. A complaint may be submitted to Roskomnadzor or a court in accordance with the procedure established by law. Contacting the Operator does not limit this right.

8 Data protection

8.1. The Operator takes the organizational and technical measures required by law: access controls, protection of account credentials, management of employee and contractor access, logging of necessary security events, prevention of unauthorized access, and incident response.

8.2. Information about measures actually applied that can be disclosed without compromising security: —. Statements about the encryption used and access to recordings must reflect the actual architecture.

8.3. In the event of an incident, the Operator establishes the circumstances, takes measures to address the consequences, and fulfills the notification obligations provided for by law. The User may report a suspected data leak or account takeover to familyguard.notify@gmail.com.

9 Website and cookies

9.1. If the FamilyGuard website uses cookies or similar tools, visitors are informed of their purpose, categories, providers, and retention periods: —.

9.2. Tools necessary for the website to operate are distinguished from optional analytics or advertising tools. Choice settings and any necessary consent must reflect actual use and applicable law. Continuing to browse the website is not, by itself, declared to be universal consent to all tracking tools.

9.3. A separate cookie document describes the website and does not replace disclosure of SDKs, identifiers, and analytics within the application.

10 Changes and contacts

10.1. The current Policy is published in the “Legal information” section and is available from the application before processing begins. Material changes are communicated before they take effect. If a change requires new consent, publishing the text does not replace obtaining that consent.

10.2. Operator: Nikolenko Evgeniya Alekseevna, self-employed (professional income tax payer). INN (taxpayer identification number): 900202950465.

10.3. Location: Russian Federation, Krasnodar Krai, Krasnodar. Electronic requests: familyguard.notify@gmail.com. Data and security contact: familyguard.notify@gmail.com. Support: familyguard.notify@gmail.com.

10.4. Related documents: User Agreement - “Legal information” section; Public Offer - “Legal information” section; separate consent - “Legal information” section.

14 Public website statistics

14.1. The website counts aggregate page views and APK-link clicks without a persistent browser identifier, analytics cookies or saving identifiers in browser storage. Do Not Track and Global Privacy Control disable this measurement. Local identifiers and analytics preferences from the previous version are removed when the updated site loads.

14.2. Aggregate statistics include the date in Moscow time, a page path without query parameters or fragments, a referral-source category, device type and page language. Full referral URLs, search terms, names, email addresses and IP addresses are not written to the analytics database. Separate visits are not linked to recognize a returning browser.

14.3. Each event has its own random key to prevent duplicate delivery. This key is not saved in the browser or reused by other events. Its hash is stored on the server without user history and removed by scheduled cleanup after seven days have elapsed. Aggregate daily totals remain for trend analysis. Hosting infrastructure may separately process technical network information to deliver and protect the site.

14.4. Reports are visible only to the product owner in the authenticated Admin app. Unique visitors, repeat visits and conversion by unique visitors are not determined. Referral sources count individual incoming page views; internal navigation is not counted as a new external source. A Download click does not confirm a completed download or installation.

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