Privacy Policy, COPPA Compliance & Terms of Service

1. Privacy Policy

1.1 Introduction and Scope

This Privacy Policy ("Policy") describes how ArtEcho ("we," "us," "our," or the "Company") collects, uses, stores, and protects information in connection with the ArtEcho mobile application (the "App"). This Policy applies to all users of the App, including parents, legal guardians, and caregivers ("Users" or "you") who use the App in connection with their children ages 3 through 13 and older ("Children").

ArtEcho is an AI-powered art analysis application designed to help parents and caregivers understand their Children's emotional expressions through artwork. The App provides supportive emotional insights based on drawings and is not intended to serve as a clinical diagnostic tool, a substitute for professional mental health services, or medical advice of any kind.

1.2 Information We Collect

ArtEcho is designed to minimize data collection. We categorize the limited information associated with App usage as follows:

1.2.1 Information You Voluntarily Provide

Data Type	Purpose	Storage Location
Display Name	Personalizing the App interface	Device only (encrypted)
Email Address (optional)	Account identification	Device only (encrypted)
Child's Age Range	Developmentally appropriate AI analysis	Device only
Drawings / Uploaded Images	AI emotional analysis	Device only
Drawing Titles	Gallery organization	Device only

1.2.2 Information Generated by the App

Data Type	Purpose	Storage Location
Analysis Results (mood, confidence, description)	Providing emotional insights to parents	Device only
AI-Generated Discussion Questions	Facilitating parent-child dialogue	Device only
Consent Preferences (parental lock, analytics)	COPPA compliance and privacy controls	Device only

1.2.3 Information Transmitted for AI Processing

When you submit a drawing for analysis, the image is transmitted to third-party AI service providers (currently OpenRouter and Google Gemini) for processing. This transmission is necessary to provide the core analysis functionality. Important details about this transmission:

• Images are sent as base64-encoded data over encrypted HTTPS connections.
• No personally identifiable information (name, email, or device identifiers) is transmitted alongside the image.
• The only contextual information sent with the image is the selected age range (e.g., "5-6 years") to enable developmentally appropriate analysis.
• Images are processed in real-time and are not stored by our AI service providers beyond the duration required to complete the analysis request, as governed by their respective data processing agreements.
• All user text inputs (drawing titles, chat messages) are sanitized before transmission to prevent prompt injection attacks.

1.2.4 Information We Do NOT Collect

ArtEcho does not collect, store, or transmit:

• Children's real names, addresses, phone numbers, or Social Security numbers
• Precise geolocation data
• Contact lists, call logs, or SMS content
• Photographs of Children (the App validates that submitted images are hand-drawn artwork, not photographs)
• Browsing history or cross-app tracking data
• Biometric data (fingerprints, facial recognition, voice prints)
• Device identifiers for advertising or tracking purposes
• Passwords (the App does not use password-based authentication)

1.3 How We Use Information

The limited information associated with App usage is used exclusively for the following purposes:

1. Providing Core App Functionality: Analyzing drawings to generate emotional insights, mood detection, and age-appropriate discussion questions.
2. Personalizing the User Experience: Displaying your chosen display name and adjusting analysis frameworks to the selected child age range.
3. Managing Subscriptions: Processing in-app purchases through Apple App Store and Google Play Store payment systems (managed by RevenueCat).
4. Maintaining Privacy Preferences: Honoring your consent choices regarding data sharing and analytics.

We do not use any information for behavioral advertising, user profiling, sale to third parties, or any purpose beyond the direct functionality of the App.

1.4 Third-Party Service Providers

ArtEcho integrates with the following third-party services, each for a specific, limited purpose:

Service Provider	Purpose	Data Shared
OpenRouter	Primary AI drawing analysis	Drawing image (base64), child age range
Google Gemini	Fallback AI drawing analysis	Drawing image (base64), child age range
RevenueCat	Subscription and purchase management	Anonymous purchase tokens (no personal data)
Apple App Store / Google Play	App distribution and payment processing	Per platform terms of service

We do not share personal information with any advertising networks, data brokers, analytics platforms, or social media companies.

1.5 Data Security

We implement the following security measures to protect information stored on your device:

• Encrypted Storage: Sensitive user profile data (display name, email) is stored using platform-native encrypted storage mechanisms: iOS Keychain on Apple devices and EncryptedSharedPreferences (Android Keystore) on Android devices.
• Transport Encryption: All network communications with AI service providers use TLS 1.2 or higher encryption.
• Input Sanitization: All user-provided text inputs are sanitized to prevent injection attacks before being processed or transmitted.
• Log Redaction: In production builds, the App's logging system automatically redacts API keys, bearer tokens, and other sensitive strings from log output.
• No Remote Storage: Because all data remains on-device, there is no centralized database that could be targeted in a data breach.

2. COPPA Compliance Statement

2.1 Compliance with the Children's Online Privacy Protection Act

ArtEcho is committed to compliance with the Children's Online Privacy Protection Act of 1998 ("COPPA"), 15 U.S.C. §§ 6501-6506, and its implementing regulations at 16 C.F.R. Part 312, as amended (the "COPPA Rule"). We recognize the importance of protecting the privacy of children under 13 years of age and have designed the App with the following COPPA principles:

2.2 Parental Consent

ArtEcho requires verifiable parental consent before any information related to a Child is processed within the App. Our consent mechanism includes:

• Account Creation Gate: During initial App setup, the parent or guardian must affirmatively acknowledge that they are the parent or legal guardian of the child whose artwork will be analyzed, and that they consent to the App's data practices as described in this Policy.
• Consent Persistence: Consent preferences are stored locally on the device and can be reviewed and modified at any time through the App's Privacy Center (Settings > Privacy).
• Consent Revocation: Parents may revoke consent at any time by disabling the relevant consent toggles in the Privacy Center or by deleting all App data.

2.3 Limited Collection Principle

In accordance with COPPA's requirement that operators collect only the personal information reasonably necessary for the child's participation in the activity, ArtEcho:

• Collects only the Child's age range (not exact date of birth) for the sole purpose of providing developmentally appropriate analysis.
• Does not condition a Child's participation on the disclosure of more personal information than is reasonably necessary.
• Does not collect any direct identifiers of the Child (name, address, phone number, email, Social Security number, or other government-issued identifier).

2.4 No Disclosure to Third Parties

ArtEcho does not disclose Children's personal information to third parties, except as follows:

• Drawing images are transmitted to AI service providers (OpenRouter, Google Gemini) solely for the purpose of performing the requested analysis. These transmissions do not include any personally identifiable information about the Child.
• We do not make Children's personal information publicly available through any feature of the App (e.g., chat rooms, forums, profiles).

2.5 Parental Rights Under COPPA

As the parent or legal guardian, you have the following rights under COPPA at all times:

1. Right to Review: You may review all information associated with your Child's use of the App at any time through the App's Privacy Center and Gallery.
2. Right to Deletion: You may delete any individual drawing analysis or all App data at any time. The App provides one-tap deletion functionality in the Privacy Center.
3. Right to Refuse Further Collection: You may revoke consent for further data collection at any time by modifying consent settings or uninstalling the App. Because all data is stored locally, uninstalling the App permanently removes all data.
4. Right to Data Export: You may export all stored data in a machine-readable JSON format through the Privacy Center.
5. Right to Contact Us: You may contact us at any time with questions or concerns regarding our privacy practices at privacy@artecho.app.

2.6 Data Retention and Deletion

All data associated with the App is stored locally on the User's device and is retained until the User takes one of the following actions:

• Deletes individual analysis entries through the Gallery or Privacy Center.
• Uses the "Delete All Data" function in the Privacy Center.
• Uninstalls the App from the device.

We do not retain any user data on remote servers. There is no data to delete on our end because we never receive or store it.

3. Detailed Data Practices

3.1 Local-First Architecture

ArtEcho employs a local-first data architecture, meaning:

• All user-generated content (drawings, analysis results, profile information) is stored exclusively on the user's device using platform-native storage APIs.
• No cloud accounts are created, and no data synchronization occurs between devices.
• The App functions fully offline for reviewing previously analyzed drawings and their results.
• An active internet connection is required only at the moment of submitting a new drawing for AI analysis.

3.2 Drawing Validation and Safety

ArtEcho implements a two-stage validation system to ensure that only genuine hand-drawn artwork is processed:

• Primary Validation: The AI performs an initial classification to determine whether the submitted image is a hand-drawn artwork, a photograph, a screenshot, or a digitally generated graphic.
• Rejection Policy: The App rejects photographs (including photographs of people), screenshots, and computer-generated graphics. Only hand-drawn artwork proceeds to emotional analysis.
• This validation serves as a safeguard to prevent the processing of photographs of Children or other individuals through the App.

3.3 AI Processing Transparency

When a drawing is submitted for analysis, the following process occurs:

1. The image is converted to base64 format on-device.
2. The base64 image and selected age range are transmitted via HTTPS to the AI service provider.
3. The AI provider processes the image in real-time and returns a structured analysis.
4. The analysis result is stored locally on the device.
5. The transmitted image is not retained by the AI service provider beyond the processing window.

The AI analysis framework examines the following artistic dimensions: color psychology (warm/cool tones, intensity, palette choices), spatial composition (placement, sizing, relationships between elements), line quality and pressure (motor control indicators, emotional expression through stroke), symbolic content (age-appropriate symbolic expression), and developmental context (age-appropriate milestone assessment).

3.4 Subscription and Payment Data

ArtEcho offers optional premium subscriptions managed through RevenueCat, Apple App Store, and Google Play Store:

• Payment processing is handled entirely by Apple and Google. ArtEcho does not receive, process, or store credit card numbers, bank account details, or other financial information.
• RevenueCat receives anonymous purchase tokens to manage subscription state. No personal information is shared with RevenueCat.
• Subscription status is determined by querying the platform's purchase APIs and does not require user accounts on our servers.

3.5 Cookies and Tracking Technologies

ArtEcho does not use cookies, web beacons, pixel tags, device fingerprinting, or any other tracking technologies. The App does not contain any advertising SDKs, analytics SDKs (unless the user has affirmatively opted in via the Privacy Center), or social media integration that could enable cross-app or cross-site tracking.

4. Terms of Service

4.1 Acceptance of Terms

By downloading, installing, or using ArtEcho, you agree to be bound by these Terms of Service ("Terms"). If you do not agree to these Terms, do not use the App. These Terms constitute a legally binding agreement between you and ArtEcho.

4.2 Eligibility

The App is intended for use by adults age 18 and older who are the parent, legal guardian, or authorized caregiver of a Child. By using the App, you represent and warrant that you are at least 18 years of age and that you have the legal authority to consent to the App's data practices on behalf of the Child whose artwork is being analyzed.

4.3 Intended Use and Limitations

• ArtEcho provides supportive insights, not clinical assessments. The App's analysis is generated by AI models and may not accurately reflect the Child's actual emotional state.
• Mood confidence scores reflect the AI's estimation and should be interpreted as general indicators, not definitive assessments.
• The discussion questions generated by the App are conversation aids and should be adapted to the specific context and needs of the Child.
• Users should exercise independent judgment and parental discretion when interpreting and acting on analysis results.

4.4 Subscription Terms

• Free Tier: All users receive 3 free drawing analyses per session.
• Premium Subscription: Unlimited analyses are available through a paid subscription with monthly, quarterly, or annual billing options.
• Subscriptions are processed and managed by the Apple App Store or Google Play Store. Billing, renewal, and cancellation are governed by the respective platform's terms.
• You may cancel your subscription at any time through the App Store or Google Play Store settings. Cancellation takes effect at the end of the current billing period.
• We do not offer refunds directly. Refund requests must be submitted through Apple or Google's standard refund processes.

4.5 Intellectual Property

• The ArtEcho App, including its design, code, AI prompts, branding, and documentation, is the property of ArtEcho and is protected by applicable intellectual property laws.
• Your Content: You retain all ownership rights to drawings and images you upload or create within the App. By using the App's analysis feature, you grant us a limited, temporary license to transmit the image to our AI service providers solely for the purpose of performing the requested analysis.
• AI-generated analysis results, mood descriptions, and discussion questions provided by the App are licensed to you for personal, non-commercial use.

4.6 Prohibited Conduct

You agree not to:

• Use the App for any unlawful purpose or in violation of these Terms.
• Submit images that are not hand-drawn artwork (photographs, screenshots, or inappropriate content).
• Attempt to reverse-engineer, decompile, or disassemble the App.
• Attempt to circumvent the App's input sanitization, validation, or security measures.
• Use the App to generate, store, or transmit malicious content or prompt injection attacks.
• Represent the App's analysis results as professional medical, psychological, or therapeutic advice.
• Use the App in a manner that could harm, exploit, or endanger a Child.

4.7 Disclaimer of Warranties

THE APP IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, COMPLETENESS, OR NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE APP WILL BE UNINTERRUPTED, ERROR-FREE, OR FREE OF HARMFUL COMPONENTS. AI-GENERATED ANALYSIS RESULTS ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY AND ARE NOT GUARANTEED TO BE ACCURATE OR COMPLETE.

4.8 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL ARTECHO, ITS OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING WITHOUT LIMITATION, LOSS OF PROFITS, DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES, RESULTING FROM (A) YOUR USE OR INABILITY TO USE THE APP; (B) ANY ANALYSIS RESULTS OR INSIGHTS PROVIDED BY THE APP; (C) ANY DECISIONS MADE OR ACTIONS TAKEN BASED ON THE APP'S OUTPUT; OR (D) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR DATA. OUR TOTAL LIABILITY SHALL NOT EXCEED THE AMOUNT YOU HAVE PAID FOR THE APP IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM.

4.9 Indemnification

You agree to indemnify, defend, and hold harmless ArtEcho and its officers, directors, employees, and agents from and against any claims, damages, obligations, losses, liabilities, costs, or debt arising from: (a) your use of the App; (b) your violation of these Terms; (c) your violation of any third-party right, including any intellectual property or privacy right; or (d) any claim that your use of the App caused damage to a third party.

4.10 Governing Law and Dispute Resolution

These Terms shall be governed by and construed in accordance with the laws of the State of Delaware, United States, without regard to its conflict of law provisions. Any dispute arising under these Terms shall be resolved through binding arbitration administered by the American Arbitration Association in accordance with its Commercial Arbitration Rules, except that either party may seek injunctive relief in any court of competent jurisdiction.

5. Your Data Rights

5.1 Rights for All Users

Regardless of your jurisdiction, ArtEcho provides the following data rights to all users as a matter of principle:

• Right of Access: View all stored data at any time through the App's Privacy Center and Gallery.
• Right to Portability: Export all data in JSON format via the Privacy Center's "Export Data" function.
• Right to Deletion: Delete individual analysis entries or all data via one-tap deletion in the Privacy Center.
• Right to Consent Management: Modify data sharing and analytics consent at any time through Privacy Center toggles.
• Right to Information: This Policy provides complete transparency about our data practices.

5.2 Additional Rights Under GDPR (European Economic Area)

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR), including the right to restriction of processing, the right to object to processing, and the right to lodge a complaint with a supervisory authority. Because ArtEcho stores all data locally on your device and does not maintain remote databases of personal information, you exercise these rights directly through the App's built-in controls.

5.3 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). ArtEcho does not sell personal information, does not share personal information for cross-context behavioral advertising, and does not use sensitive personal information for purposes other than those permitted under the CCPA/CPRA. You may exercise your California privacy rights through the App's Privacy Center.

5.4 International Users

ArtEcho is available internationally in 120+ countries. If you are located outside the United States, please note that drawing images are transmitted to AI service providers whose servers may be located in the United States or other jurisdictions. By using the App's analysis feature, you consent to this transfer. No personal information is transmitted alongside the image.

6. Changes to This Policy & Contact Information

6.1 Policy Updates

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. If we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this document.
• Provide notice through the App (e.g., an in-app notification or consent prompt).
• For material changes affecting Children's data, obtain renewed parental consent before implementing the changes.

6.2 Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy, COPPA compliance, or our data practices, please contact us:

6.3 Reporting Privacy Concerns

If you believe that ArtEcho has collected personal information from a Child without proper parental consent, or if you have any other privacy concern, please contact us immediately at privacy@artecho.app. We will investigate promptly and take appropriate corrective action.

You may also file a complaint with the Federal Trade Commission (FTC) at ftc.gov/complaint if you believe your COPPA rights have been violated.