Privacy Notice for Parents — Wondimo
Last updated: [DATE]
This notice explains in plain language what data we process when your child uses Wondimo, why we process it, where it is stored and how you stay in control. There is also a version for children ([link]) you can read together.
At a glance
- Only you have an account. Your children use profiles inside your account: a nickname, an avatar picked from a list, and their school year or age band. We do not ask for a child's date of birth, surname, photo, email or phone number.
- No ads, no trackers, no selling of data. We only use the technical cookies the service needs to work.
- You can read every chat your child has with the AI assistant. Chats are automatically deleted after 90 days, and you can delete them sooner.
- Voice is not recorded or kept. We use it only to turn speech into text, then delete it straight away.
- Data stays in Europe (servers in Frankfurt). [⚠️ DA VERIFICARE: true only with the OpenRouter EU endpoint or the direct Mistral API; some providers are US companies, see section 7]
- We do not use your family's data to train AI.
1. Who is responsible for your data (controller)
Mirco Cervi, [address], Italy. Email: [EMAIL PRIVACY]. [⚠️ DA VERIFICARE: update if the service moves to a company; add the DPO if one is appointed; add UK/Swiss representatives if appointed.]
2. What data we process and why
| What | Examples | Why | Legal basis (GDPR / UK GDPR) |
|---|---|---|---|
| Your account | Email; if you sign in with Google or Apple, your account identifier; language; parent-area PIN (stored only as an irreversible hash) | Let you sign in and protect the parent area | Performance of a contract (Art. 6(1)(b)) |
| Your consent record | Date, time and version of the notice you accepted | Prove that consent was given | Legal obligation / proof (Art. 7(1)) |
| Your child's profile | Nickname, avatar, school year or age band, chosen mascot, your settings | Tailor games and the assistant to your child's age | Your consent as parent (Art. 6(1)(a) and Art. 8; in Italy also Art. 2-quinquies Privacy Code and Art. 4 Law 132/2025 on under-14s accessing AI) and contract |
| Games and progress | Games played, levels, scores, play time | Let your child play, show you progress, suggest the next level | Contract |
| Chats with the AI assistant | Your child's questions and the assistant's answers | Give age-appropriate answers and let you see the conversations | Your consent + contract |
| Voice (if enabled) | Recording of a spoken question | Turn it into text. Not stored | Your consent + contract |
| Safety alerts | Alert type (e.g. "possible bullying") and an excerpt of the conversation | Protect your child and tell you straight away | Contract and our legitimate interest in protecting the child (Art. 6(1)(f)); in the most serious cases, vital interests (Art. 6(1)(d)) |
| Usage statistics | Usage events with a pseudonymous code, age band, country, device type. Never chat text | Understand how to improve the service | Legitimate interest (Art. 6(1)(f)); you can object |
| Technical security data | IP address, browser type, error logs | Security and abuse prevention | Legitimate interest (Art. 6(1)(f)) |
Sensitive information. A child may spontaneously write or say things about health, family or other sensitive topics. We never ask for this, and the assistant encourages children not to share personal information. When it happens, we use that information only to respond safely and to alert you, based on the explicit consent you give when you turn on the assistant (Art. 9(2)(a)). [⚠️ DA VERIFICARE legal basis]
3. How the AI assistant works
- It is a computer program, not a person, and it always says so to your child.
- It runs on open-weight language models from Mistral AI (a French company), with safety rules tailored to each age band.
- By default it guides your child to reason things out instead of giving the answer straight away. You can make it more direct.
- Every message, in and out, goes through automatic moderation.
- It can make mistakes. We teach it to say "let's check with a grown-up".
- It does not make decisions about your child. Game levels are suggestions for you only.
- Our AI providers run in zero data retention mode: they process the request and keep neither the text nor the voice.
4. Sensitive topics and alerts
If your child brings up topics such as bullying, abuse, self-harm or danger, the assistant will:
- reply gently and encourage your child to talk straight away with a trusted adult (you, a teacher or another grown-up), and give a free children's helpline (e.g. Childline 0800 1111 in the UK, 147 in Switzerland, 19696 in Italy) [⚠️ DA VERIFICARE numbers];
- not go into the topic in depth;
- alert you straight away in the parent area, and send an email with no sensitive details in it.
We do not report anything to third parties automatically. [⚠️ DA VERIFICARE procedure for illegal content]
5. Who can see the data
- You, in the PIN-protected parent area.
- Our service providers, who process data on our behalf under contracts that require them to protect it (Art. 28 GDPR):
| Provider | Role | Location |
|---|---|---|
| Vercel Inc. | Hosts the app | EU servers (Frankfurt); US company certified under the EU-U.S. Data Privacy Framework |
| Supabase Inc. | Database and account sign-in | EU servers (Frankfurt); US company, transfers covered by Standard Contractual Clauses |
| OpenRouter Inc. | Routes requests to the AI model | [⚠️ DA VERIFICARE: EU endpoint; US company; Standard Contractual Clauses] |
| Mistral AI SAS | AI models, speech-to-text, moderation | EU (France) |
| [Email provider] | Sends sign-in emails and alerts | [⚠️ DA DECIDERE] |
- Google or Apple, if you choose to sign in with them. They act as independent controllers for your Google/Apple account data.
- Public authorities, only where the law requires it.
We do not sell data, do not share it with advertisers and do not use third-party analytics or advertising tools.
6. How long we keep data
| Data | Retention |
|---|---|
| Voice | Not stored |
| Chats and alerts | 90 days, then deleted automatically |
| Detailed progress | 13 months, then only a summary [⚠️ DA VERIFICARE] |
| Profile and account | Until you delete them; after 24 months of inactivity we warn you and then delete [⚠️ DA VERIFICARE] |
| Consent record | Life of the account + 5 years [⚠️ DA VERIFICARE] |
| Technical logs | About 30 days [⚠️ DA VERIFICARE] |
| Backups | Deleted data also disappears from backups within [7] days [⚠️ DA VERIFICARE] |
7. Where data is stored and international transfers
Data is stored on servers in the European Union (Frankfurt, Germany). Some providers are US companies. Where data may be accessed from or transferred to the US, we rely on the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) for certified providers, or on Standard Contractual Clauses approved by the European Commission (with the UK Addendum and the Swiss adaptations). You can ask for a copy of these safeguards at [EMAIL PRIVACY]. [⚠️ DA VERIFICARE DPF status of each provider at publication date]
8. Your rights (and your child's)
For yourself and your child, you can:
- see all the data (parent area) and download it (portability);
- correct it;
- delete a conversation, a profile or the whole account, directly in the parent area;
- withdraw consent at any time (the AI assistant is then switched off for that profile);
- object to usage statistics;
- restrict processing;
- complain to a supervisory authority: the Italian Garante (www.garanteprivacy.it), the authority in your EU country, the UK ICO (ico.org.uk) or the Swiss FDPIC (edoeb.admin.ch).
We reply within one month. Write to [EMAIL PRIVACY] from your account email address.
Separated parents or shared parental responsibility: the other parent can exercise these rights by showing they hold parental responsibility. [⚠️ DA VERIFICARE procedure]
9. Security
We use encryption in transit and at rest, strict separation between families, a PIN for the parent area, multi-factor authentication for administration, and safety testing of the AI assistant before every release. No system is 100% secure. If something happens that puts your child's data at risk, we will tell you.
10. Cookies
We only use technical cookies and browser storage, needed to keep you signed in and to remember language and active profile. No profiling or third-party analytics cookies, so there is no consent banner.
11. Age and who can use the service
An account can only be created by an adult who holds parental responsibility (or guardianship) for the child. The service is designed for children from pre-school to the end of primary school (around age 11) [⚠️ DA VERIFICARE whether up to 13]. The service is not currently offered in the United States.
12. Changes
If we change anything important, we will tell you by email and in the parent area, and ask for your consent again where needed.