Child Privacy and Parental Consent

1. Our principles

• No covert tracking. The app icon is never hidden on the child's device and a permanent notification is displayed. No feature exists, or will exist, to conceal that tracking is happening.
• Parents only. The app may be used only to locate a child in your care. Tracking adults without their consent is prohibited and is a breach of our Terms of Service.
• Minimal data. Only location and device status are collected. Messages, calls, contacts, camera, microphone and browser history are never accessed.
• No advertising. No child data is ever used for advertising, profiling or marketing, and it is never sold to third parties. The advertising measurement SDKs we use on the parent side (Meta and TikTok) are never initialised on the child's device; no advertising identifier is read from the child's device.
• Short retention. Location history is deleted automatically after 30 days.

2. How parental consent is obtained

The person creating an account must be 18 or older. No separate account is created for the child. The process is:

1. The parent creates an account on their own device and verifies their email address.
2. The parent declares that they are the child's parent or legal guardian and accepts the consent statement. The consent record is stored together with the accepted policy version.
3. Pairing is performed while the child's device is physically in the parent's hands — remote or unnoticed installation is not possible.
4. Protection mode is activated on the child's device and a notification that cannot be dismissed appears: *“FamSinyal protection mode is on — your location is shared with your family.”*

A child's data is visible only to the active parent members of the same family. Parents do not see each other's location.

Under GDPR Art. 8, processing a child's personal data on the basis of consent requires the authorisation of the holder of parental responsibility. Under Turkish law the same requirement follows from KVKK.

3. The child's rights

Data protection law does not exclude children from being data subjects. Children who are old enough to understand have the right to be informed about their own data. For that reason:

• A notification that cannot be dismissed runs on the child's device while protection is active.
• The child can see, from within the app on their device, which data is being shared.
• The child can always see in the app which family the device is linked to.
• Nothing in the app prevents the child from withdrawing the location permission in their device settings.

We adopted these principles to keep the balance between a child's safety and their privacy. Our recommendation to families is to start by talking to the child openly about it.

4. This is not stalkerware

FamSinyal is built in line with Google Play's and Apple's policies on unauthorised monitoring. The app:

• Cannot hide its icon or change its name
• Cannot run invisibly in the background
• Does not record message, call or chat content
• Does not capture ambient audio or record the screen
• Is not marketed for monitoring adults

Any attempt to circumvent these restrictions is a breach of the Terms of Service and results in the account being closed.

5. Age limits

The app is not marketed to children and its store audience is adults. Installation on a child's device is possible only with the parent's pairing code; a child cannot register or create an account independently.

6. Deleting a child's data

When you remove a child device from your account, that device's location history and activity data are permanently deleted within 30 days at the latest. To delete the whole account, use the account and data deletion page.

7. Contact

Send questions, concerns or reports about child privacy to kvkk@hulaguhanlabs.com.tr. We treat reports of misuse of the app as a priority. General support: destek@hulaguhanlabs.com.tr.