Privacy Policy

Introduction

Phloe Inc. ("we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Phloe mobile application ("App").

This Privacy Policy is designed to comply with:

1. Apple App Store Privacy Requirements[2][9]

2. California Consumer Privacy Act (CCPA)

3. General Data Protection Regulation (GDPR)

4. Children's Online Privacy Protection Act (COPPA)[8][11]

5. Family Educational Rights and Privacy Act (FERPA)

By using Phloe, you consent to the data practices described in this policy.

Information We Collect

2.1 Information You Provide Directly

1. Account Information: Name, email address, date of birth, grade level, school (optional)

2. Profile Information: Username, profile picture (optional), learning preferences

3. Learning Data: Quiz responses, progress tracking, study habits, subject preferences

4. Communication Data: Support messages, feedback, survey responses

5. Payment Information: Processed through Apple App Store (we do not store credit card details)

2.2 Information Collected Automatically

1. Device Information: Device model, operating system version, unique device identifiers

2. Usage Data: Features accessed, time spent in app, session frequency, interaction patterns

3. Performance Data: Crash reports, error logs, app performance metrics

4. Location Data: General geographic location (city/state level only, if permitted)

2.3 Information from Third-Party Sources

1. Authentication Services: If you sign in with Apple ID, Google, or other providers

2. Analytics Providers: Aggregated usage statistics (anonymized)

3. Educational Content Partners: Subject matter accuracy verification

2.4 Children's Privacy (Under 13)

We do not knowingly collect personal information from children under 13 years of age. Phloe is designed for users aged 14 and older. If we discover that we have inadvertently collected information from a child under 13, we will delete that information immediately[8][11].

If you are a parent or guardian and believe your child under 13 has provided us with personal information, please contact us at privacy@phloe.app.

How We Use Your Information

We use collected information for the following purposes:

3.1 Core Educational Functions

1. Provide personalized learning experiences and content recommendations

2. Track learning progress and mastery of topics

3. Implement spaced repetition algorithms for optimal retention

4. Generate performance analytics and learning insights

5. Adapt question difficulty based on individual performance

3.2 App Functionality and Improvement

1. Operate, maintain, and improve the App's features

2. Develop new educational content and features

3. Analyze usage patterns to enhance user experience

4. Troubleshoot technical issues and bugs

5. Conduct research on learning effectiveness

3.3 Communication

1. Send important account and service notifications

2. Respond to your support requests and inquiries

3. Provide updates about new features or content

4. Send educational tips and study reminders (with your consent)

3.4 Security and Legal Compliance

1. Detect and prevent fraud, abuse, or security threats

2. Enforce our Terms of Service

3. Comply with legal obligations and respond to lawful requests

4. Protect the rights, property, and safety of Phloe, our users, and the public

Third-Party Data Sharing and AI Disclosure

We do not sell your personal information to third parties. We may share limited data with trusted service providers who help us operate the App:

4.1 Service Providers

1. Cloud Hosting: Data storage and server infrastructure (e.g., Vercel, GitHub)

2. Analytics: App performance and usage analytics (anonymized)

3. Customer Support: Help desk and communication tools

4. Payment Processing: Apple App Store for subscription management

4.2 Artificial Intelligence Services

Important Disclosure: Phloe may use third-party artificial intelligence systems to enhance learning experiences, including content generation, personalization, and adaptive learning features.

Before sharing any personal data with third-party AI services, we will:

1. Clearly disclose which AI services are being used

2. Explain what data will be shared and for what purpose

3. Obtain your explicit consent through an in-app permission request

4. Allow you to opt out of AI-powered features without losing core functionality

AI Service Providers We May Use:

1. Anthropic (Claude) for content generation and question analysis

2. OpenAI for educational content personalization (if implemented)

You can manage AI data sharing preferences in the App's privacy settings at any time[2][6][12].

4.3 Legal Requirements

We may disclose your information if required by law, court order, or governmental request, or to protect our legal rights.

4.4 Business Transfers

If Phloe is acquired or merged with another company, your information may be transferred as part of that transaction. We will notify you before your information is subject to a different privacy policy.

Data Retention

We retain your personal information only as long as necessary for the purposes outlined in this Privacy Policy:

1. Active Accounts: Data retained while your account is active

2. After Account Deletion: Most personal data deleted within 30 days; aggregated, anonymized learning data may be retained for research

3. Legal Requirements: Some data may be retained longer to comply with legal obligations

Backups: Deleted data may persist in backup systems for up to 90 days before permanent deletion

Your Privacy Rights and Choices

Depending on your location, you may have the following rights:

6.1 Access and Portability

1. Request a copy of the personal information we hold about you

2. Export your learning data in a portable format (CSV, JSON)

6.2 Correction and Updates

1. Update or correct your account information at any time through App settings

2. Request correction of inaccurate data

6.3 Deletion and Account Removal

1. Delete your account and associated personal data through the App settings

2. Request data deletion by contacting privacy@phloe.app

3. Receive confirmation of deletion within 30 days[9]

6.4 Consent Withdrawal

1. Withdraw consent for optional data collection (e.g., location, AI features)

2. Opt out of marketing communications

3. Disable specific tracking features in privacy settings

6.5 California Privacy Rights (CCPA)

California residents have additional rights:

1. Know what personal information is collected and how it's used

2. Request deletion of personal information

3. Opt out of sale of personal information (note: we do not sell data)

4. Non-discrimination for exercising privacy rights

6.6 European Privacy Rights (GDPR)

EU residents have additional rights:

1. Right to rectification, erasure, and restriction of processing

2. Right to data portability

3. Right to object to processing

4. Right to lodge a complaint with a supervisory authority

To exercise any of these rights, contact us at privacy@phloe.app.

Data Security

We implement industry-standard security measures to protect your information:

1. Encryption: Data encrypted in transit (TLS/SSL) and at rest (AES-256)

2. Access Controls: Strict employee access limitations on a need-to-know basis

3. Secure Authentication: Password hashing and secure token-based sessions

4. Regular Security Audits: Vulnerability assessments and penetration testing

5. Incident Response: Documented procedures for data breach notification

However, no method of transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

App Privacy Nutrition Labels

As required by Apple's App Store guidelines, we provide the following App Privacy Labels disclosure[2][4][9]:

Data Linked to You

1. Contact Information: Email address

2. User Content: Learning progress, quiz responses, study habits

3. Identifiers: User ID, device identifiers

4. Usage Data: Product interaction, app usage patterns

Data Not Linked to You

1. Diagnostics: Crash data, performance metrics

2. Usage Data: Aggregated analytics

Data Used to Track You

We do not use data to track you across apps and websites owned by other companies.

Cookies and Tracking Technologies

Phloe uses minimal tracking technologies:

1. Essential Cookies: Required for login sessions and core functionality

2. Analytics: Anonymized usage statistics (can be disabled in settings)

No Third-Party Advertising Trackers: We do not use ad networks or behavioral tracking

International Data Transfers

Phloe is based in the United States. If you access the App from outside the U.S., your information may be transferred to, stored, and processed in the United States.

For EU users, we rely on appropriate safeguards such as Standard Contractual Clauses when transferring data internationally.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes by:

1. Posting the updated policy in the App with a new "Last Updated" date

2. Sending an email notification to your registered email address

3. Displaying an in-app notification upon your next login

Material changes will take effect 30 days after notification. Continued use of the App after changes become effective constitutes acceptance of the updated Privacy Policy.

Contact Us

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

Phloe
Email: phloeorg@gmail.com
Support: phloeorg@gmail.com
Data Protection Officer: phloeorg@gmail.com

Mailing Address:
Phloe
3608 Page St.
Redwood City, CA 94063
United States

We will respond to privacy inquiries within 30 days.