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Privacy Policy

Version 2.3 · Last updated: 2026-06-12

This Privacy Policy describes how Punn ("we", "us", or "our") collects, uses, shares, and protects personal information when you use the Punn mobile application ("App"). It is written to comply with the U.S. Children's Online Privacy Protection Act (COPPA, 16 CFR Part 312), the European Union General Data Protection Regulation (GDPR), the United Kingdom GDPR, and the Personal Data Protection Act B.E. 2562 (PDPA) of Thailand.

Punn is directed at parents and legal guardians, not at children. The personal information described in this policy is about a child but is collected from and controlled by the parent or guardian who uses the App. We treat all baby data as personal information of a child under 3 and apply COPPA-grade protections to it regardless of the parent's country of residence.

1. Operator / Data Controller

For the purposes of COPPA, the App operator is:

  • Legal entity: Attention AI (Thailand)
  • Mailing address: 195/69 Chaiyapruk Petchkasem 69, Nong Khaem, Bangkok 10160, Thailand
  • Telephone: +66 93-393-9955
  • Email: admin@punnbaby.app

For the purposes of GDPR, UK GDPR, and Thai PDPA, the same entity acts as the data controller of the personal information collected through the App. For privacy requests, please email us with the subject line "Privacy Request".

2. Categories of Personal Information We Collect

a. Parent account data

When you create an account, we collect your email address, display name, and a Firebase-issued user ID. If you choose to sign in with Apple or Google, we receive only the information you authorize the provider to share (typically email and name). Authentication is provided by Google's Firebase Authentication service.

b. Baby profile

You provide your baby's name, date of birth, gender, and optionally a profile photo. This data personalizes age-appropriate features such as feeding ranges, sleep guidance, and developmental milestones.

c. Photos of your child

You may upload photos to the in-app family photo feed and to your baby's profile. Photos are stored in Google Firebase Storage. They are visible only to you and to adult family members you have explicitly invited.

d. Chat messages

When you use the "Ask Punn" assistant, your text prompt and a structured context payload describing your baby are sent to our chat endpoint, which forwards them to OpenAI to generate the reply (see section 4.b). Our server does not store your messages or the context payload; it records technical metadata about each request (timestamp, token counts, latency, request status, your user ID, and a hashed IP address). Your chat history — the 200 most-recent messages per baby — is kept on your device only; older messages are pruned automatically.

e. Health events

You may record temperatures, medications and dosages, vaccines, doctor names, symptom descriptions, and free-text notes. Health data is treated as a special category under GDPR Article 9 and is collected only with your explicit consent (signified by your act of entering it into the corresponding tracking form).

f. Growth measurements

You may record weight, height (length), and head circumference. We compare these to WHO Child Growth Standards for charts and reports.

g. Daily tracking

You may log feeding sessions (including type, amount, duration, content, and food name for solids), sleep periods, diaper changes (including color, consistency, amount, and rash flag), pumping sessions, milk inventory entries, and developmental milestones. All of these fields may include free-text notes.

h. Cry analysis results

When you use the cry analysis feature, audio is recorded on your device and analyzed entirely on-device using a bundled ONNX machine-learning model. Only the resulting classification (for example, "hungry"), the confidence score, and an optional audio-quality warning flag are stored. The raw audio recording is not uploaded to our servers. The cry audio is analyzed in memory and is never uploaded as part of cry analysis. The only way a recording ever leaves your device is the opt-in anonymous donation described in section 2.m, which you control per recording.

i. Family sharing membership

If you invite a partner or family member, we store the family group, member roles, and share-link metadata in Firestore. Family members are adults; we do not invite children to the family share.

j. Optional feedback on cry results

If you correct a cry-analysis result, Punn can send anonymous feedback to help improve the model. This is off by default and is controlled by an opt-in toggle in Settings → Privacy; nothing is sent unless you turn it on, and you can turn it off again at any time. When enabled, Punn uploads only metadata — Punn's prediction, your correction, and your baby's age as a coarse bucket (one of 0–3, 3–6, 6–12, 12–24, or 24–36 months). The exact age, your baby's gender, and any identifying information are not included, and no audio is uploaded through feedback. Audio is shared only through the separate, per-recording donation described in section 2.m.

k. Diagnostic data

Crash reports and non-fatal error reports are sent to Firebase Crashlytics. These contain stack traces, device model, OS version, and app version. They are configured to exclude user content and baby data. Crash reporting is disabled in debug builds.

l. Subscription data

If you subscribe to Punn+, RevenueCat (acting as our subscription processor) receives a pseudonymous app user identifier, the purchased product, the entitlement status, and metadata about the purchase. Apple and Google Play process the actual payment; we never receive your full payment-card details.

m. Anonymous cry audio donation (opt-in)

Punn's cry analysis runs entirely on your device. Separately, you can choose to donate individual cry recordings to help improve the model. This is opt-in: nothing is ever shared unless you choose it, and you can turn sharing off at any time.

In Settings → Privacy you can set one of three modes:

  • Always ask (the default) — Punn asks on each recording, one recording at a time, and nothing is shared unless you actively choose to share that recording.
  • Auto-share — once enabled, corrections you make are shared automatically without a separate prompt each time. Turning this mode on is a deliberate, one-time choice: before it takes effect we show you the same disclosure as the per-recording prompt — including that a shared recording is anonymous and cannot be retrieved or deleted afterwards — and we run the medical-complexity screening below for each baby that has not yet been screened. A baby excluded for medical complexity is never auto-shared.
  • Never — sharing is fully off. You can switch to "Never" at any time to stop all future sharing.

What is collected when you share a single recording:

  • The roughly 7-second audio recording of your baby's cry.
  • Punn's predicted category for that cry (for example, "hungry").
  • Your correction, if you provided one.
  • Your baby's age as a coarse bucket only — one of 0–3 months, 3–6 months, 6–12 months, 12–24 months, or 24–36 months. The exact age is never included.

What is never collected or sent:

  • Your account, your name, or your baby's name.
  • Your baby's exact age or date of birth.
  • Your location or your device identifier.

During the roughly 7-second capture the audio is processed on your device and is held in memory; the recording may pass through a temporary file on your device for that brief window, which is deleted immediately after processing. Nothing leaves your device unless you choose to share that recording. When you consent to share, the recording is saved in a protected delivery queue on your device until it finishes uploading (at most 14 days), then removed. The donation is unlinkable by design: it is not tied to your account, name, or device identifier.

Medical-complexity exclusion: A per-baby setting in Settings → Privacy lets you exclude any baby under specialist or NICU care from donation entirely. When excluded, none of that baby's recordings can be shared, even if you change the mode above.

Where it goes and how long we keep it: Donated recordings are processed and stored on Google Cloud servers in the European Union (Belgium, europe-west1), in a dedicated storage location used only for this purpose. They are kept for up to 90 days and then permanently and automatically deleted. They are used only to retrain Punn's cry-classification model. They are not sold and are not shared with advertisers.

Alongside each recording we keep a small anonymous catalogue record (a random file identifier pointing to the stored audio, the predicted cry category, any correction you provided, a coarse age bracket, the audio format, and the month it was received — no account, device, or network identifiers). This catalogue record is stored in our database in the United States; the audio itself never leaves the European Union.

Legal basis and withdrawal: Because your baby's voice is a special category of personal data, we collect donated recordings on the basis of your explicit parental consent under GDPR Article 9(2)(a), given on your child's behalf. The data is anonymized at the point of collection. To withdraw, set the mode in Settings → Privacy to "Never"; this stops all future sharing. Recordings you have already donated are fully anonymous and cannot be retrieved or deleted on request; they are automatically and permanently deleted within 90 days of donation.

3. Recipients (Processors) and Where Your Data Goes

We use the following service providers to operate the App. Each acts as a processor on our behalf, under a written data processing agreement where required by law.

a. Google LLC — Firebase & Google Cloud

We use the following Google services:

  • Firebase Authentication — account creation, password reset, and Apple / Google sign-in.
  • Cloud Firestore — cloud sync of baby profiles, all tracking data, and family share metadata.
  • Firebase Storage — baby profile photos and family-feed photos.
  • Google Cloud Storage (EU) — a dedicated bucket in the European Union (europe-west1, Belgium) that holds opt-in donated cry recordings, used only to retrain the cry-classification model (see section 2.m).
  • Google Cloud Run — hosts our chat backend at https://api.punnbaby.app, which proxies your prompts to OpenAI.
  • Firebase Crashlytics — crash and non-fatal error reports.

Data residency for these services: the Cloud Firestore database (user documents, baby profiles, synced tracking data, and family-sharing metadata) is hosted in the United States (us-central1). The default Firebase Storage bucket (photos) and the chat Cloud Run backend run in asia-southeast1 (Singapore). Donated cry audio (section 2.m) is stored in the European Union (europe-west1, Belgium) in its own dedicated bucket.

b. OpenAI — AI chat responses

OpenAI (United States) acts as our processor for generating Ask Punn replies. When you use the Ask Punn assistant, your typed prompt, your recent chat history, and a structured context payload describing your baby are sent from our Cloud Run endpoint to OpenAI's API so OpenAI's language model can generate the reply. The context payload includes your baby's age in days and recent tracking summaries, which can include health entries you have logged (for example medications and dosages, vaccines, symptoms, and notes). Your baby's name is never sent — the app replaces it with a placeholder before the request and substitutes the real name back into the reply on your device. Your baby's date of birth is not sent. We do not send cry audio, photos, or your account email to OpenAI.

Our own server does not keep a copy of your messages or the context payload (section 2.d). OpenAI processes this data under its API terms: it may retain API inputs and outputs for a limited period for abuse monitoring, and it does not use data submitted through its API to train its models.

c. RevenueCat, Inc. — subscription management

RevenueCat (United States) manages Punn+ subscription entitlements. It receives a pseudonymous app user identifier and purchase metadata. See revenuecat.com/privacy.

d. Apple Inc. and Google LLC — app distribution and payments

Apple and Google distribute the App through their respective stores and handle in-app purchases. Their privacy practices apply to data they collect during download and purchase.

We do NOT use advertising SDKs, behavioural-analytics tracking libraries, or data brokers. We do not sell personal information. We do not allow our processors to use your personal information for their own advertising purposes.

4. How We Use Your Data

a. Core app functionality

We use your tracking data, baby profile, and cry analysis results to provide the features of the App: event logging, charts, insights, growth tracking, reports, and on-device cry classification.

b. AI chat assistant

We use your prompt and the structured context payload (see section 3.b) to generate a response. The server system prompt instructs the model to refuse medical questions and to redirect you to a pediatrician.

c. Cloud sync and family sharing

If you sign in, your data syncs to Firestore so it is available across devices and to adult family members you have explicitly invited.

d. Model improvement (opt-in only)

If you opt in to ML feedback uploads, we use that data to improve the cry classification model.

e. Service operations

We use Crashlytics reports to diagnose bugs and improve reliability. We do not use personal information for behavioural advertising.

5. Legal Basis for Processing (GDPR / UK GDPR)

a. Article 6(1)(b) — contract

Most processing (tracking, sync, family sharing, cry analysis, subscription management) is necessary to provide the App service you have signed up for.

b. Article 9(2)(a) — explicit consent for special categories

Health information (temperatures, medications, vaccines, symptoms, doctor names), cry-audio uploads, and any data revealing the child's physical or mental health is processed only on the basis of your explicit consent, signified by your active choice to enter or upload it.

c. Article 6(1)(a) — consent

We rely on consent for: opt-in ML feedback uploads, partner invitations, and any future anonymous cry-donation feature.

d. Article 6(1)(f) — legitimate interests

We have a legitimate interest in security monitoring, abuse prevention, and Crashlytics-based reliability work. We have balanced this against your rights and offer the controls described in section 7.

Because the personal information is about a child, parental consent is the consent we obtain and rely on. The parent or legal guardian grants consent on the child's behalf.

6. Retention

  • Baby profiles, tracking data (feeding, sleep, diaper, growth, pumping, milestones, milk inventory), and health events: retained until you delete the record or delete your account. For a baby you do not own (a shared baby), deleting your account removes only your membership — the data you logged remains with the baby's owner until the owner deletes it.
  • Photos: retained in Firebase Storage until you delete the photo or delete your account.
  • Cry analysis results: retained until you delete them or delete your account.
  • Chat messages: the 200 most-recent per baby are retained on your device only; older messages are pruned automatically.
  • Cry-analysis feedback (opt-in, off by default): metadata only (the prediction, your correction, and your baby's age as a coarse bucket — no exact age, no gender). No audio is retained through feedback.
  • Donated cry-audio recordings (opt-in): audio is processed and stored in the European Union (europe-west1) and retained for up to 90 days, then permanently and irreversibly deleted. The recordings are anonymized at the point of collection and are not linked to your account. The anonymous catalogue record for each donation (no identifiers — see section 2.m) is stored in the United States.
  • Cloud Run access logs (chat backend): retained approximately 30 days for operational debugging.
  • Chat usage metadata (no message content): per-request records of timestamp, token counts, latency, request status, your user ID, and a hashed IP address, retained while your account is active and deleted when you delete your account.
  • Crashlytics non-fatal error payloads: retained per Firebase Crashlytics defaults; we are reviewing and tightening this in a future release.
  • RevenueCat subscription records: retained per RevenueCat's policy; subscription history may be retained for financial-record purposes after account deletion.

7. Your Rights and the Parent's Right to Review and Delete the Child's Data

Under COPPA, GDPR, UK GDPR, and Thai PDPA, as the parent or legal guardian you have the right to:

  • Access the personal information we hold about your child
  • Rectify inaccurate information
  • Erase the information ("right to be forgotten"). Recordings you have already donated are fully anonymous and cannot be retrieved or deleted on request; they are automatically and permanently deleted within 90 days of donation.
  • Restrict or object to certain processing
  • Port the data to another service in a machine-readable format
  • Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal
  • Refuse further collection of your child's information and require us to delete what we already hold (COPPA 16 CFR 312.6)
  • Lodge a complaint with your supervisory authority (for example, the U.S. Federal Trade Commission, an EU/EEA Data Protection Authority, the UK Information Commissioner's Office, or the Personal Data Protection Committee of Thailand)

You can exercise the access, rectification, and erasure rights directly inside the App by viewing, editing, or deleting individual records. For any other request, email admin@punnbaby.app with the subject "Privacy Request" and we will respond within 30 days.

We do not condition your child's participation in any App activity on the disclosure of more personal information than is reasonably necessary to provide that activity (COPPA 16 CFR 312.7).

8. Children's Data — COPPA Notice

The data subjects whose information is collected through the App are children under 3 years old. The App is directed at the parent or legal guardian. We do not knowingly allow children to create accounts, enter their own information, contact other users, or post publicly.

Parents and legal guardians grant consent on the child's behalf. By creating an account, entering your baby's profile, or logging tracking data, you confirm that you are a parent or legal guardian of the child and that you consent to the collection, use, and sharing of the child's personal information as described in this policy.

We use the child's personal information only to support the internal operations of the App (providing the tracking features, syncing across the parent's devices, generating reports for the parent, and improving the cry classification model when the parent opts in). We do not use it for behavioural advertising or third-party marketing.

If you believe we have collected information from a child without the necessary parental consent, or you wish to review or delete your child's data, please email admin@punnbaby.app.

9. International Data Transfers

Personal information may be processed outside your country of residence:

  • United States (us-central1): our Cloud Firestore database stores user documents, baby profiles, synced tracking data, and family-sharing metadata. OpenAI processes chat prompts and context; RevenueCat processes subscription metadata; Firebase Crashlytics processes crash reports; the anonymous cry-donation catalogue record (no personal data — see section 2.m) is stored here.
  • Singapore (asia-southeast1): Firebase Storage (photos) and our Cloud Run chat backend (server compute).
  • European Union (europe-west1, Belgium): donated cry-audio recordings (opt-in) — the audio itself — are processed and stored here (see section 2.m).

For transfers from the EU/EEA or the UK, we rely on the European Commission's Standard Contractual Clauses (or the UK International Data Transfer Addendum) as a transfer mechanism with our U.S. processors. EU users should be aware that synced app data is stored in the United States and photos in Singapore by default. For users in the EU/EEA, donated cry audio stays within the EEA, so no Chapter V transfer applies to that data.

10. Security

  • Encryption in transit: all traffic between the App, our Cloud Run backend, and our processors uses TLS.
  • Encryption at rest: Firestore and Firebase Storage encrypt data at rest by default.
  • Authentication: API requests are authenticated with Firebase ID tokens.
  • Access control: Firestore Security Rules and Storage Security Rules restrict each user to their own baby data and to families they have been invited to.
  • On-device cry analysis: raw cry audio is analyzed on-device and is uploaded only if you explicitly donate that recording (see section 2.m). ML feedback never includes audio.

11. How to Delete Your Account and Data

You can delete your account and your child's data from inside the App:

  1. Open the App and go to Settings.
  2. Tap Account.
  3. Tap Delete account and confirm. You may be asked to sign in again to confirm the deletion.

Account deletion removes:

  • All Firestore documents owned by your account (baby profiles, all tracking data, family-share metadata).
  • Chat usage metadata records linked to your account (see section 2.d).
  • All Firebase Storage objects owned by your account (profile photos, family-feed photos).
  • Your local on-device database.
  • Your RevenueCat subscription record (subject to financial-record retention).
  • Your Firebase Authentication user record.

Family-sharing note: if you are the owner of a baby, deleting your account permanently deletes that baby and all of its tracking data for every family member who shared it. If you are a non-owner member, deleting your account removes only your own membership — data you logged into a baby owned by someone else remains with that owner.

Account deletion does not immediately remove:

  • Cloud Run server-side access logs for the chat backend (retained approximately 30 days, then automatically purged).
  • Crashlytics non-fatal error payloads that may have been collected before deletion. We are tightening this retention in a future release.

For any deletion request you cannot complete in the App, or to request a copy of your data, email admin@punnbaby.app and we will respond within 30 days.

12. Thai PDPA Compliance

In compliance with the Personal Data Protection Act B.E. 2562 (PDPA):

  • The data controller is identified per Section 23 (see Section 1 above).
  • Data subject rights are honored per Sections 30 to 36 (see Section 7 above).
  • Cross-border data transfers are protected per Section 28 (see Section 9 above).
  • Consent is obtained in accordance with Section 19, with additional explicit consent for sensitive data (including health data) per Section 26.

13. Changes to This Policy

We will notify you of material changes to this policy in-app and by updating the "Last updated" date at the top. Where the change affects the personal information of a child and requires new parental consent under COPPA, we will request that consent before applying the change to existing accounts.

14. Contact

For any privacy question or to exercise your rights:

  • Email: admin@punnbaby.app
  • Telephone: +66 93-393-9955
  • Mailing address: 195/69 Chaiyapruk Petchkasem 69, Nong Khaem, Bangkok 10160, Thailand
  • Subject line for privacy requests: "Privacy Request"

We will respond to verifiable requests within 30 days.

  • Privacy Policy
  • Terms of Service
  • Account Deletion

Contact: admin@punnbaby.app

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