Last updated: Oct 16, 2026

Effective date: Oct 16, 2026

BeSpoke Care Inc. (“My Phoenyx,” “we,” “us,” or “our”) provides a connected language-learning plush toy (“Toy”), a parent-managed mobile application (“App”), our website at www.myphoenyx.com (“Website”), and related services (together, “Services”). This Privacy Policy explains the personal information we collect, how we use and disclose it, how long we keep it, and the choices available to parents and guardians.

1. Our commitment to children's privacy

My Phoenyx is designed for young children and managed by a parent or legal guardian. We are committed to protecting children's privacy and complying with the Children's Online Privacy Protection Act (“COPPA”) and other applicable privacy laws. We require parental authorization before enabling children's voice conversations and provide parents with choices about their children's data. The method used to verify parental consent is subject to legal review.

Children do not create their own accounts. Parents manage child profiles and consent. We do not sell children's personal information or use it for targeted or behavioral advertising. We do not make children's content publicly available through the child experience.

2. Information parents provide

We may collect a parent's name, email address, account and sign-in credentials or identifiers, timezone, account and subscription/trial status, purchases and order details, shipping and billing information, support messages, and consent and parental-verification records. Payment information is handled by our payment provider. We also process account activity, IP addresses, device identifiers, and technical/security logs to authenticate accounts and protect the Services.

We record parental consent decisions, including the parent and child profile concerned, consent type, action, timestamp, notice version, and verification method or reference. We retain appropriate evidence of consent and withdrawal for compliance purposes.

3. Information about children and learning

A parent may provide a child's name, age or birthday, preferred languages, name pronunciation, learning goals, proficiency, interests, and other learning preferences. Some fields are optional. Children may share interests, experiences, family details, or other information during conversations or activities.

We process learning and activity records, including lessons, practiced vocabulary, progress, speaking activity, games, stories, songs, achievements, and session history. The App may also store child-created drawings, images, stories, and other creations where those features are used.

We do not intentionally ask children to provide their home address, personal email, telephone number, contacts, government identifiers, or precise location through the child experience. However, a child may voluntarily mention personal information in speech or include it in a drawing or other content, and we may process that information as part of providing the Services.

4. How the Toy works and what it collects

The Toy uses a microphone and speaker to support spoken language practice. During an authorized conversation, it captures and transmits audio through our real-time voice infrastructure and speech/AI services so Phoenyx can understand and respond. **We do not save raw child voice recordings for product improvement by default.** Temporary audio processing by our systems and providers is distinct from our optional saved-recording feature; provider-side logging and retention are addressed in Section 9.

The Toy also processes identifiers and operational data needed for setup and operation, such as device/factory identifiers, authentication information, connectivity and pairing status, battery level, volume, session status, and firmware version. Bluetooth and Wi-Fi are used for setup and connectivity.

Toy parental consent: A parent or guardian must complete the applicable privacy and voice-consent steps for the child profile before the Toy can begin voice conversations.

5. How the App works and what it collects

The App allows parents to create child profiles, configure the Toy, review learning progress and conversations, manage preferences, and access supported learning activities. When the App itself offers voice conversation, it processes the child's speech through our voice and AI systems as described below. App-only features may also collect child-created drawings, lesson/game activity, questionnaire answers, and other content.

The App uses child-profile-specific consent controls: (1) required consent for voice processing needed to provide conversations (`core_voice`); and (2) separate, optional consent for saving recordings for internal product improvement (`recording_storage`). Optional recording consent is OFF by default and does not affect access to core conversations.

6. Voice processing, transcripts, and AI-generated information

Live voice processing. When a child speaks to Phoenyx, audio is transmitted to our real-time communication, speech-recognition, and AI service providers as needed to transcribe speech, understand the conversation, and generate spoken responses. Depending on language and feature, the processing chain may include LiveKit, Deepgram, OpenAI, Google Gemini, and other providers identified in Section 9. Providers may receive audio, transcript text, prompts, and relevant child context such as first name, language, age or level, learning progress, preferences, and conversation memories as necessary for the requested feature. We do not promise that all provider requests omit names or context.

Stored transcripts and derived information. Unlike raw audio, text transcripts of conversations may be retained and made available to parents. We also generate and store session summaries and titles, classifications, vocabulary and learning metrics, and memories that help Phoenyx remember interests, preferences, previous activities, and learning progress. Some memories are represented as keywords or numerical embeddings used to retrieve relevant context. These records can persist beyond an individual conversation and may contain information shared by the child.

Voice recordings are not saved for product improvement by default. Any optional storage of recordings is governed exclusively by the separate opt-in described in Section 7 below. Agreeing to this Privacy Policy or consenting to core voice processing does not authorize optional recording storage.

We do not currently use children's saved voice recordings to train or fine-tune our own AI models. If this practice changes, we will update our disclosures and seek additional parental consent where required. Our service providers process data subject to their applicable terms and data-processing arrangements.

7. Optional voice recording storage — separate parental opt-in

This section applies only when a parent has separately and explicitly opted in for the relevant child. Agreeing to this Privacy Policy, or consenting to the core Phoenyx service, does not automatically grant permission to save voice recordings for product improvement.

Optional recording storage is OFF by default. Parents may affirmatively choose to allow My Phoenyx to securely save their child's voice recordings and associated speech-recognition and session metadata for internal product improvement, including evaluating speech recognition and conversational quality. This optional consent is managed separately for each child and is not required to use Phoenyx's conversational features.

When a parent opts in, recordings and associated speech-recognition/session metadata are stored privately in our cloud storage systems. Access is restricted to authorized My Phoenyx team members, who may listen to recordings and review associated metadata to evaluate speech recognition and improve the product. Parents cannot currently play back or download saved raw recordings directly in the App; they may contact us about their access rights. We retain these recordings until that child's optional consent is withdrawn, the associated transcript is deleted, or the child profile or parent account is deleted. Parents may withdraw this consent through the recording-consent controls in the parent App. Turning it OFF stops future recording storage and deletes previously saved recordings and associated recording metadata from our active storage systems.

Withdrawal of optional recording-storage consent does **not** automatically delete standard conversation transcripts, learning progress, summaries, or memories, which are handled under the ordinary data practices and retention rules described elsewhere in this Policy.

8. Personalization and learning analytics

We use child profile information, conversation history, learning records, and AI-generated memories to adapt vocabulary, activities, stories, and responses to a child's learning needs. We may use operational and learning analytics to measure feature usage, session duration, words practiced, reliability, errors, and product performance. These are learning personalization and service analytics, **not advertising profiles**.

Our systems record first-party product events that may be associated with account, child, device, session, or app identifiers. We do not use advertising identifiers or targeted advertising technology in child-facing Toy or App experiences.

9. Notifications and communications

We may send parents account, security, consent, support, device-status, and learning-related messages. If a parent enables push notifications, we process push tokens, device platform, timezone, and notification delivery or interaction information through our notification providers. Notifications may include learning or device information; parents should consider what may appear on a locked screen. Parents can manage push permissions through their device settings.

10. Service providers and disclosures

We share information with providers only as needed to operate, secure, support, and improve the Services, as described in this Policy and subject to applicable consent requirements. Providers identified in our architecture include:

Provider or category and Function and information potentially processed

• LiveKit Cloud. Real-time voice transport, audio streams, and session metadata.
• Deepgram; OpenAI; Alibaba Cloud/Qwen. Speech recognition and/or AI voice, text, and conversation processing.
• Google Gemini. Conversation summaries, classifications, memories, and related AI features
• Groq. Repair or speech features.
• Vercel; Railway. Application hosting, APIs, voice-agent execution, logs, and operational infrastructure
• Neon; Vercel Blob. Database and file/media storage.
• Firebase. Authentication and/or child-created image storage.
• Resent; Expo. Parent account email and app push-notification delivery.
• Payment, shipping, and app-store providers. Purchases, fulfillment, and distribution.

The exact providers and data shared vary by feature, language, and configuration. We may also disclose information when required by valid legal process, to address security or safety incidents, or in a business transfer subject to applicable privacy protections. We do not sell children's personal information or share it for targeted advertising. Parents can consult the respective providers’ privacy policies for their retention and deletion practices. Those policies do not replace our obligations under applicable law.

11. Parental consent and choices

Parents control their children's profiles. Before voice features are activated, we present the applicable privacy notice and request parental consent. The parental verification method remains under legal review. We record consent and withdrawal decisions. A separate, unchecked opt-in controls whether we may save a child's recordings for internal product improvement. Declining that optional use does not prevent ordinary conversations.

In the App, parents can visit **Settings → Privacy & Data** to read this Policy and manage recording preferences for each child. Parents can turn optional recording storage off at any time. Parents can also delete a child profile in the App. Deleting the profile is the method for withdrawing core voice consent: it immediately hides the profile and associated child data, revokes voice consent, and disables further voice processing for that profile. The profile can be restored during the 30-day recovery period only after privacy and voice consent are completed again.

Parents may request access to or a copy of their child's personal information, correction where appropriate, deletion, or refusal of further collection or use by emailing **legal@myphoenyx.com**. We verify the requester's parental authority before disclosing or deleting child information. We will not require a parent to consent to optional recording storage as a condition of using core language-learning features. If a parent withdraws consent necessary to provide voice conversations, those features cannot continue for the affected child.

12. Retention and deletion

We retain personal information for the purposes described in this Policy, subject to applicable legal requirements. The following describes our retention and deletion practices in My Phoenyx-managed systems:

• Live conversation audio. Processed to enable real-time conversations. We do not save raw voice recordings for product improvement without separate parental opt-in. Temporary processing and third-party retention may differ.
• Optional saved voice recordings and related recording metadata. Saved only after a separate, affirmative opt-in for that child. Retained until recording consent is withdrawn, the associated transcript is deleted, or the child profile or parent account is deleted. Turning off optional recording consent stops future storage and deletes saved recordings and associated recording metadata from active My Phoenyx storage.
• Conversation transcripts, titles, and summaries. Generally retained while the child profile is active. When a parent deletes an individual transcript, it is hidden immediately and its text and summary are scrubbed after approximately 30 days. Limited non-content session metadata may remain. Deleting a transcript does not automatically delete learning progress or memories derived from it.
• Memories and learning progress. Short-lived episodic memories generally expire after approximately 30 days. Other memories and learning progress may be retained while the child profile exists, unless superseded or otherwise deleted.
• Drawings and other child-created content. Retained while needed for the relevant feature or until deleted, subject to the child-profile deletion process below.
• Device, usage, analytics, and security data. Retained as needed to operate, protect, and measure the Services, subject to applicable retention requirements.
• Parent account, orders, and support records. Retained as needed to provide the Services and comply with legal obligations, including transaction-record retention where applicable.
• Consent records. Consent audit records may be retained for compliance purposes after a child profile is purged, without a link to the deleted child's identifying profile.

Deleting a child profile. When a parent deletes a child profile, the profile and its associated information—including transcripts, memories, learning progress, drawings, saved voice recordings, and recording metadata—are immediately hidden, and the child's voice consent is revoked. The information remains recoverable for 30 days in case of accidental deletion. During that period, a parent may restore the profile, but must complete privacy and voice consent again before voice features can resume. After 30 days, an automated purge permanently deletes the child profile, child-owned database records, saved recordings, and stored child media from active My Phoenyx systems, subject to legally required records and the third-party and backup limitations described below.

Deleting a parent account. Account deletion is permanent and does not offer the 30-day profile-restoration option. It initiates deletion of associated child profiles and data, subject to necessary legal or compliance records and applicable infrastructure retention.

Third-party retention. The deletion timelines above describe data in systems managed by My Phoenyx. Third-party service providers may retain information under their own policies, contracts, backup schedules, and legal obligations. For additional information, consult the providers' privacy policies or contact us at legal@myphoenyx.com. These provider policies do not remove My Phoenyx's obligations under applicable children's privacy laws.

13. Security

We use administrative, technical, and organizational safeguards appropriate to children's personal information, including access restrictions, authentication controls, encryption where applicable, security monitoring, and vendor oversight. No system can be guaranteed completely secure. Report privacy or security concerns to legal@myphoenyx.com.

14. Website and other state privacy rights

Our public Website may use essential cookies and analytics. Depending on applicable state law, parents and other users may have additional rights to access, correct, delete, or restrict uses of personal information, or appeal certain decisions. Contact **legal@myphoenyx.com** to exercise applicable rights.

15. Where the Services are offered and data is processed

The Services are intended for use in the United States at launch. Some service providers may process information in other locations.

16. Changes to this Policy

We may update this Policy as our Services change. We will post the updated version and change the “Last updated” date. Where required, we will give parents direct notice and obtain renewed consent before materially changing how their child's personal information is collected, used, or disclosed.

17. Contact us

**BeSpoke Care Inc. (My Phoenyx)**  
800 Third Avenue, FRNT A #1028  
New York, NY 10022  
Phone: (646) 827-0563  
Email: legal@myphoenyx.com