Children's Privacy Notice
Last updated October 7, 2026 · Version 2026-10
This notice is for parents and guardians. It explains how Tumbly, made by Winding AI Inc. (Winding Labs), handles information about children under 13, as required by the Children's Online Privacy Protection Act (COPPA). It's part of our privacy policy.
Who to contact
Winding AI Inc. · Mill Valley, California, USA · privacy@tumbly.ai. We're the only operator collecting children's information through Tumbly.
How we get your consent
- Kids can open Tumbly and listen to pre-made stories as a guest. As a guest we collect only an app-generated ID and usage events, which we use solely to keep the app working and measure how it's used (COPPA's "support for internal operations"): no name, no voice, no precise location, and nothing goes to ad networks or Google Analytics.
- Before a child gets a profile, or uses location or voice features, a grown-up passes a parent check, signs in, reads this notice, and gives consent. We record when consent was given and which version of this notice it was for.
- Consent is a step-by-step choice. You can allow profiles and progress without allowing location, voice questions or "Tell me about here".
- Where the law requires a stronger method of verifying that you're a parent, we'll use one, such as a small card transaction through your app store or Stripe.
What we collect from or about children
| Information | How we use it | Kept for |
|---|---|---|
| Nickname, avatar, age range (entered by a parent) | Show the right profile and age-appropriate stories | Until the profile is deleted |
| Precise location, only on trips and only if you allow it | Start the story for the place you're passing; find stories nearby | Not stored on our servers |
| Voice recordings, only while the "ask" button is held and only if you allow it | Turn the question into text so it can be answered | Not stored; deleted right after transcription |
| Question text (from the recording) | Write the answer | Not stored |
| Stories played, quiz answers, island items, favorite topics | Remember progress and suggest stories | Until the profile is deleted (trip history: 13 months) |
| Profile ID, household ID, device type and app version | Keep the app working, count usage, fix bugs (support for internal operations) | 13 months in analytics |
Children can't chat, post, share photos, make public profiles or contact anyone through Tumbly. We don't collect a child's real name, birthday, photo, email, phone number or school.
Who receives children's information
Only service providers that help us run Tumbly, under contracts that forbid them from using it for anything else:
- Cloudflare (hosting and storage).
- ElevenLabs (turns a voice question into text and voices the answer).
- OpenRouter, routing to Anthropic and Google AI models (writes answers and stories from the question text and a rounded location; never the nickname).
- PostHog (product analytics with profile IDs, sent from our servers without IP address or location).
We don't disclose children's information to any other third party. We don't sell it, use it for ads, or let anyone use it to train AI. If we ever want to disclose a child's information to a third party for a purpose that isn't part of running Tumbly, we'll ask for your separate consent first, and you can say no and keep using Tumbly.
Your rights as a parent
- Review the information we have about your child, and get a copy: tumbly.ai/data-request.
- Change or delete it: in the app's grown-up area, or delete the account.
- Refuse further collection or use: turn off features in the grown-up area, delete the profile, or email privacy@tumbly.ai.
We'll never require a child to give more information than is reasonably needed to take part in an activity.
How we protect it
We keep a written information security program and a written data retention policy (the "Kept for" column above and section 7 of our privacy policy). We delete children's information when it's no longer needed, and never keep it indefinitely.