Kamelo helps your child practise tonight’s homework: you photograph the instruction or the lesson, an artificial intelligence reads it, you check it, and your child practises with Kamelo, the colour-changing chameleon. This policy explains which data we process, why, with whom, for how long, and how to exercise your rights. It applies to the Kamelo app (iPhone, iPad and Android) and to the website kamelo.app.
In short
- The homework photo is cropped on your phone, your child’s name is masked, then it is read by Anthropic’s Claude AI (United States) and deleted from our servers within 24 hours.
- We never ask for your child’s surname, school, address or date of birth.
- No advertising, no tracking, no selling of data. The child space contains no analytics, no purchases and no external links that can be reached without your parent code.
- Our servers are in the European Union (Paris). You can export your data or delete everything from the app, at any time.
1. Who we are
Kamelo is published by Thomas Sobstyl, an independent developer based in France, who is the controller of your personal data.
- Contact for your data, support and your rights: thomas.sobstyl@me.com. We reply personally, in French or English.
- Data protection officer: none appointed at this time; please write to the address above.
- UK representative (Article 27 UK GDPR): none yet, as the app is not yet available in the United Kingdom.
2. What data we process
We collect the minimum we need. You can use Kamelo without creating an account.
2.1 You, the parent
- Without an account (the default): a random technical identifier, created by the app on first launch, to save and sync your family’s data. It is neither the advertising identifier nor a hardware identifier of your device.
- If you sign in (to back up, to find your data on another device or to share it with the other parent): your email address, or the identifier provided by “Sign in with Apple” (which may be a private relay address), and sign-in dates.
- Family settings: country, language, time zone, plan (free or Premium). The time of the daily reminder stays on your device.
- Consents: what you agreed to or withdrew, the version of the text and the date.
- Subscription: status, plan and renewal or expiry dates, sent by Apple or Google through our provider RevenueCat. We never see your payment details.
- Your messages to us: your emails, your content reports (“Report a problem”) and your requests for new exercise types, with our replies.
- Parent code: it stays on your device as a salted hash and is never sent to us.
2.2 Your child
- Profile: a first name or nickname that you choose, the school year, the curriculum (France, United Kingdom or United States), a favourite colour, the dictation mode and the preferred voice. No surname, date of birth, school or photo of the child.
- Exercises: the exercises you confirmed (word lists, times tables, lesson questions, poems…), their date and status.
- Practice: answers and results of sessions (right first time, “almost”, words to review), their duration, colour drops, stickers and practice days.
- No location data, no voice recordings, no face or emotion analysis.
2.3 Homework photos
- You take or import the photo in the parent space. Before sending it, your device crops it to the page, shrinks it (1,568 pixels at most), removes its metadata (including location) and masks the lines at the top of the page that look like a name, a class or a date.
- The text read by your device (character recognition) may be sent with the photo as a hint, without the masked lines. The AI also receives the school year, the curriculum and the language, never your child’s first name or your identifiers. It is instructed never to copy the name of a person or a school.
- The photo is kept for at most 24 hours on our servers, for the analysis, then deleted automatically. Only the exercise you confirm stays in your account, with technical information about the analysis (model used, duration, cost, confidence level), without the image.
- If you ask Kamelo to learn a new exercise type, and only with your explicit consent for that request, the photo is kept for 30 days for review, then deleted.
- Tip: frame only the instruction or the lesson; avoid photographing faces or personal documents.
2.4 On your device
- Kamelo works on your device first: your family’s data is stored there, then synced with our servers when possible. On iPhone and iPad, it may be included in your device backups (iCloud or computer), which are governed by Apple’s terms; on Android, Kamelo turns off the automatic backup of its data.
- Your device’s own speech voices work offline: no text is sent when they are used.
- On Android, Google’s document scanner and text recognition (ML Kit, provided by Google Play services) run on the device: the photo is not sent to Google. Google may receive technical diagnostics about these tools (device and app model and version, performance, error codes, installation identifier).
2.5 On this website
The kamelo.app website sets no cookies and reads or stores nothing on your device. It loads no external fonts or scripts. It is hosted by Vercel, which logs visitors’ IP addresses in its technical logs for security purposes.
- Visit counts. To know which pages are useful and where visitors come from, the site counts visits anonymously: the page viewed, the site you came from (or the link’s campaign tag), the country derived from the connection, the type of device, and clicks on the sign-up or download buttons. To count a visit only once a day, a code is computed from the IP address and the browser with a random value that changes every day and is erased within 48 hours: neither the IP address nor the browser is stored, and the code can no longer identify you afterwards. These statistics stay with us, in our database in Paris, and are never shared. If your browser sends a “Do Not Track” or “Global Privacy Control” signal, nothing is counted.
- “Tell me” reply slip. If you leave your email address to hear when the app comes out, we use it to send you one email, on the day the app comes out on the phone you chose, and then we delete it. We keep the site’s language and the site you came from with it.
2.6 What we don’t do
- No advertising, no tracking, no advertising identifier: the app does not request it.
- No audience measurement and no crash-reporting tool in the current version. If we ever add one to the parent space, it will be after updating this policy, and never in the child space.
- No selling, renting or sharing of data for commercial or advertising purposes.
- No training of AI models with your data or your child’s data.
- No free conversation between your child and an AI: all of Kamelo’s lines are written in advance.
3. Why we process data, and on what legal basis
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Provide Kamelo: family space, profiles, exercises, sessions, progress, sync, sign-in and sharing with the other parent | account, family, profiles, exercises, results | performance of the contract, that is our terms of use (Art. 6(1)(b)) |
| Read the homework photo with AI and prepare the exercises, including lesson quizzes | photo, text hint, school year, curriculum, language | your consent (Art. 6(1)(a) and 8; in France, Art. 45 of the French Data Protection Act) |
| Keep a photo for 30 days to learn a new exercise type | photo, instruction, school year, curriculum, language | your consent, given for each request (Art. 6(1)(a)) |
| Manage the Premium subscription, the free scans (3 offered, then 1 a month) and fair use | subscription status, scan counter, cost of each analysis | performance of the contract (Art. 6(1)(b)) |
| Read words aloud with an online voice, when enabled | words and phrases of the exercise | performance of the contract (Art. 6(1)(b)) |
| Security: prevent abuse (at most 20 scans per hour), technical logs, records of consents, exports and deletions | technical identifiers, logs, events | legitimate interest: keeping the service secure and being able to prove we meet our obligations (Art. 6(1)(f)) |
| Monitor the quality and cost of analyses | technical scan information, aggregate statistics | legitimate interest: reliability of the service (Art. 6(1)(f)) |
| Answer you and handle your requests | email, messages | performance of the contract; legal obligation for your rights (Art. 6(1)(c)) |
| Count website visits anonymously | page viewed, referring site, country, device type, daily code | legitimate interest: knowing which pages of the website are useful (Art. 6(1)(f)) |
| Tell you when the app comes out (website reply slip) | email address, chosen phone, language, referring site | your consent (Art. 6(1)(a)), which you can withdraw by writing to us |
We make no solely automated decision that has legal or similarly significant effects on you or your child (Art. 22 GDPR). Kamelo gives no marks, does not rank your child and predicts nothing about them: words to review are chosen by simple rules (a missed word comes back later).
You can withdraw your consent at any time in Settings › Privacy › “Withdraw my consent”. Scanning is then turned off; exercises already created remain available and manual entry still works. Withdrawal does not affect processing already carried out.
4. Who processes data on our behalf
We do not sell or share your data. Only the following providers process it, on our behalf and on our instructions, under a data processing agreement (Art. 28 GDPR):
| Provider | What for | Data | Where | Safeguards |
|---|---|---|---|---|
| Supabase, Inc. | database, sign-in, file storage, server functions | all service data, including photos (24 hours at most) | European Union: Paris (Amazon Web Services servers, eu-west-3 region) | data processing agreement; standard contractual clauses for any access from the United States |
| Anthropic (Claude API) | read the homework photo, prepare exercises and lesson quizzes, check that texts shown to the child are suitable | masked photo, text hint, school year, curriculum and language, lesson text; never the child’s first name or your identifiers | United States | Anthropic’s commercial terms and data processing agreement; standard contractual clauses; no model training on your data |
| Amazon Web Services (Amazon Polly), when the online voice is enabled; it is not yet: Kamelo currently uses your device’s voices | read words aloud | words and phrases to speak, language, voice | European Union: Paris (eu-west-3 region) | AWS data processing agreement; standard contractual clauses |
| RevenueCat, Inc. | manage the subscription status | your family’s random identifier, purchase history sent by the store, country, technical information about the device and app | United States | data processing agreement; standard contractual clauses |
| Vercel Inc. | hosting the kamelo.app website and relaying visit counts and the reply slip to our database | IP address and technical logs of website visitors | United States and European Union | data processing agreement; standard contractual clauses |
Anthropic does not use this data to train its models and does not keep it beyond processing the request, except as provided in its terms (30 days at most, and up to 2 years for content flagged by its safety systems).
Other recipients:
- Apple and Google sell and bill the subscription through the App Store and Google Play under their own terms and privacy policies: for this they act as independent controllers. “Sign in with Apple” is provided by Apple. Emails sent to support are received in an iCloud (Apple) mailbox.
- Google receives ML Kit diagnostics on Android (see 2.4).
- We only disclose data to an authority when the law requires it, after checking that the request is valid.
5. Children
5.1 A service used by the child, run by the parent
- Kamelo is designed for parents of children aged 6 to 11. Children have no account: you create the profiles, scan the homework, confirm every exercise before your child sees it, and manage settings, purchases and consents in the parent space, protected by a 6-digit code.
- In the child space: no advertising, no analytics, no purchases, no external links, no leaderboards, no chat with an AI, no public profile. No data is sent to Claude from the child space. To call a grown-up, your child taps the door.
- High-privacy defaults: no profiling, no location, no notifications aimed at the child (the daily reminder is addressed to you), no nudges to buy or to extend screen time; a day without practice is never presented to the child as a loss.
- AI-prepared content: lesson quizzes carry the label “Questions generated by AI and reviewed by a parent”, and you must review them before assigning them. Texts produced by the AI for the child go through a moderation filter. The “Report a problem” button lets us review unsuitable content.
5.2 France and the European Union
In France, when processing is based on consent and concerns a child under 15, consent must be given jointly by the child and the holder of parental responsibility (Article 45 of the French Data Protection Act, Article 8 GDPR). You give your consent in the parent space. Your child has a notice written for them, “Kamelo and you”, available from the door in the child space and on this website, which we invite you to read together; your child agrees by starting their first session. The other parent can object to the processing by writing to us.
5.3 United Kingdom
Kamelo follows the UK Age appropriate design code (the Children’s Code): best interests of the child, impact assessment, high-privacy defaults, data minimisation, no profiling, no nudge techniques, child-friendly information, and transparency towards the child about what the parent can see. In the UK the age of digital consent is 13: consent to photo reading is given by you.
5.4 United States: notice to parents (COPPA)
- Operator: Thomas Sobstyl, contact details in section 1.
- Information collected from the child in the child space: their answers and practice results, session duration and rewards (colour drops, stickers, practice days), linked to their profile and to your family’s random technical identifier. No full name, no contact details, no photo, no voice, no location. The child cannot make anything public.
- Use: only to run the exercises, show you progress, back up your family’s data and keep the service secure. Never for advertising or commercial profiling. The technical identifier is used only for these internal operations.
- Disclosure: none to third parties, apart from the providers that host and run the service on our behalf (section 4). This information is never sent to Anthropic.
- Profile creation: only a parent can create a child’s profile, from the parent space protected by their code.
- Your rights: review your child’s information (parent space, export), have it deleted (delete the profile or the account, or write to us), and refuse its further collection (stop using the child space or delete the profile). Retention periods: section 6.
5.5 A question about a child’s data?
If you believe we hold data about a child without their parents’ agreement, write to us: we will delete it.
6. How long we keep data
| Data | Retention period |
|---|---|
| Homework photo (scan) | 24 hours at most, then deleted automatically; only technical information without the image remains |
| Photo sent with a new exercise type request | 30 days, then deleted automatically; the request text and our reply remain visible in “My requests” while the account exists |
| Exercises, sessions, progress, rewards | while the account exists; deleted with the child’s profile or with the account |
| Family without an account, inactive | 18 months after the last activity, then deleted automatically |
| Account (email or Apple identifier) | until the account is deleted |
| Export file of your data | link valid for 1 hour, file deleted after 1 day |
| Consent history and event log (creation, consents, exports, deletion), minimised | 3 years after the account is deleted, so that we can prove we met our obligations |
| Subscription status | while the account exists; purchase history is kept by Apple, Google and RevenueCat under their own rules, as long as needed for the subscription, refunds and accounting |
| Emails sent to support | 12 months after the last exchange |
| Hosting provider’s technical logs | 7 days at most |
| Data processed by Anthropic | not kept beyond the request, except as provided in its terms (30 days at most; up to 2 years for flagged content) |
| Voice cache (spoken words, no personal data) | no limit |
| Website visit statistics | 13 months, then automatic deletion; the day’s random value is erased within 48 hours |
| Email address left on the website’s reply slip | until the launch email, then deletion; 13 months at most |
7. Your rights
You have the rights of access, rectification, erasure, restriction, portability and objection, the right to withdraw your consent at any time and, in France, the right to give instructions about what happens to your data after your death. You also exercise these rights for your child, and your child may write to us directly.
In the app (parent space):
- Review and correct: profiles, exercises and progress can be seen and edited in the parent space.
- Export: Settings › Privacy › “Export my data” (JSON file).
- Withdraw your consent to photo reading: Settings › Privacy.
- Delete a child’s profile and progress: from the list of children in the parent space.
- Delete everything: Settings › Privacy › “Delete my account and all data”, confirmed with your parent code. Deletion is immediate on our servers and also erases the data on the device. It does not cancel a subscription bought on the App Store or Google Play: cancel it in your store settings.
By email, at thomas.sobstyl@me.com: we answer within one month, which may be extended by two months for a complex request. We may ask you to prove that the request comes from you, for example by writing from your account’s email address. Without the app, follow the instructions on the Help page.
If you think your rights are not respected, you can complain to a supervisory authority:
- France: Commission nationale de l’informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr; or the authority of the EU country where you live.
- United Kingdom: Information Commissioner’s Office (ICO), ico.org.uk.
- United States: Federal Trade Commission (FTC), reportfraud.ftc.gov.
8. Security
- Encrypted connections (HTTPS) and data encrypted at rest by our hosting provider.
- Isolation: each family can only reach its own data, through security rules enforced by the database itself.
- Secret keys kept only on our servers, never in the app.
- Photos stored in a private storage area and deleted within 24 hours.
- Parent code kept only on the device, as a hash.
- Administrative access limited to the publisher and protected by two-factor authentication.
- A written security programme, reviewed at least once a year. In the event of a data breach, we notify the CNIL within 72 hours when the law requires it, and we inform the families concerned directly if the risk is high.
No system is invulnerable: if you notice a security problem, please write to us.
9. Transfers outside the European Union
Your data is hosted in the European Union (Paris). Some of it is transferred to the United States:
- to Anthropic: masked photos, text hints and exercise texts, to be read by the AI;
- to RevenueCat: the subscription status;
- occasionally, when Supabase or Amazon Web Services staff carry out maintenance or support.
These transfers are covered by the European Commission’s standard contractual clauses (Decision 2021/914) and, for UK residents’ data, by the UK addendum to those clauses. We have assessed these transfers (transfer impact assessment) and added supplementary measures: name masking, photo reduction, rapid deletion, encryption, no use for model training. You can obtain a copy of the safeguards by writing to us.
10. Changes
We will update this policy if the service changes, for example with a new provider or a new feature. For any significant change, we will tell you in the app before it applies and, where the law requires it, ask for your consent again. The version and date appear at the top of this page; previous versions are available on request.
11. Version for children
A notice written for children explains Kamelo in simple words: Kamelo and you. It is also available in the app, from the door in the child space (“How does Kamelo work?”). We invite you to read it with your child.