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Legal

Compliance overview

Children's and health-related data sit under the strictest rules in every country. This page maps each law to what Earbunny actually does. It is a summary: the binding texts are the privacy policy, the terms of use and the regional notices linked below.

  1. 1What we do everywhere

    • Privacy by design: no microphone, no listening content, raw motion processed on the phone, location only at earbud events and deleted after 7 days.
    • Explicit consent for health-related measurements; parents give every consent for children.
    • No ads, no trackers, no third-party analytics in the app, no data sale, no profiling of children.
    • No hidden mode: the person monitored always sees it and who can see their data.
    • In-app data download and account deletion; clear retention periods.
    • EU hosting, encryption in transit and at rest, logged staff access.
  2. 2European Union and EEA: GDPR

    RequirementHow we meet it
    Art. 6 and 9: legal basis, health dataContract for the account; explicit consent for listening, dose and posture data and for event location
    Art. 8: childrenA parent creates every child account and gives consent; a recorded consent declaration before pairing a child under 13
    Art. 12 to 14: transparencyPrivacy policy, children's notice with a part for kids, GDPR notice
    Art. 15 to 22: rightsDownload and deletion in the app; other requests answered within one month
    Art. 25: privacy by design and defaultData minimisation, location off until allowed, friends off until a parent turns them on
    Art. 27: representativeNamed in the privacy policy once appointed
    Art. 28 and 44 to 49: processors and transfersData processing agreements; EU hosting; Data Privacy Framework or Standard Contractual Clauses
    Art. 32 to 34: security and breachesEncryption, access control, logging; notification within 72 hours
    Art. 35: impact assessmentData protection impact assessment for the monitoring of children
    ePrivacy DirectiveNo tracking cookies; analytics only after opt-in; refusing is as easy as accepting

    Details: GDPR notice. Accessibility follows the European Accessibility Act target of WCAG 2.2 AA; see the accessibility statement.

  3. 3United Kingdom: UK GDPR and the Children's Code

    UK GDPR and the Data Protection Act 2018 apply as in the EU, with the UK Addendum for transfers and PECR for cookies. We follow the ICO's Age Appropriate Design Code (Children's Code): the child's best interests, high-privacy defaults, no nudging towards weaker settings, no profiling, geolocation off by default and an obvious sign to the child whenever a parent can see their data. Details: UK GDPR notice.

  4. 4United States

    LawHow we meet it
    COPPA (FTC Rule, as amended in 2025)Parental consent before collecting from children under 13; parents can review, delete and stop collection; written retention periods and security programme; no behavioural advertising
    CCPA / CPRA (California)Notice at collection; no sale or sharing; sensitive data used only to provide the service; rights to know, delete and correct; Global Privacy Control honoured
    Other state privacy lawsThe same rights for residents of every state; no targeted advertising or profiling
    Consumer health data laws (Washington My Health My Data Act, Nevada, Connecticut)Consumer health data only with consent, never sold, shared only with processors; consumer health data policy in the privacy notices
    FTC Act §5 and Health Breach Notification RuleTruthful privacy promises; breach notification to users and the FTC where required
    Automatic renewal lawsClear renewal terms before purchase; cancellation in Apple Account settings

    Details: US privacy notice and COPPA notice.

  5. 5Canada: PIPEDA and Québec Law 25

    RequirementHow we meet it
    PIPEDA fair information principlesAccountability, meaningful consent, limited collection, safeguards, openness, individual access
    Children (OPC guidance)Consent from a parent; no behavioural advertising and no covert monitoring
    Québec Law 25A person in charge of personal information reachable at the privacy mailbox; privacy by default; assessment before transfers outside Québec; parental consent under 14; portability
    Breach of security safeguardsReport to the regulator and notify people where there is a real risk of significant harm
    CASLNo marketing email without express consent; one-click unsubscribe
  6. 6Türkiye: KVKK

    Law No. 6698 on the Protection of Personal Data: information notice (aydınlatma metni, Art. 10), explicit consent for special-category data (Art. 6) and for event location, consent from parents for minors, security measures (Art. 12), transfers abroad under Art. 9, rights under Art. 11 and an application form. Before offering the service in Türkiye we register with VERBİS and, if required, appoint a data controller representative. Consumer rules for subscriptions follow Law No. 6502 and the Distance Contracts Regulation. Details: KVKK notice.

  7. 7Brazil: LGPD

    Legal bases under Art. 7 and, for sensitive health data, Art. 11; children's data processed in their best interest with specific consent from a parent (Art. 14); rights under Art. 18; international transfers under Art. 33. Details: LGPD notice.

  8. 8Japan: APPI

    Purposes of use stated in advance; consent before acquiring health-related information (special care-required personal information); consent or equivalent safeguards for transfers abroad, with information about the destination; security control measures and breach reporting to the Personal Information Protection Commission. Details: APPI notice.

  9. 9App Store and Apple Health

    Apple Health data is never used for advertising, marketing or data mining and is never sold. The app does no tracking, so it does not ask for App Tracking Transparency permission. The App Store privacy details match the privacy policy.

  10. 10Not a medical device

    Earbunny provides awareness and habit information. It makes no diagnostic or treatment claims and is not intended to be a medical device under the EU MDR, US FDA rules or similar laws. See the health disclaimer.

  11. 11Questions

    Compliance questions: . Legal questions: . Security researchers: see the security page.