# Privacy Policy

**BabeBom**

**Last Updated**: January 28, 2026
**Effective Date**: January 28, 2026

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## 1. Overview

BabeBom ("BomToBe", "we", "us", "App") takes your privacy seriously and complies with applicable data protection laws, including GDPR, CCPA, and local privacy regulations.

This Privacy Policy explains what information is collected when you use the BabeBom app, how it is used, stored, and protected.

---

## 2. Information We Collect

### 2.1 Required Information

**Device Identifiers**
- Android: Android ID
- iOS: Vendor Identifier (IDFV)
- Windows: System ID
- **Purpose**: App settings, subscription management, local network device identification
- **Retention**: Until app is uninstalled

**Camera and Microphone Data**
- Real-time video stream (WebRTC)
- Recorded video files (WebM format)
- **Purpose**: Baby monitoring, sleep observation
- **Retention**: Stored locally on your device until you delete them
- **Note**: All videos are stored only on your device and never sent to external servers

**Face Recognition Data** (MediaPipe)
- 478 facial landmark coordinates (3D)
- Head pose (Pitch, Yaw, Roll)
- Eye Aspect Ratio (EAR)
- Facial expression analysis
- Pain score (NFCS-based)
- **Purpose**: Sleep state analysis, anomaly detection, statistics
- **Processing**: All analysis is performed on-device in real-time, only results are stored locally
- **Retention**: Until you delete them

**Sleep Analysis Data**
- Sleep stages (Awake, Light Sleep, Deep Sleep, Risk)
- Anomaly scores (Ensemble Score)
- Alert event records
- **Purpose**: Sleep quality analysis, risk situation alerts
- **Retention**: Until you delete them

### 2.2 Optional Information

**Network Information**
- Local network IP address, subnet mask
- **Purpose**: Automatic device discovery on local network (parent device ↔ monitoring device connection)
- **Retention**: Temporary in memory until app is closed

**Payment Information**
- Subscription status (active/inactive)
- Purchase receipt tokens (provided by Google Play / App Store)
- **Purpose**: Subscription feature provision and management
- **Storage**: Encrypted in SecureStorage
- **Note**: We do not collect actual payment information (card numbers, account numbers); Google/Apple handles payment processing

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## 3. How We Process Information

### 3.1 Local Processing Principle

**BabeBom is a completely on-device app:**
- ✅ All data is stored only on your device
- ✅ Video analysis is processed in real-time on your device (MediaPipe WASM)
- ✅ No personal information is sent to external servers
- ✅ No cloud storage is used

### 3.2 Data Transmission

**WebRTC Local Network Streaming**
- Uses WebRTC for video transmission between parent device and monitoring device
- **Transmission Scope**: Only within the same Wi-Fi network (no external transmission over the internet)
- **Encryption**: WebRTC standard encryption (DTLS-SRTP)
- **Data Storage**: Transmitted data is temporarily stored only in receiving device memory and deleted when app is closed

### 3.3 Third-Party Sharing

**BabeBom does not share your personal information with third parties.**

However, information may be provided in the following legal circumstances:
- When required by law or regulation
- When requested by law enforcement agencies following legal procedures

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## 4. Third-Party Services

### 4.1 Payment Services

**Google Play Billing (Android)**
- Provider: Google LLC
- Information Collected: Purchase history, subscription status
- Privacy Policy: <https://policies.google.com/privacy>

**Apple In-App Purchase (iOS)**
- Provider: Apple Inc.
- Information Collected: Purchase history, subscription status
- Privacy Policy: <https://www.apple.com/legal/privacy/>

### 4.2 Face Recognition Library

**MediaPipe (Google)**
- Provider: Google LLC
- Purpose: Facial landmark detection and analysis
- **Processing**: Completely local processing (WASM), no data sent to Google servers
- Open Source License: Apache 2.0
- GitHub: <https://github.com/google/mediapipe>

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## 5. Data Retention and Deletion

### 5.1 Retention Periods

| Data Type | Retention Period | Deletion Method |
|-----------|------------------|-----------------|
| Device ID | Until app is uninstalled | Auto-deleted when app is uninstalled |
| Recorded Videos | Until you delete them | In-app delete function or app uninstall |
| Face Recognition Data | Until you delete them | In-app delete function or app uninstall |
| Sleep Analysis Data | Until you delete them | In-app delete function or app uninstall |
| Subscription Info | Until app is uninstalled | Auto-deleted when app is uninstalled |
| Network Info | During app runtime only (memory) | Auto-deleted when app is closed |

### 5.2 Your Right to Delete

You can delete your data at any time using the following methods:
1. **In-App Deletion**: Delete individual recordings from the file management screen
2. **App Uninstall**: Uninstalling the app completely deletes all local data

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## 6. Data Protection Measures

### 6.1 Technical Measures

- **Encrypted Storage**: Sensitive information is encrypted in SecureStorage
- **WebRTC Encryption**: DTLS-SRTP protocol for video transmission
- **Minimal Permissions**: Request only essential permissions for required features
- **Local Processing**: All data processing is performed on-device

### 6.2 Administrative Measures

- Establishment and implementation of privacy policy
- Designation of Data Protection Officer
- Regular security audits and updates

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## 7. Your Rights

You have the following rights:

1. **Right to Access**: View stored data anytime within the app
2. **Right to Rectification**: Delete and recreate incorrect data
3. **Right to Erasure**: Immediately delete data using in-app delete function or app uninstall
4. **Right to Restrict Processing**: Data processing stops immediately when you stop using the app

**How to Exercise Rights**: Manage directly through in-app features or contact us using the information below

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## 8. Children's Privacy

BabeBom protects the privacy of children under 14 years old by taking the following measures:
- The app is installed and used by the child's legal guardian
- The child's video is stored only on the guardian's device
- Processed locally only, without external transmission

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## 9. Changes to Privacy Policy

This Privacy Policy may be updated due to changes in laws, policies, or service updates.
When updated:
- Notification through in-app announcements or update messages
- Important changes will be announced 7 days prior to implementation

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## 10. Data Protection Officer

**Data Protection Officer**
- Company: BomToBe
- Email: [email protected]
- Phone: +821053786099

**For Privacy Complaints or Inquiries (Korea)**
- Privacy Infringement Report Center: 118 (<https://privacy.kisa.or.kr>)
- Supreme Prosecutors' Office Cyber Investigation Division: 1301 (<https://www.spo.go.kr>)
- National Police Agency Cyber Safety Bureau: 182 (<https://cyberbureau.police.go.kr>)

**For Privacy Complaints or Inquiries (International)**
- EU: Your local Data Protection Authority
- US: Federal Trade Commission (<https://www.ftc.gov>)
- UK: Information Commissioner's Office (<https://ico.org.uk>)

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## 11. Supplementary Provisions

**Effective Date**: This Privacy Policy is effective as of January 28, 2026.

## 12. Terms of Use (EULA)

**1. Acknowledgment**
This app, BabeBom, is licensed to you under the terms of the **Apple Standard End User License Agreement (EULA)**. By downloading, installing, or using this app, you agree to be bound by these terms.
* [View Apple Standard EULA](<https://www.apple.com/legal/internet-services/itunes/dev/stdeula/>)

**2. Subscription Terms**
If you choose to purchase a subscription, the following terms apply:

* **Payment**: Payment will be charged to your Apple ID account at the confirmation of purchase.
* **Auto-Renewal**: Subscription automatically renews unless auto-renew is turned off at least 24 hours before the end of the current period.
* **Account Charges**: Your account will be charged for renewal within 24 hours prior to the end of the current period.
* **Management**: You can manage and cancel your subscriptions by going to your App Store Account Settings after purchase.
* **Free Trial**: Any unused portion of a free trial period, if offered, will be forfeited when the user purchases a subscription to that publication, where applicable.