PRIVACY POLICY

Offloo — a Softora42 Labs LLC Service

Effective Date: March 1, 2026

Softora42 Labs LLC (“Softora42 Labs,” “Offloo,” “we,” “our,” or “us”) operates the Offloo mobile application (the “Services”). This Privacy Policy explains what information we collect from parents and children, how we use it, and the rights parents have. This Policy is written to comply with the Children's Online Privacy Protection Act (“COPPA”) and should be read together with our Terms of Use and our COPPA Direct Notice to Parents.

Offloo is a family app: a Parent creates and controls the account, and a child may use a linked child profile only within that Parent-controlled account.

1. Information We Collect

1.1 Information We Collect From the Parent (Account Holder)

• Email address and password (for account creation and login)
• Parent PIN (stored in hashed/encrypted form; used to gate parent-only screens)
• Parent's year of birth (used only to confirm the account holder is an adult; not published or shared)
• Subscription and payment status (payment itself is processed entirely by Apple App Store or Google Play — Softora42 Labs LLC does not receive or store your payment card details)
• Communications you send us (for example, support requests or feedback)

1.2 Information We Collect About a Child

We collect the minimum information necessary to operate the child profile. Specifically, and only this:

• First name or nickname, as entered by the Parent
• Age, as entered by the Parent

We do not collect: the child's last name, email address, phone number, precise or approximate geolocation, photos, videos, audio recordings, drawings, school information, or any persistent identifier used for behavioral advertising. The Services do not currently allow a child to upload photographs, drawings, or other user-generated media, and no such content is collected or stored for any child profile.

1.3 Activity and Usage Data

Within the child profile, we record which in-app activities were viewed, started, marked complete, and approved by the Parent, along with associated in-app currency (“gems”), streaks, and trophies. This data is tied to the child profile (identified only by first name/nickname and age, as provided by the Parent) and is used solely to operate the Services — for example, to show progress, unlock trophies, and support the reward-approval workflow between child and Parent.

1.4 Automatically Collected Technical Information

Like most apps, we automatically receive limited technical information necessary for the app to function and to diagnose problems, such as device type, operating system version, app version, crash logs, and general performance data. This technical data is associated with the Parent's account/device, not marketed to children, and is not used to build an advertising profile of a child.

2. How We Use Information

We use the information described above only to:

• Create and operate the Parent account and linked child profile;
• Deliver age-appropriate activity suggestions and track a child's in-app progress, gems, streaks, and trophies;
• Operate the parent-approval workflow (activity completion approval, reward approval);
• Process subscriptions through the applicable app store;
• Maintain, secure, and improve the Services, including diagnosing crashes and technical issues;
• Respond to support requests; and
• Comply with legal obligations.

We do not use a child's information for behavioral advertising, and we do not build advertising profiles of children. We do not serve targeted, third-party advertising to children within the Services.

3. Verifiable Parental Consent

Before we collect any personal information from or about a child, we require the Parent to complete an account-creation flow that includes review of a COPPA Direct Notice, agreement to this Privacy Policy and our Terms of Use, and creation of a Parent PIN. This process is designed to provide verifiable parental consent consistent with COPPA before a child profile becomes active. If we later introduce a new category of data collection from children (for example, allowing a child to submit a photo), we will provide a new direct notice and obtain new verifiable parental consent before enabling that feature for any child account.

4. How We Share Information

We do not sell children's personal information, and we do not share children's personal information with third parties for their own marketing or advertising purposes.

We share information only in the following limited circumstances:

• Service Providers: With vendors who process data on our behalf solely to operate the Services — currently, Firebase/Google Cloud (authentication, database hosting, and backend infrastructure) and, if enabled, crash-reporting or analytics tools configured not to serve ads to children. These providers are contractually restricted to using data only to provide services to us.
• Legal Requirements: If required to comply with a legal obligation, protect the rights, property, or safety of Offloo, our users, or the public, or in connection with a subpoena, court order, or similar legal process.
• Business Transfers: If Softora42 Labs LLC is involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction, subject to this Policy's protections continuing to apply or the provision of prior notice of any change.
• With Your Direction: If the Parent explicitly directs us to share information (for example, exporting data at the Parent's request).

5. Parental Rights and Controls

As the Parent/Account Holder, you have the right at any time to:

• Review the personal information we have collected from your child;
• Request that we delete your child's personal information;
• Refuse to permit further collection or use of your child's information, and request that the child profile be deactivated;
• Update or correct your child's name or age; and
• Ask questions about our data practices.

You can exercise most of these rights directly within the app under Settings → Account. To delete your child's profile and associated data, or for any request you cannot complete in-app, email us at info@offloo.org from the email address associated with your account. We will verify you are the Parent/Account Holder before making changes and will respond within a reasonable time, and in any event within the time required by applicable law.

6. Data Retention

We retain Parent account information for as long as the account is active, and child profile information for as long as the associated child profile is active within that account. If you delete the child profile or your account, we will delete or anonymize the associated personal information within a reasonable period, except where we are required to retain limited records (such as consent records) to comply with legal obligations or resolve disputes.

7. Data Security

We use administrative, technical, and physical safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction, including encrypted storage of the Parent PIN and password, and access controls on our backend systems. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

8. Children's Use Outside the Parent-Controlled Profile

A child cannot create an account, cannot access parent-only screens (which are protected by the Parent PIN), and cannot approve their own reward redemptions or activity completions — all approvals require the Parent PIN. The Services are not designed to allow a child to interact with unrelated third parties, other children, or the public through the app.

9. International Users

The Services are operated from the United States and are intended for use by families in the United States. If you access the Services from outside the United States, you understand that your information will be transferred to and processed in the United States, which may have different data protection laws than your country of residence.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, particularly any change affecting how we collect or use a child's information, we will notify the Parent (via in-app notice and/or email) and, where required by COPPA, obtain renewed verifiable parental consent before the change takes effect for an existing child profile.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, or wish to exercise any parental right described above, contact:

Softora42 Labs LLC

Email: info@offloo.org

Website: https://offloo.org