This Privacy Policy describes how Beijing Webulls Information Technology Co., Ltd. (“Company”, “we”, “us”) collects, uses, discloses, and protects personal information relating to users of the Twinkle Plan (also written “TwinklePlan”) service and related mobile applications, websites, and online features (collectively, the “Service”). This Policy explains how information is handled for all users, and contains a special section describing how we treat information collected from children and the role of parental/guardian consent where required.
1. Scope and acceptance
By accessing or using Twinkle Plan, the user (or the user’s parent/guardian, where applicable) accepts the terms of this Privacy Policy. Use of certain features (for example: account creation, goal tracking, reward redemption, or upload of profile content) may require the user (or a parent/guardian) to provide additional information and consent.
2. Information collected
We collect information in three broad categories:
a. Account and contact information. May include parent/guardian email address, account username, hashed password, and minimal child identifiers (first name or nickname, age or birth year) when necessary for account setup.
b. Content and activity data. Data created through use of the Service such as goals/plans created, progress and completion records, reward redemptions, badges/twinkles(stars) earned, device-generated activity logs (timestamps, event records), and optional content the child or user uploads (profile avatar, photos or voice clips) if the corresponding feature is enabled.
c. Device and analytics data. Technical information such as device type, app version, IP address, and usage analytics (crash logs, feature-usage metrics, and performance data) used to operate and improve the Service.
Where the Service integrates third-party features (for example analytics, cloud storage, or payment processors), additional categories of data may be processed by those third parties under their own policies (see Section 6 below).
3. Children’s privacy and parental consent (COPPA and related rules)
Twinkle Plan is designed with child users and families in mind. Where the Service collects personal information from children under 13 years of age (a “child” under the U.S. Children’s Online Privacy Protection Act — COPPA), the Company follows the U.S. federal requirements for parental notice and verifiable parental consent before collecting, using, or disclosing personal information from such children. See the Federal Trade Commission and COPPA Rule for details.
Specifically:
• No collection of personal information from a child under 13 will occur without providing a direct notice to the child’s parent/guardian and obtaining verifiable parental consent, except where strictly permitted by law.
• Types of personal information requiring parental consent (where collected) include: full name, personal photos or videos, audio recordings containing a child’s voice, home address, precise geolocation, and parent email or phone for account linkage. Activity data tied to an identified child is treated as personal information to the extent required by law.
• Parents/guardians have the right to review the personal information collected from their child, revoke consent, request deletion, and obtain a copy of the child’s personal data as required by COPPA. The Company provides a clear mechanism for parental review and deletion requests (see Section 9).
4. How information is used
Personal information is used to provide and improve Twinkle Plan, including but not limited to: account provisioning, goal tracking, reward issuance and redemption (including star-accounting features), feature personalization, troubleshooting, fraud prevention, and communications regarding the Service (e.g., notices about changes or important account activity). Non-identifying analytics help improve the app experience. Processing is carried out only as necessary to provide the Service or as permitted by applicable law.
5. Sharing and disclosure
We do not sell personal information. The Company may share or disclose information in the following limited circumstances:
• With service providers. Trusted third-party vendors who perform services on our behalf (cloud hosting, analytics, payment processing, messaging) and who are contractually bound to protect data.
• For legal reasons. To comply with legal obligations, respond to lawful requests, protect rights, or prevent fraud or imminent harm.
• With parental consent. When explicitly authorized by the child’s parent/guardian (for example to enroll in certain optional features or third-party activities).
Parental choices govern disclosures of a child’s personal information; the Company will not disclose such data to third parties for marketing without parental consent.
6. Third-party services and links
Twinkle Plan may link to or integrate with third-party services (for example: payments, cloud storage, analytics, or optional content providers). Those third parties may collect or process information independently. This Policy does not apply to third-party sites or services; users should review third-party privacy terms before using them.
7. Data retention and deletion
Personal information is retained only as long as necessary for the purposes described in this Policy or as required by law. For personal information collected from children, retention practices follow COPPA and related rules; the Company maintains and publishes a children’s data retention schedule upon request and will delete personal information when no longer needed for the purposes collected. (See 16 CFR Part 312 for regulatory retention and direct-notice requirements.) eCFR
8. Security
Reasonable administrative, technical, and physical measures are in place to protect personal information from unauthorized access and disclosure. However, no data transmission or storage system is completely secure; the Company cannot guarantee absolute security.
9. Parental rights and controls
Parents and legal guardians can:
• Review personal information collected from their child.
• Revoke consent, request deletion, or request portable copies of the child’s data.
• Approve or decline optional features that collect personal information (for example cloud backups, photo uploads, or optional social features).
To exercise these rights, contact the Company using the contact information below. The Company will respond to verifiable parental requests consistent with applicable law. COPPA requires verifiable parental consent for certain actions; the Company reserves the right to require reasonable proof of parental identity before fulfilling requests.
10. Notices and communications
The Company may send transactional messages (account and security notices). Marketing communications will be sent only with explicit opt-in consent. For children under applicable age thresholds, direct notices to parents will be provided for data practices that require parental awareness or consent.
11. International users and children outside the U.S.
This Policy is written primarily for U.S. compliance. International rules (for example the EU’s data protection framework which has specific provisions for children and parental consent) may apply to certain users. Where relevant, the Company will act in a manner designed to be consistent with applicable international laws (for example GDPR guidance on child consent), but local legal advice may be required for country-specific compliance.
12. California and state privacy rights
California residents may have additional rights under state law (such as the California Consumer Privacy Act / CPRA and CalOPPA). The Company provides mechanisms to exercise California data rights (access, deletion, limited sale/targeted advertising opt-out where applicable). For users in California, specific contact and disclosure sections will be made available to comply with state law requirements.
13. Children’s safety best practices
The Service is intended to support healthy goal-setting and family interaction. Parents/guardians are encouraged to supervise app use for young children and to configure account settings consistent with family values and safety.
14. Changes to this Privacy Policy
If this Policy changes in a material way, the Company will post the updated Policy and provide direct notice where required by law (for example in matters affecting collection or disclosure of children’s personal information).
15. Contact information
For questions, parental requests, or privacy inquiries, contact: Beijing Webulls Information Technology Co., Ltd.
Email: contactstarplan@gmail.com
Mailing address: Room 704, 7th Floor, Building 1, No. 26 Jinyuan Road, Daxing District, Beijing