Privacy policy

Effective: from the date of publication · Version: privacy-2026-10-draft

This policy explains what personal data we process when you use the Teki app, our website or our customer support, what we use it for, who can access it, how long we keep it and what your rights are. Adults and children use Teki together: the account always belongs to the adult, and a child never signs in.

It is based on the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and Hungarian Act CXII of 2011 on informational self-determination and freedom of information (Infotv.). "We" means the data controller named in section 1; "you" means the adult who holds a Teki account, or anyone who contacts us. This English version is a translation; if the two differ, the Hungarian version prevails.

1. The data controller

Until Fejlesztőmentor Kft. is registered, "we" in this policy means the controller above. If the controller changes after the registration, we will tell you in advance by e-mail and in the app, and explain what changes.

2. In short

• The account belongs to the adult. A child is a profile with a nickname inside your family: no account, e-mail address or password of their own.
• About a child we store only a nickname, a character picture, optionally the year and month of birth, a few settings and the learning history.
• We show no ads, use no third-party analytics or advertising identifiers, and never sell your data.
• We store data in the European Union. Some of our providers also process data in the United States – they are named in sections 7 and 8.
• AI Teki is optional: it works only when an adult turns it on for a specific child. We never store a child's voice.
• You can ask for a copy of your data at any time and delete your account in the app.

3. Whose data we process

• Adults with an account: the family's owner and the invited second adult (the "caregiver").
• Children for whom an adult creates a child profile.
• People who contact us by e-mail, on the website or in the app.
• Visitors of our website.

4. What data we process, why, and on what legal basis

The table shows, for each processing activity, the purpose, the data, the legal basis and how long we keep the data. The legal bases are the points of GDPR Article 6(1): (a) consent, (b) performance of a contract, (c) compliance with a legal obligation, (f) legitimate interests.

Where it is needed to establish, exercise or defend a legal claim, we may keep the relevant data until the claim is time-barred (generally 5 years under section 6:22 of the Hungarian Civil Code) – on the basis of our legitimate interests (f).

Providing data is voluntary, but the app cannot be used without an account, and we cannot answer a message without a way to reach you. There is no other consequence.

5. What we deliberately do not collect

We never ask for or store a child's full name, photo, video, voice recording, exact date of birth, home address, kindergarten or school, health data or contact details – the app has no place where these could be entered. The app never uses the camera. Only AI Teki uses the microphone, and only when an adult has turned that on for the specific child (section 6).

We show no ads, use no advertising identifiers, third-party analytics or tracking code, and we never sell or rent personal data.

6. AI Teki

6.1 What AI Teki is

AI Teki is an optional talking companion in the Teki Plus and Teki Family plans. Teki the turtle plays short talking games with the child (for example finishing a story or counting together), and if the adult allows it, the two can also chat more freely in a Teki call about a fixed set of child-friendly topics (for example animals, colours, seasons or stories). Teki's sentences are written by a language model based on artificial intelligence. We tell the child this too: at the start of the first conversation Teki says that it is a play character that a computer helps to talk.

AI Teki is off by default. Only an adult can turn it on, per child, behind the parental PIN, after reading what it does. If your app does not offer AI Teki, or it is off for a child, none of the processing described in this section takes place and the app does not use the microphone.

6.2 How a conversation works

• Tap or voice. In the games the child answers by tapping pictures by default. Answering by voice needs a second, separate switch: the microphone, which stays off until an adult turns it on. A Teki call is available only with the microphone on.
• When the microphone listens. In a game the app listens only while the child presses the talk button, for at most 10 seconds. During a Teki call – while the call screen is open and the microphone is not muted – the phone itself recognises, on the device, when the child starts and stops speaking, and sends only that short piece of speech. If you choose calls with a button in the settings, the call also listens only while the child holds the button.
• Speech to text. The app sends the piece of speech once to our server, which turns it into text with a speech recognition service. We never store the audio – not on the phone, not on our servers, not in logs or backups – and we use it for nothing other than letting Teki answer.
• Checks and reply. The text is checked by automatic filters and a classifier based on artificial intelligence (for example for personal information, topics not suitable for children, or signs that the child may be in trouble). The language model then writes Teki's next sentences within the game or the call. Every sentence is checked again before it is spoken, and a text-to-speech service turns it into Teki's voice.
• No emotion recognition, no profile. Nothing tries to work out from the child's voice or words how the child feels, and we build no profile from conversations. Teki can remember only the few things listed in section 6.3, and only if you agreed to that separately. The language model never receives the child's nickname.
• When an adult is needed. If the child says something that suggests they are hurt, scared or in trouble, Teki gives no advice: it asks the child to tell a grown-up, pauses the conversation and notifies the family's adults in the app, by push notification and by e-mail. The notice says only what kind of event happened; it never contains the child's words.

6.3 Teki's memory (optional)

If you separately turn on memory for Teki calls and give your consent, Teki can remember a few simple things about the child for later calls: their favourite animal, their favourite colour, the story they heard last and the activity they played last. We store these encrypted, and the language model receives them in the next call so Teki can refer back to them. Teki cannot remember anything else: the list of possible items is fixed, and every item is checked by the same filters as Teki's sentences.

You can see what Teki remembers in the Teki settings and delete it item by item or all at once. Turning memory off or withdrawing your consent deletes everything at once. If you allow Teki to call the child by their nickname, the app inserts the nickname into the sentence; the language model still never receives it.

6.4 What we keep, and for how long

6.5 Who processes AI Teki data

AI Teki uses providers that process the data only on our instructions, under a data processing agreement:

• Language model and safety classification: Anthropic (Claude), United States. It receives the text of what the child said, the frame of the game or call, and, with memory on, the memory items – never the child's voice, nickname or any account identifier. It does not use this data to train its models.
• Teki's voice: ElevenLabs, United States. It receives the text of Teki's sentences, which may repeat the child's words – never the child's voice.
• Speech recognition: OpenAI (gpt-4o-transcribe), United States. It receives the child's piece of speech to turn it into text, does not keep it, and does not use it to train its models.

If we start using another provider for AI Teki, we will name it here first and only then switch it on. Transfers to the United States are covered in section 8.

6.6 Legal basis

AI Teki's processing is based on the adult's explicit consent (GDPR Art. 6(1)(a) and Art. 8), recorded per child with the version of the text shown and the time. The microphone, transcript keeping and memory each need their own consent. Safety filtering, notifying the adults and handling problem reports serve the child's protection; their legal basis is legitimate interests (GDPR Art. 6(1)(f)).

6.7 Your choices

• You can turn off AI Teki, the microphone, Teki calls, memory or transcript keeping for a child at any time in the Teki settings. Turning off AI Teki, the microphone or calls ends the conversation in progress; turning off transcript keeping or memory deletes the stored text or items at once.
• You can report a problem with any conversation in the Teki settings; our staff review it.
• Your data export contains the AI Teki settings and consents, the conversation data, any transcripts still kept and the memory items.
• Deleting the child deletes everything in this section.

7. Who can access the data

7.1 Our staff

Only staff who need it for their work can access the data, and only with two-step verification. In the admin tool they see children's data masked by default. If you ask for help, a staff member can open more for a limited time and with a stated reason; this is logged. Our staff cannot sign in to your account as you.

7.2 Processors

These providers process data only on our instructions, under a data processing agreement:

7.3 Independent controllers and authorities

• App Store and Google Play. If you subscribe in the app, the store handles the purchase, payment, invoicing and refunds under its own privacy policy (App Store: Apple Distribution International Ltd.; Google Play: Google Commerce Limited). We receive only the subscription status from them, never card data.
• Sign in with Apple or Google. If you use them, the provider processes your data under its own policy and passes on to us only an identifier, your e-mail address and whether it is verified.
• Authorities and courts. We disclose data to them only where the law requires it.

8. Transfers outside the European Union

We store data in the European Union. The providers in section 7.2 whose location includes the United States also process data outside the European Economic Area. Such transfers rely on the safeguards the GDPR requires: the standard contractual clauses adopted by the European Commission or, where the provider is certified, the EU–US Data Privacy Framework. You can ask for information about the safeguards using the contact details in section 1.

9. How we protect the data

• Every connection is encrypted.
• Passwords and the parental PIN are stored only in a form that cannot be reversed.
• Observations, notification tokens, kept transcripts, Teki's memory and the comments on problem reports are additionally encrypted.
• Data stored on the phone is kept in an encrypted database.
• Data exports are stored encrypted and can be downloaded only in the app, while signed in.
• We do not write passwords, tokens, nicknames or observations to logs.
• Our staff work with two-step verification and only the permissions their work needs, and their actions are logged.
• We make regular backups, and after restoring a backup we apply earlier deletion requests again.

If a personal data breach nevertheless occurs that puts you or your child at risk, we report it to the authority as the GDPR requires and, where needed, notify you without undue delay.

10. Children's data and parental consent

Teki is made for children aged 4–7, but an adult always creates and manages the account; only a person aged 18 or over can open one. Under the GDPR, processing a child's data on the basis of consent requires the consent of the holder of parental responsibility while the child is under 16 (Art. 8); in Hungary this age is 16. That is why only an adult can create a child profile, the adult gives the consent, and we record it with its version and time.

Settings, purchases and anything that leads out of the app sit behind the parental PIN. If you believe we process a child's data without a parent's consent, write to us and we will delete it without delay.

11. Automated decisions and profiling

We make no decision about you or your child based solely on automated processing that has legal or similarly significant effects. The app suggests the next activities from the child's progress by fixed rules and checks answers by each activity's rules; it gives no scores or ratings, and the adult can always choose a different activity. We build no advertising or marketing profile.

12. Your rights

• Access: you can find out what data we process about you and your child, and ask for a copy.
• Rectification: you can correct most data yourself in the app; we correct the rest on request.
• Erasure: you can delete a child profile or the whole account, and ask us to delete other data unless we are obliged to keep it.
• Restriction: you can ask us to only store data temporarily while a question is being resolved.
• Portability: you receive your data export in a machine-readable format.
• Objection: you can object at any time to processing based on legitimate interests.
• Withdrawing consent: you can withdraw consent at any time; this does not affect the lawfulness of processing before the withdrawal.

How to use them. In the app: Profile → Account and data. The export is made in JSON and CSV, is available for 48 hours and can be downloaded at most three times; we never send it as an e-mail attachment. Deleting the account signs you out of every device at once and completes within 30 days; within that window customer support can still stop it, after that it is final. You can also request deletion without signing in, on the account deletion page of our website. Deleting your Teki account does not cancel a store subscription – cancel it in the App Store or Google Play.

You can also write to us: [email protected]. We answer within one month; where justified we may extend this by two further months and will tell you so within the first month. It is free of charge. Before acting on a request we make sure it really comes from you – so please contact us with the e-mail address of your account, or use the app.

13. Remedies

If you feel we are not handling your data properly, please write to us first ([email protected]) so we can sort it out quickly. You can also lodge a complaint with the supervisory authority:

Hungarian National Authority for Data Protection and Freedom of Information (NAIH)

• Seat: 1055 Budapest, Falk Miksa utca 9–11.
• Postal address: 1363 Budapest, Pf. 9.
• Phone: +36 1 391 1400
• E-mail: [email protected]
• Website: https://naih.hu

You can also go to court. Such cases belong to the regional courts (törvényszék), and you can choose to bring the case before the court of your place of residence or stay (section 23 of the Infotv.). If you live in another EU member state, you can also complain to the data protection authority there.

14. Website and cookies

Our website uses no tracking, analytics or advertising cookies and contains no third-party tracking code. When serving the website, the hosting provider (Contabo GmbH) keeps a technical log for secure operation (IP address, time, the page requested, browser type), which we keep for at most 30 days, on the basis of our legitimate interests (f). If you write to us through the website, the "Customer support and contact" row of section 4 applies.

15. Changes to this policy

If this policy changes materially – for example we start using a new provider, introduce new processing, or the controller changes after Fejlesztőmentor Kft. is registered – we publish the new version before it takes effect, and the app shows it at the next launch. The version and the effective date are always at the top of the document; we send earlier versions on request.