Contents
Freckle Privacy Policy
Freckle Technologies, Inc., a Delaware corporation (“Freckle,” “we,” “us,” or “our”), makes a phone for children ages 7 to 13, the software that runs on it (ClayOS), the Freckle app that parents use to set up and manage the phone (the “Parent App”), the cellular service that connects the phone, and the website at freckle.tech (the “Website”). Together, these are the “Services.”
This Privacy Policy explains what information we collect, why we collect it, who we share it with, how long we keep it, and what choices you have. It is written for parents. The Children’s Privacy section explains how we handle information about children who use a Freckle phone. The Parents, Adults, and Website Visitors section explains how we handle information about parents and adults who use the Parent App or visit the Website.
Our address is 131 Continental Dr, Newark, DE 19713. You can reach us about anything in this policy at privacy@freckle.tech.
The short version (pre-order period)
- Phones have not shipped yet. No child’s information is collected until a parent activates a phone, and the full children’s privacy notice will be published before that is possible.
- Every person who uses a Freckle phone will be treated as a child under 13, and we will collect a child’s information only after a parent has reviewed that notice and given verifiable consent.
- We do not show ads on the phone, in the Parent App, or anywhere else in the Services. We do not sell children’s information. We do not use children’s information to train AI models, build advertising profiles, or market to children.
- Right now, the information we collect is about you, the parent: what you give us to pre-order. The Parents, Adults, and Website Visitors section explains that.
- Freckle is a member of the kidSAFE Seal Program and is being reviewed under its COPPA safe-harbor program.
Children’s Privacy
The Freckle phone has not shipped yet. No child’s personal information is collected until a parent activates a phone, and before that happens we will publish the full children’s privacy notice required by the Children’s Online Privacy Protection Act (COPPA), and ask every parent to review it and give verifiable consent as part of activation. Pre-ordering a phone does not involve any collection of information about your child.
Here is what we can already commit to:
- Every person who uses a Freckle phone will be treated as a child under 13, and we will collect a child’s information only after a parent has reviewed the full children’s notice and given verifiable consent.
- We will collect only what the phone needs to work.
- There will be no advertising on the phone, in the Parent App, or anywhere in the Services. We will never sell children’s information, use it to build advertising profiles, or market to children.
- We will never use children’s information to train AI models, and we will not allow any provider we work with to do so.
- We will publish, inside the children’s notice, exactly who receives children’s information, why, and how long we keep each type of information.
- Parents will be able to review, correct, download, and delete their child’s information at any time.
- Freckle Technologies, Inc., a Delaware corporation, is a member of the kidSAFE Seal Program and is undergoing review under its COPPA safe-harbor program.
We will email every account holder the full children’s notice before activation opens, and it will replace this section at that time.
Parents, Adults, and Website Visitors
This section covers information about adults: parents who buy a Freckle phone and use the Parent App, and anyone who visits the Website. It does not cover children’s information, which is governed entirely by the Children’s Privacy section.
During the pre-order period the Parent App is not yet available. Right now the only information we collect is what you give us to pre-order and what the Website collects automatically. The rest of this section describes how we will handle your information once the Parent App and the phone service are live.
What we collect
- Account and order information: your name, email address, phone number, shipping address, and the products and plans you buy.
- Payment information: our online store runs on Shopify, and your payment card details are collected and processed by Shopify Payments. Freckle does not receive or store your full card number. We keep the card type, last four digits, and expiration date so you can recognize the card on file.
- Parent App activity: the settings you choose, the contacts and quests you create, and the notifications you receive.
- Communications: emails, support conversations, survey responses, and anything you post in Freckle communities or send us as a testimonial.
- Referral and creator program information: if you take part in a referral or ambassador program, the information needed to run it.
When you visit the Website or use the Services, we may automatically collect:
- Log files: technical information collected automatically from your browser:
- IP address
- Device and browser type
- Approximate location (city or region, estimated from your IP address)
- Pages visited, links clicked, and how you use the Website
- Date and time of your visit
- Referring page (for example, a search engine or social media platform)
- Pixels and web beacons: small graphics with a unique identifier that work like cookies. We use pixels to measure Website visits, ad performance, and usage. Pixels can record:
- Links clicked
- Pages visited
- Interactions with our marketing
Cookies, pixels, and analytics
The Website uses:
- Strictly necessary cookies that make the Website and checkout work.
- Analytics: Google Analytics, to understand how the Website is used. We do not use Google Analytics’ advertising features.
- Advertising pixels: pixels from third parties, including Meta, each of which sets a cookie and records the pages you visit so we can measure our ads and show Freckle ads to people who have visited the Website. Each provider’s own privacy policy governs what it does with that data.
You can opt out of these pixels and any other sharing through the “Your Privacy Choices” link in the footer, by enabling Global Privacy Control in your browser (which we honor automatically), or through your browser’s cookie settings. Opting out does not affect your account or your child’s phone. No cookies, pixels, or trackers of any kind run on the Freckle phone or in the Parent App.
How we use it
We use your information for the following purposes:
- Provide products and services: sell, ship, activate, and support the Freckle phone and service, run the Parent App, and bill you
- Market and advertise: send you marketing about Freckle if you have not opted out, and show Freckle ads to people who have visited the Website
- Improve your experience: understand how the Website and Services are used so we can improve them
- Prevent fraud and maintain security: detect and prevent fraud, abuse, and other harmful activity
- Communicate with you: send you service messages (activation, billing, safety alerts, security notices) and respond to your support requests
- Legal compliance: comply with applicable laws, regulations, legal process, and court orders
Who we share it with
Service providers who help us run the business, under contracts that limit their use of your information to our instructions: payment processing (Shopify Payments), website hosting, analytics (Google Analytics), shipping and fulfillment, email and SMS delivery, customer support tools, and professional advisers. We also share information when required by law or to protect safety or security, and if Freckle is acquired or merges with another company, in which case your information may transfer to the new owner, who must honor this policy.
We do not sell your personal information. The Website uses advertising pixels from third parties, including Meta, to measure our advertising and reach people who have visited the Website (see Cookies, pixels, and analytics). Under California law and some other state laws, this counts as “sharing” personal information for cross-context behavioral advertising, and you can opt out at any time using the “Your Privacy Choices” link in the Website footer (shown to residents of states that grant this right) or by turning on Global Privacy Control in your browser. These pixels run only on the marketing pages of the Website. They do not run in the Parent App, on the Freckle phone, in the account or activation flow, or on any page where a child’s information is collected, and they never receive any information about a child.
Marketing choices
You can opt out of marketing emails using the unsubscribe link in any email, and out of marketing texts by replying STOP. We will still send you service messages about your account and your child’s phone.
Your privacy rights
Depending on where you live, you may have the right to access, correct, delete, or download your personal information, to opt out of its sharing for cross-context behavioral advertising (see Who we share it with and Cookies, pixels, and analytics), and not to be discriminated against for exercising these rights. Residents of California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, New Jersey, and other states with comprehensive privacy laws may exercise these rights by contacting us at privacy@freckle.tech. We will verify your identity before responding, and we will respond within 45 days (or sooner where the law requires). You may appeal a decision by replying to our response.
California residents. We share internet activity (pages visited on the Website) and identifiers (cookie ID, IP address) with third parties, including Meta, for cross-context behavioral advertising. We do not sell personal information. We do not knowingly sell or share the personal information of anyone under 16.
New York residents. The New York Child Data Protection Act applies to information about users under 18. Because we treat every Freckle phone user as a child under 13 and comply with COPPA for all of them, our practices meet that law’s requirements for children’s information.
How long we keep it
We keep your personal information only for as long as we need it for the purposes described in this section, or longer where the law requires it. For example, tax and accounting rules require us to hold order and payment records.
When deciding how long that is, we weigh how much information it is and how sensitive it is, what could happen if it were used or disclosed without authorization, why we collected it and whether we could achieve the same thing with less, and what the law requires.
Once we no longer need it, we delete or anonymize it.
General
Security
We protect your personal information with encryption in transit, access limited to staff who need it to do their jobs, and contracts that require our service providers to safeguard your information. If we discover that your personal information has been accessed without authorization, we will notify you promptly and as required by law.
Where we operate
Freckle sells and supports the phone in the United States, and all personal information is stored in the United States. If you use the Services from outside the United States, you are sending your information to the United States.
Changes to this policy
We will post any changes here and update the “Last updated” date. If a change affects how we collect, use, or share children’s information in a material way, we will notify parents by email and in the Parent App before the change takes effect, and where COPPA requires it, we will ask for fresh consent. Continued use of the Services after the notice period means you accept the change; if you do not, you can delete your account.
Contact us
If you have questions or concerns about this Privacy Policy, or want to exercise any right it describes, please contact:
Freckle Technologies, Inc.
131 Continental Dr
Newark, DE 19713
FOR ANY QUESTIONS CONTACT: privacy@freckle.tech