MiFamilias Privacy Policy

Introduction

MiFamilias ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services (collectively, the "Service").

Please read this Privacy Policy carefully. By using the Service, you agree to the collection and use of information in accordance with this policy.

Information We Collect

Information You Provide

Information Collected Automatically

Information from Third Parties

We may receive information from:

• Authentication providers: When you sign in via Apple or Google
• Family members: When they add you to a family group

How We Use Your Information

Primary Uses

1. Provide the Service

• Create and manage your account
• Enable video recording and time capsules
• Facilitate family group connections
• Process and store your content

1. Communication

• Send time capsule unlock notifications
• Family activity alerts
• Family Alert notifications
• Service announcements

1. Safety and Security

• Verify user identity
• Detect and prevent fraud
• Enforce our Terms of Service
• Protect users from harmful content

We Do NOT

• Sell your personal information
• Share your content with advertisers
• Use your content to train AI models
• Access your locked time capsules before unlock dates
• Share your information with unrelated third parties

Data Sharing

Within the App

Service Providers

We use trusted third-party services:

Where Your Data Is Stored

Your data is stored and processed in Singapore (AWS Asia Pacific region ap-southeast-1).

This means that if you use MiFamilias from another country — including the Philippines, where our current pilot runs — your personal information is transferred outside your country of residence and processed in Singapore.

We remain responsible for your information wherever it is processed:

• All data is encrypted in transit (TLS) and at rest.
• AWS acts as our processor (sub-processor) under contractual terms that

require it to protect your information and to process it only on our instructions.

• Transfers are made on the basis of your consent to these terms and the

contractual safeguards above.

• Your rights described in Your Rights below apply regardless of where your

data is physically stored.

For users in the Philippines: this constitutes notice of cross-border transfer under the Data Privacy Act of 2012 (Republic Act No. 10173). We remain accountable for personal information transferred to Singapore for processing.

For users in the EU/UK: transfers outside the EEA/UK are made under appropriate safeguards, including AWS's Standard Contractual Clauses.

If you have questions about where your data is held, contact us using the details in the Contact Us section.

Legal Requirements

We may disclose information:

• To comply with legal obligations
• To respond to lawful requests from authorities
• To protect our rights and safety
• To protect users from harm

Data Retention

Time Capsule Special Handling

Time capsules are designed for long-term storage (potentially decades). By creating a time capsule, you consent to extended storage until the unlock date.

Your Rights

All Users

You have the right to:

• Access: Request a copy of your data
• Correction: Update inaccurate information
• Deletion: Delete your account and data
• Portability: Export your data
• Withdraw consent: Opt out of optional processing

EU/UK Users (GDPR)

Additional rights:

• Object to processing based on legitimate interest
• Restrict processing in certain circumstances
• Lodge a complaint with a supervisory authority

California Users (CCPA)

Additional rights:

• Know what personal information is collected
• Know if personal information is sold or disclosed
• Say no to the sale of personal information
• Non-discrimination for exercising privacy rights

To Exercise Your Rights

Contact us at: privacy@mifamilias.com

Or use in-app settings: Settings → Privacy → Data Rights

Children's Privacy

Age Requirements

• Users must be 13 years or older (16 in EU)
• Users under 18 require guardian consent
• Guardian approval required for family membership

COPPA Compliance

We do not knowingly collect information from children under 13. If we discover such collection, we will delete the information immediately.

Guardian Controls

Guardians can:

• Approve/deny family membership requests
• Monitor their minor's family connections
• Request data deletion for their minor

Data Security

Technical Measures

• Encryption in transit (TLS 1.3)
• Encryption at rest (AES-256)
• Secure authentication (Cognito)
• Regular security audits

Organizational Measures

• Employee access controls
• Security training
• Incident response procedures
• Privacy by design principles

Time Capsule Security

Locked time capsules:

• Encrypted with unique keys
• Not accessible until unlock date
• Not accessible to MiFamilias staff
• Decryption keys released only at unlock time

International Transfers

Your data may be processed in:

• Singapore (primary hosting)
• Other AWS regions (backup/redundancy)

We ensure adequate protection through:

• Standard Contractual Clauses
• AWS compliance certifications
• Data Processing Agreements

Cookies and Tracking

Mobile App

The mobile app does not use cookies but may use:

• Local storage for preferences
• Session tokens for authentication
• Analytics SDKs (can be disabled)

Website

Our website uses:

• Essential cookies (required for function)
• Analytics cookies (with consent)

Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of significant changes via:

• In-app notification
• Email notification
• Updated "Last Updated" date

Continued use after changes constitutes acceptance.

Contact Us

MiFamilias is in closed beta and is not yet operated by an incorporated company. It is run by its founder, and there is therefore no registered business address to publish and no corporate entity standing behind it. We would rather tell you that than print an address that does not exist. When the operating company is formed, this section will name it, and we will say so through the app before the change takes effect.

Data Controller: the founder of MiFamilias, contactable at the address below.

Privacy questions, and all requests about your data:

• Email: privacy@mifamilias.com

Every right described above — access, correction, deletion, export and withdrawal of consent — can be exercised at that address, or from Settings → Privacy in the app. Not having a company does not reduce those rights, and we answer to the same rules either way.

Data Protection Officer:

• No DPO is appointed. The beta is small enough that it does not meet the threshold for a mandatory appointment, and a named officer we could not staff would be worse than none.

EU Representative:

• None appointed, because the Service is not offered in the EU or UK during the beta. The pilot is limited to invited testers, currently in the Philippines. A representative will be appointed before the Service is made available to anyone in the EU or UK, and the GDPR rights set out above are honoured for any user who reaches us in the meantime.

Additional Information

Analytics and Advertising

• We use anonymized analytics to improve the app
• We may show family-appropriate advertisements
• You can opt out of personalized ads in Settings

Push Notifications

• Required for time capsule unlocks
• Required for Family Alerts
• Other notifications can be customized

Biometric Data

• We do not collect fingerprints or face scans
• Profile photo matching is optional and uses AWS services

This Privacy Policy is available at: https://www.mifamilias.com/privacy

See also our Terms of Service, which cover the closed beta.

© MiFamilias. Questions about this policy? Contact us through the app or at the email address above.