Privacy policy.

Plain English summary: LaLa helps parents and caregivers with baby sleep coaching. By default, sleep data is stored locally on your device and anonymised sleep logs are stored in our cloud only if you enable backup. We do not store a child’s real name or date of birth on our servers unless you give separate, explicit consent to send that information to our AI provider (OpenAI) to generate a personalised sleep plan. Subscriptions are handled via Apple (RevenueCat). If you accidentally share personal information in free-text chat, contact us and we’ll help remove it.

1. Who we are / Data controller

Controller: Rest Tech Ltd
Registered address: 12 Laurel Gardens, TW4 6AQ, UK
Contact (privacy & data requests): contact@lala-sleepcoach.com

2. Scope & key principles

LaLa is designed for adults (18+) caring for children. We follow privacy-by-default and data-minimisation principles: we collect only what is necessary, keep sensitive processing to a minimum, and require explicit, unbundled consent for processing that is not strictly necessary (notably sending a child’s name and DOB to OpenAI).

3. What data we collect & why

Data you provide directly

  • Account / device info: email (if you create an account) or device identifier, device type, app version — used to operate your account and provide support. (Lawful basis: performance of contract / necessary for service.)

  • Sleep data: bedtime, nap times, sleep events, parent stress score, short notes. By default this is stored locally in the app (AppState). If you enable cloud backup, anonymised sleep logs are stored in Firestore. (Lawful basis: performance of contract / legitimate interest for core service.)

  • Consent for AI plan generation: if you request a personalised plan, you may be asked to provide a child’s name and date of birth. We will only send name + DOB to our AI provider if you give explicit, separate consent. (Lawful basis for that transfer: explicit consent.)

  • Free-text chat messages: anything you type into chat may be processed to generate replies. Do not enter sensitive personal or medical details into chat unless you want them processed. (Lawful basis: consent / performance of service depending on context.)

Data collected automatically

  • Usage & analytics: coarse app events (e.g., “plan_generated”, “session_start”) to improve the product. We endeavour to avoid including sleep detail values in analytics. You may opt out of analytics where the app provides that option. (Lawful basis: legitimate interests; you can object.)

  • Crash and error logs: technical data to diagnose issues; we filter or block logs that contain chat transcripts where possible.

Data we do not collect (unless you opt in)

  • Photos or audio uploads of your child are not collected at launch. If we add uploads later, separate consent and controls will be required.

4. How we use your data (purposes)

We use data to:

  • Provide and operate the App, account management and subscription features. (Performance of contract.)

  • Generate personalised sleep plans using AI when you request them and explicitly consent to sending name + DOB to OpenAI. (Explicit consent required.)

  • Store anonymised sleep logs (if cloud backup enabled) to allow device restore and to provide aggregated product improvements. (Performance of contract / legitimate interests.)

  • Process payments and subscriptions via Apple/RevenueCat. (Performance of contract.)

  • Improve the app via aggregated analytics and debugging. (Legitimate interests; opt-out available.)

  • Comply with legal obligations and respond to lawful requests. (Legal obligation.)

5. Lawful bases for processing

  • Performance of a contract: account provisioning, subscription management, delivering core services.

  • Explicit consent: for sending child name and date of birth to OpenAI and for optional features like cloud backup if you must opt in. Consent is unbundled, specific, recorded and revocable.

  • Legitimate interests: product analytics, fraud prevention and security, where those interests are balanced against your rights.

6. Third parties & processors

We use the following processors and have contractual safeguards (DPAs) in place:

  • OpenAI — AI provider. Only with your explicit consent will we send a child’s name + DOB and an anonymised sleep summary/prompt to OpenAI. We will seek contractual limits on retention and use for training where possible.

  • Firebase / Google Cloud — Firestore and hosting for anonymised sleep logs (when cloud backup is enabled), authentication and system logs.

  • RevenueCat & Apple — billing, subscription management and receipts (handled through Apple’s in-app purchase system). We do not process card payments directly.

  • Analytics & crash reporting providers (if enabled) — for product performance and debugging. We will filter or avoid logging chat transcripts; analytics can be disabled where possible.

We keep signed DPAs and transfer documentation in our internal compliance folder.

7. Special rules for sending child name & DOB to OpenAI (explicit consent)

We will only send a child’s name and DOB to OpenAI after you provide explicit, unbundled consent via a consent checkbox that is unchecked by default. When you give consent we will:

  1. Record a consent record including: user/device id, consentTextVersion, timestamp, consent method (modal/login-checkbox), and a revocation flag. We will not store the child’s name/DOB in the consent record.

  2. Use a backend proxy that enforces PII-scrubbing and minimisation before sending any content to OpenAI; where possible we will send derived values (e.g., age-in-months or age-bucket) rather than raw DOB.

  3. Use our contractual protections with OpenAI to limit retention and prevent use for model training where contractually possible.

  4. Allow you to withdraw consent at any time via Settings → Data & Privacy or by emailing contact@lala-sleepcoach.com. If you withdraw consent we will stop future sending and initiate deletion steps (see Section 9).

Warning: free-text chat is user-supplied; even with warnings a user may type PII. We provide PII detection and prompts, but we cannot guarantee every instance will be caught. If you accidentally send PII, contact us immediately.

8. Anonymisation & Firestore storage

  • Sleep logs stored in Firestore are anonymised: direct identifiers are removed and a one-way pseudonymous key is used only if cross-device restore is required (that key is stored separately and encrypted).

  • Subscription/billing metadata (RevenueCat/Apple) is stored separately and not linked directly to sleep logs to reduce re-identification risk.

9. Deletion, retention & OpenAI removal requests

Retention defaults (current)

  • Consent records: retained for audit — 7 years.

  • Anonymised sleep logs (cloud backup enabled): retained for 3 years unless you request earlier deletion.

  • Subscription & billing metadata: retained for 7 years for accounting and tax reasons.

  • Support logs, crash logs: retained for up to 1 year.

How to delete your data

  • Local data: use Settings → Data & Privacy → Clear local data to remove AppState data from the device.

  • Cloud data: submit a deletion request in-app or email contact@lala-sleepcoach.com with your account/device id. We will acknowledge within 5 business days and aim to complete deletion from our systems within 30 days where feasible.

  • OpenAI: upon deletion or withdrawal of consent we will request deletion from OpenAI under our contractual process and confirm when we have done so. The effectiveness and timing depend on OpenAI’s contractual and technical processes; we will act promptly and provide references for our requests.

10. International transfers

Our processors may store or process data outside your jurisdiction (including the United States). Where necessary we use standard contractual clauses, UK addenda or other approved mechanisms to protect transfers. Details are available in our DPAs with those providers.

11. Your rights

You may, subject to applicable law:

  • access the personal data we hold about you;

  • request rectification of inaccurate data;

  • request erasure (right to be forgotten) — subject to legal exceptions;

  • restrict processing in certain circumstances;

  • object to processing based on legitimate interests (e.g., analytics);

  • obtain a machine-readable copy of personal data you provided (data portability) where applicable;

  • withdraw consent at any time (withdrawal does not make prior processing unlawful).

To exercise rights: Settings → Data & Privacy → Request data / Delete account, or email contact@lala-sleepcoach.com. We will respond within statutory time limits (typically one month; complex cases may take up to three months with notice).

If you are in the UK/EU and believe we have not complied, you may lodge a complaint with your supervisory authority (in the UK: the ICO).

12. Security

We use industry-standard measures, including:

  • TLS for data in transit;

  • encryption at rest where possible (Google Cloud encryption);

  • secure secret management for API keys;

  • role-based access controls and least privilege for staff;

  • regular security reviews and patching.

No system is 100% secure. In the event of a notifiable personal-data breach we will follow legal obligations, including notifying the supervisory authority and affected individuals where required.

13. Analytics, cookies & marketing

  • Analytics: aggregated and pseudonymised metrics help us improve LaLa. We do not intentionally include chat transcripts or PII in analytics. You may opt out in Settings where that option is offered.

  • Cookies: our website uses cookies; a cookie banner explains options and preferences.

We will not use your child’s data for advertising or behavioural profiling targeted at children.

14. Children & the Age-Appropriate Design Code

Although LaLa is used by adult caregivers, it concerns children and may be regarded as “likely to be accessed by children.” We follow the ICO’s Age-Appropriate Design Code principles: minimise collection, avoid profiling and behavioural advertising directed at children, enforce privacy-by-default, and document safeguards in our DPIA and internal records.

15. Changes to this policy

We may update this Privacy Policy for legal, technical or business reasons. We will notify you in-app and/or by email where appropriate. Continued use after notification constitutes acceptance of the updated policy.

16. Contact & complaints

Data protection contact: contact@lala-sleepcoach.com
If you remain unsatisfied you may contact your supervisory authority (in the UK: Information Commissioner’s Office).

17. Practical tips for users

  • Prefer a nickname when asked for a child’s name for AI plan generation to reduce risk.

  • Do not enter sensitive personal, medical or identifying information into free-text chat. If you accidentally do so, contact contact@lala-sleepcoach.com immediately with the approximate time and device id.

  • For maximum privacy keep cloud backup disabled — sleep data will then remain on your device only.

18. Record of processing & DPIA

We maintain a record of processing activities and have completed a Data Protection Impact Assessment (DPIA) for LaLa due to its focus on children and use of automated AI. The DPIA documents risks and mitigations and is available to regulators on request.