Last updated: [Oct 1, 2025]
Applies to: Jumpo AI Camera provided by Azores Labs (collectively “we”, “our”, or “us”).

1. Overview / Scope

Azores Labs provides an AI-powered smart camera designed for children, combining playful photo discovery with interactive learning experiences. This Privacy Policy explains how we collect, use, disclose, and retain personal information of children under 13 in the United States, the choices parents have regarding that information, and how parents can provide verifiable consent as required by the Children’s Online Privacy Protection Act (“COPPA”). This Policy applies to information collected by our devices, apps, services, websites, and cloud features (collectively, the “Service”).

2. Our privacy principles

• Minimize collection. We collect only the personal information necessary to operate the Service and provide requested features.
• Secure storage with parental control. Photos and media are stored locally on the camera by default. To enable parental review and management, media is also uploaded securely to our servers and synced with the parent dashboard.
• Parental control and transparency. Parents can manage their child’s use of the Service by binding or unbinding the camera device, viewing and deleting photos, and managing subscriptions for optional services.
• No sale / no targeted advertising to children. We do not sell children’s personal information and we do not use children’s personal information for targeted advertising.

3. Information we collect and why

A. Information collected directly about the child

• Used for local interactive features; uploaded to the cloud only for parental review and management.
• Child audio (voice recordings / short utterances): used to enable voice-interactive features and immediate processing (speech recognition). By default we process transiently and do not retain recordings.

B. Parent Platform

• Used to manage accounts, consent, and subscriptions.

C. Device / connection info

• Device identifiers, ICCID (if eSIM/connected device), connection logs — used for connectivity support, billing and device management.

D. Usage & analytics (non-identifying where possible)

• Crash logs, feature usage metrics — used to improve the Service. We keep usage logs only for short, defined periods (see Section 8).

4. How we use data

We use data to:

1. Provide core features of the Service (object recognition, AI voice chat, art generation, local album).
2. Maintain and troubleshoot devices and connectivity.
3. Comply with legal obligations.
4. We do not use children’s personal information for advertising, cross-site tracking, or sell it to third parties.

5. Optional Features, Parental Controls, and Subscription Consent

All parental management features of the Jumpo AI Camera and Services are automatically enabled when a parent registers an account and binds the device. This includes cloud media storage for viewing and managing photos.

Paid vs Free Features

• Paid Plan: Paid subscribers have access to AI features, unlimited eSIM connectivity, cloud uploads, and cloud storage with a retention period of 30 days.
• Free Plan: Free users can take photos locally on the device, use Wi-Fi, upload photos to the cloud, and access cloud storage with a retention period of 30 days. AI features and eSIM connectivity are not available.

Parental Consent for Data Collection:
By registering and binding the device, parents provide consent for the collection and processing of their child’s photos and media for parental review and management.

Parental Consent Verification (Credit Card Verification):
To comply with COPPA, we verify parental consent through a valid credit card during device registration. Credit card verification is used solely to authenticate that the account holder is an adult and is not used to charge fees unless the parent continues the optional subscription beyond the free trial. Credit card information is processed securely by our authorized payment processor (e.g., Stripe). We do not store full credit card numbers on our servers.

Subscriptions and Auto-Renewal:
Parents may choose to subscribe to optional premium services, such as cloud storage, AI features, and third-party integrations. When a parent activates a new device, a 60-day free trial of the Paid plan is automatically started. Unless cancelled before the end of the free trial, the subscription will automatically renew at $5.99 per month, and the parent’s payment method on file will be charged. Parents can view billing details, update payment methods, or cancel at any time through the Parent Dashboard.

We provide clear notice of the terms of the free trial, automatic renewal, and cancellation process at the point of enrollment as required by applicable laws, including the Federal Trade Commission’s Negative Option Rule and the California Automatic Renewal Law.

Parent Rights:

• View, download, or delete media stored on our servers.
• Delete their account at any time, which will automatically remove all cloud-stored media while keeping local device data unaffected.
• Parents may choose to sync their child’s photos from the parent dashboard to their Google Photos account. Jumpo only has permission to add photos; it cannot view, edit, or delete photos in the parent’s Google Photos library.

6. Third parties and service providers

7. Data retention — our policy

We retain children’s personal information only as long as necessary to provide the Jumpo AI Camera services and comply with legal obligations.

• Cloud-stored photos and media are kept until the parent deletes them or deletes the account. If not deleted, media may be retained for up to 12 months before automatic removal. Local copies on the device are unaffected.
• Voice recordings are processed transiently and not stored by default, unless explicitly enabled by the parent for cloud storage.
• Device and connection information is retained for up to 12 months for billing and technical support.
• Usage and analytics data are anonymized and retained for up to 3 months to improve the Service.

8. Security

We use reasonable administrative, technical, and physical safeguards to protect personal information:

1. Encryption of stored data: Sensitive information, including credentials and user data, is encrypted using AES/CBC/PKCS5Padding with Base64 encoding.
2. Secure transmission: Data transmitted between devices and our servers is encrypted using RSA. Tokens are signed using HMAC-SHA-512 to ensure integrity and authenticity.
3. Password and sensitive data storage: User passwords and other sensitive data are securely stored using BCrypt hashing.

These measures help protect your child’s information from unauthorized access, disclosure, or modification.

9. Data Storage and Processing

All data is processed on servers located in the United States. We take appropriate measures to ensure that personal information is protected at all times.

10. Changes to this policy

We may change this Privacy Policy. For material changes affecting children’s personal information collection or parental consent mechanisms, we will post the new policy and, where required by law, obtain fresh parental consent or provide direct notice.

11. Contact

If you have questions or concerns, please contact our privacy team at:
Azores Labs — Privacy Team
Email: privacy@jumpo.ai
Address: 5405 Morehouse Dr, San Diego, CA 92121-4725