US Privacy Policy
NODI Privacy Policy (United States)
Version 1.0, effective July 30, 2026 · Applies to us.nodi.kids, the NODI App, and the NODI Flip for customers in the United States.
The essentials in one page
NODI is built so that we know as little about your family as possible.
- Your child never creates an account. Parents and legal guardians are the only account holders. Child profiles (first name, optional photo) are created by you inside your account after you give verifiable parental consent.
- Voice messages are private. Encrypted in transit and at rest, delivered only between contacts you approve, and automatically deleted from our servers after at most 30 days. We never listen to, analyze, transcribe, or monetize voice content. You cannot listen to your child’s messages through the app either; playback happens only on the Flip.
- The Flip is not a surveillance device. No camera, no GPS, no always-on microphone. Recording happens only when actively started and is clearly shown on the display.
- We do not sell or share personal information, we do not use children’s data for advertising or profiling, and we show children no ads. This has been true for the preceding 12 months and will stay true.
- Maximum privacy by default. Every optional data use is off until you turn it on.
- Your data is hosted on EU-based infrastructure with strict access controls.
Questions: help@nodi.kids. Full details below, including our Children’s Privacy Notice (Section 3), which is our primary notice under the Children’s Online Privacy Protection Act (COPPA).
1. Who we are
NoDi GmbH, c/o Betahaus, Rudi-Dutschke-Straße 23, 10969 Berlin, Germany (“NODI”, “we”). NODI is the operator collecting and maintaining personal information through the NODI service. Contact: help@nodi.kids; postal contact at the address above.
2. Scope
This policy covers the us.nodi.kids web shop, the NODI App (iOS/Android), the NODI Flip device (WiFi and WiFi + LTE), and related services for US customers. The NODI service is directed to children within the meaning of COPPA: the Flip is designed for children ages 5 to 12. Accordingly, Section 3 (Children’s Privacy Notice) governs all personal information collected from children and is written to satisfy 16 C.F.R. Part 312 as amended (compliance date April 22, 2026).
3. Children’s Privacy Notice (COPPA)
3.1 Operator
The sole operator collecting or maintaining children’s personal information through the service is NoDi GmbH (contact details in Section 1). No other operator collects personal information from children through the NODI service.
3.2 What we collect from children, and how
The child does not register, has no account, and is never asked by us to provide information about themselves. The personal information relating to a child that the service processes is:
| Information | Source | Purpose |
|---|---|---|
| First name and optional photo | Entered by the parent when creating the child profile | Identifying the Flip and its messages to approved contacts |
| Voice recordings (audio files of the child’s voice) | Created when the child actively records a message on the Flip | Delivering the message to the contact chosen from the parent-approved list |
| Device identifiers and technical telemetry (device ID, firmware version, connectivity status) | Generated by the Flip | Operating, securing and updating the device |
We do not collect from children: precise geolocation (the Flip has no GPS), photos or videos taken by the child (no camera), browsing or search history, contact lists from any phone, or any biometric identifiers. We do not create voiceprints or use voice recordings to identify anyone; audio is processed solely to deliver messages. We do not rely on the COPPA audio-file exception; instead, voice messages are collected with verifiable parental consent and deleted under the retention policy in Section 3.6.
We do not condition a child’s participation on disclosing more information than is reasonably necessary to use the service.
One practical transparency note: the Flip plays messages out loud through its speaker, so people near the device may overhear a message, just as with a walkie-talkie. We recommend encouraging children not to include sensitive information in voice messages.
3.3 How we use children’s personal information
Solely to provide the service: delivering voice messages between the child and parent-approved contacts, operating and securing the device, and support at the parent’s request. Never for marketing, advertising (contextual or behavioral), profiling, or sale. We use no persistent identifiers from children for any purpose other than support for the internal operations of the service.
3.4 Disclosure of children’s personal information
We disclose children’s personal information only to: (a) the contacts the parent has approved (voice messages are delivered to the recipients you choose, including guest contacts such as grandparents and, for Flip-to-Flip messaging, the other child’s family, which requires approval by the parents of both children); and (b) service providers that process data on our behalf to run the service, listed in Section 5, bound by contracts limiting their use of the data to providing services to us. We do not disclose children’s personal information to third parties for advertising, marketing, AI training, or any other independent use. Because we make no such third-party disclosures, the separate parental consent that the amended COPPA Rule requires for disclosures to third parties is not applicable; if our practices ever changed, we would seek that separate verifiable consent first.
3.5 Verifiable parental consent
Before a child profile can be created and before any collection of children’s personal information begins, we provide the parent a direct notice and obtain verifiable parental consent in the NODI App. The parent may give consent to collection and use without consenting to any optional feature. Consent can be withdrawn at any time by deleting the child profile.
3.6 Children’s data retention policy (published pursuant to 16 C.F.R. § 312.10)
We retain children’s personal information only as long as reasonably necessary for the specific purpose for which it was collected, and never indefinitely:
| Data | Retention |
|---|---|
| Voice messages (server) | Maximum 30 days from recording, then automatic deletion; undelivered messages from a removed contact are deleted immediately |
| Voice messages (receiving Flip, local) | Last 50 messages, until manually deleted or factory reset |
| Child profile (first name, photo) | Until the parent deletes the profile or account: immediate, permanent deletion |
| Device telemetry | Deleted when the device is removed from the app |
| Support tickets involving children’s data | 6 months after closure |
Deletion is performed with reasonable measures protecting against unauthorized access during disposal. This written retention policy is reviewed at least annually.
3.7 Parents’ rights
At any time, you can: review the child’s personal information we hold (visible directly in the app: profile data and message metadata; full access requests via help@nodi.kids), delete it (deleting the profile erases all of the child’s data immediately and permanently), refuse to permit further collection or use (same mechanism, or contact us), and do all of this without charge. We will verify that you are the child’s parent before acting on requests made outside the app. Exercising these rights may mean the service can no longer be provided to the child’s device.
4. Information we collect from parents and adult users
Account data (email address, display name, role, language; passwordless login with sign-in links), purchase data (name, addresses, email, order details; payment processed by Shopify Payments/Stripe, we store no card numbers), LTE subscription data, support communications (Gorgias, US/EU; AI assistance by Anthropic with content generally pseudonymized, never used to train AI models), marketing email only with your opt-in (off by default; unsubscribe in every email; CAN-SPAM compliant), post-purchase review requests (you can opt out at collection and in every email), website analytics and advertising cookies only with your consent (Section 7), and opt-in app usage analytics (Firebase, EU region, 14-month retention, never containing child profile data). Server and access logs are kept for about 12 months for security.
5. Service providers
Google Cloud/Firebase (backend, EU); Stripe (payments/subscriptions, US); Shopify (shop, EU storage with US/Canada transfers); ShipBob (US fulfillment) and the carriers it uses (name, delivery address, email for delivery notifications; no phone number); Klaviyo (email, US); Gorgias (support, US/EU); Anthropic (AI support assistance, US); Spotify (track IDs only); Cloudflare (CDN/security); Apple/Google (push notifications; app stores process install/crash data as independent businesses); Giesecke+Devrient Mobile Security TCD Iberia (LTE connectivity, device identifiers and network data only); consent-gated website tools (Google Analytics 4, Microsoft Clarity, Meta Pixel, Google Ads, Tracklution, Klar Insights); Schutzwerk (security testing). All providers processing personal information for us are contractually limited to providing services to us.
6. US state privacy disclosures
We do not sell personal information and we do not share it for cross-context behavioral advertising, and we have not done either in the preceding 12 months. This applies to everyone and, emphatically, to children’s data; consequently there is no “Do Not Sell or Share” choice to exercise, because there is nothing to opt out of. We do not use or disclose sensitive personal information for purposes requiring a right to limit. We do not discriminate against anyone for exercising privacy rights.
Applicability note: NoDi GmbH currently does not meet the thresholds that make comprehensive state privacy laws such as the California Consumer Privacy Act (as amended by the CPRA) applicable (annual revenue and consumer-volume thresholds). We nonetheless voluntarily extend the core rights of access, correction, deletion, and portability to all US residents, exercisable via help@nodi.kids with identity verification, answered within 45 days. We will adopt full statutory compliance, including any required notices and metrics, when we meet an applicable threshold.
New York (Child Data Protection Act): for users under 13, our COPPA compliance described in Section 3 constitutes compliance with the NY CDPA’s consent requirements; we process minors’ data only as strictly necessary for the service the parent requested or with the consent described above, and we do not sell minors’ data.
California “Do Not Track” disclosure (CalOPPA): our website responds to consent signals through our cookie banner; like most sites, it does not respond to browser Do Not Track signals, but honors the Global Privacy Control where legally required. Third parties do not collect personal information about your online activities over time and across different websites through our service except for the consent-gated advertising tools listed in Section 7, which operate only after you opt in.
7. Cookies and website tracking
us.nodi.kids uses the consent tool Pandectes. Non-essential cookies (analytics: Google Analytics 4, Microsoft Clarity, Shopify Analytics; advertising/attribution: Meta Pixel, Google Ads, Klaviyo, Tracklution, Klar Insights) are set only after you opt in; “Reject all” is as prominent as “Accept all,” and a persistent “Cookie settings” control lets you change your choice at any time. The complete, current cookie table is generated dynamically by Pandectes. Bot protection (Cloudflare Turnstile, hCaptcha, and Google reCAPTCHA in our support contact form) processes technical connection data to distinguish humans from bots. No tracking is directed at children; the NODI App and the Flip contain no advertising or tracking technologies, and there are no child-directed pages on nodi.kids.
8. Data security
Encryption in transit (TLS) and at rest (AES-256 for voice content); passwordless authentication without default passwords; signed over-the-air updates; remote wipe and factory reset; technical access to stored audio restricted to the managing directors and CTO, only in justified sensitive cases after your prior confirmation, with auditable access logging; certification under EN 18031 and an independent security assessment of device and app (Schutzwerk, April 2026); security updates guaranteed for at least five years from purchase; a written information security program covering children’s personal information with a designated coordinator. Report vulnerabilities to development@nodi.kids (see our Vulnerability Disclosure Policy).
9. Retention (all users)
Voice messages: Section 3.6. Accounts: life of the account, immediate deletion on request, inactive accounts deleted after 24 months (warning plus 30 days). Support tickets: 24 months (6 months where children’s data is involved). Order and tax records: statutory retention periods. Logs: 12 months. Consent records: duration of processing plus limitation periods.
10. Changes; contact
We will notify you of material changes in advance by email and/or prominently in the app, and, where the changes concern children’s personal information practices in ways that require it, we will obtain fresh verifiable parental consent before they apply to your child. The current version is always available at us.nodi.kids/privacy. Contact: help@nodi.kids, or NoDi GmbH, c/o Betahaus, Rudi-Dutschke-Straße 23, 10969 Berlin, Germany.
Annex: NODI explained for kids
What happens to your voice messages? When you record a message on your NODI Flip, we send it, safely wrapped up, to the person it is meant for, like Mom, Dad, Grandma or Grandpa. Only people your parents have chosen can send you messages or hear yours.
Does NODI listen to your messages? No. We do not listen, we do not read along, and we never sell anything about you. After 30 days at the latest, our computers delete your messages from our servers automatically.
Is your Flip always listening? No. Your Flip records only while you are recording, and the display shows “Recording…” the whole time. There is no hidden microphone, no camera and no tracking.
What do we know about you? Very little: only what your parents typed in, your first name and, if they want, a picture. Your parents can delete that any time.