Children’s Privacy & Safety

A family memory app is, in practice, full of pictures of children. That is the point of it. This page sets out how Heirloom Journey handles children’s information, the difference between a child using Heirloom and a child appearing in it, and what a parent or guardian can ask us to do.

1. Minimum age

Heirloom is not directed to children under 13 and you must be at least 13 to create an account. Where local law sets a higher age for consent to data processing — for example 16 in parts of the EEA — that higher age applies, and a person below it may use the Service only with the consent of a parent or guardian who holds or supervises the account.

We do not knowingly collect personal information from a child under 13 as an account holder. If we learn that we have, we delete the account and its information promptly.

2. Children who appear in memories

This is the ordinary case, and it works differently from a child having an account.

• Photographs, videos and recordings of a child are uploaded by an adult account holder — a parent, grandparent or another family member.
• That adult is responsible for having the right to upload and share that content, and for having the consent of the child’s parent or guardian where they are not one themselves.
• We treat that content as the account holder’s content. We do not build a profile of the child, do not attempt to identify them, do not use facial recognition to tag them, and do not use the content for advertising or to train models.
• The content is visible only to the members of the journey or vault it was added to, and content in a private Vault is visible only to the account holder.

3. COPPA (United States)

Heirloom is a general-audience service not directed to children under 13, and we do not knowingly collect personal information online from children under 13 as users. We do not serve behavioural advertising, do not operate a public profile or messaging system that a child could use to communicate with strangers, and do not disclose children’s information to third parties for their own purposes.

If you are a parent or guardian and believe a child under 13 has created an account or that we hold personal information about your child that you want removed, contact privacy@heirloom.setrick.com. We will verify your relationship to the child, delete the information, and confirm when it is done.

4. UK and EU children’s data

Where the UK or EU GDPR applies, children’s personal information receives specific protection. Our approach follows the UK ICO’s Age Appropriate Design Code in the respects relevant to a service of this kind:

• Privacy by default. Nothing is public. There is no discoverable profile, no follower mechanic and no public sharing surface at all.
• Data minimisation. We collect no location data, no contacts, and no advertising identifiers.
• No nudge techniques. There are no streaks, no engagement rewards and no notifications designed to pull someone back into the app.
• No profiling. Children’s content is not used for profiling or automated decision-making.
• No detrimental use. We do not use children’s data in ways shown to be detrimental to their wellbeing.

5. Parental and guardian rights

A parent or legal guardian may ask us to:

• tell them what personal information we hold relating to their child;
• correct information that is inaccurate;
• delete their child’s information from our systems;
• stop any further collection or use of it.

Send the request to privacy@heirloom.setrick.com with enough detail to identify the content or account concerned. We will ask for reasonable verification that you are the child’s parent or guardian — this protects the child — and will respond within 30 days.

One limitation, stated plainly. Where a photograph of a child was uploaded by an adult family member to a shared journey, we can remove it from our systems on request. We cannot recover copies that other members of that journey may already have downloaded to their own devices. No service can.

6. Safety

Heirloom has no public feed, no stranger messaging, no discovery and no follower system. A person can only see content in a family, journey or shared vault they were explicitly invited to by a member. There is no mechanism by which an unknown adult can contact a child through the Service.

Child sexual abuse material is reported to the relevant authorities and the account terminated, without exception and without prior notice.

7. For adults managing a family space

• Check who is in a journey, from its ••• menu, before adding photographs of a child.
• Use your private Vault for anything you are not certain you want other family members to see.
• Remember that removing someone from a journey stops future access but does not recall what they already saw or saved.
• As children grow up, consider asking them how they feel about what is stored, and use the deletion controls if they would rather something were not kept.

8. Contact

Questions or requests about children’s information: privacy@heirloom.setrick.com. See also the Privacy Policy and Delete your data.