Privacy Policy — LU6OLE

Version 1.5 — of 19 October 2026

In two sentences

LU6OLE protects the phone of a child aged 6 to 15: it closes the apps that their parents have not allowed, puts the phone to sleep at night, and lets the parents adjust all of this from their own phone. It has no account for the child, no advertising and no statistics — the parents, for their part, sign in to their page with their Google or Apple account: it reads neither messages nor the websites visited, and what it sends to the parents' page is limited to the settings, the list of apps on the phone, the state of the protection, the time spent today in each app, the child's requests and, if the parent has turned on the option, the phone's location when a parent asks for it — for thirty minutes at most, with no history, and with a message on the child's phone each time. Its website filter asks Cloudflare for Families whether a website name (for example "example.com") is for adults or dangerous; neither Cloudflare nor LU6OLE keeps a list of them.

1. Who is responsible for your data

Géry ROTSAERT EI, sole trader, trading name SOSBY — LU6OLE is a SOSBY product —, registered under SIRET 399 538 172 00020, 1 quai Maréchal Joffre, 69002 Lyon, France. The publisher's full identity appears in the legal notice.
Contact for any question or request relating to data: contact@lu6ole.app.

2. What is processed, why, and on what basis

LU6OLE is installed by a parent on their child's phone, and set up by them, behind a six-digit code that the child does not know. It is the data of this phone that is covered here.

What stays on the child's phone

Data	Why	What LU6OLE does with it
The parent's code	To protect the settings, the uninstallation and the Android settings that target LU6OLE	Kept as a fingerprint (hash), on the phone only; it never leaves the device
The child's month and year of birth, entered by the parent	To check that LU6OLE suits their age (6 to 15) and, at 15, to stop blocking anything and leave the choice of location to them	Kept on the phone only; they never leave the device (only the fact of being 15 leaves it, so that their parents know). Neither the day of birth nor the child's name is requested
The name of the app in the foreground	To close an app that is not allowed, whose time for the day is used up, or any app at night (except the phone, emergency calls and SOSBY)	Read at the moment the app opens, by the accessibility service (point 3); only its name is read, never its content
The time spent today in each app	To apply the time limits and the day's screen time, and to show it to the child as well as to their parents	Reset every night at midnight; past days are not kept
The texts of the Settings screens and of the app installation screens	To recognise those that target LU6OLE (turning it off, uninstalling it) and to ask for the parent's code	Read on those screens only, at the moment they are displayed, then forgotten; never saved, never sent
The list of launchable apps (name and technical name)	To show them to the parent so that they can choose, and to the child so that they can see what is allowed	Read on the phone; sent to the parents' page (next table)

What leaves the child's phone

Data	Recipient	Why	Legal basis
A randomly generated identifier at the first connection, and a secret, of which the server keeps only the fingerprint (hash)	The LU6OLE service (Cloudflare)	To recognise this phone without ever reading a hardware identifier, a phone number or an account	Performance of the contract (the service requested by the parent)
The settings: allowed apps, time limits, bedtime, the day's screen time, school days; the name the parent gave to the phone	The LU6OLE service, then the linked parents	To adjust the child's phone from the parent's page, and the reverse	Performance of the contract
The list of launchable apps (displayed name, technical name, and whether it is always allowed)	The LU6OLE service, then the linked parents	So that the parent chooses what is allowed	Performance of the contract
The state of the protection: guardian running or not, uninstallation blocked or not, battery unrestricted, website filter on or bypassed, permanent notification displayed, code created, LU6OLE version, time of the last connection	The LU6OLE service, then the linked parents	To warn the parent when the protection stops, with the action to take	Legitimate interest (that the protection wanted by the parent holds)
The time spent today in the apps where the child has spent at least one minute (twenty at most)	The LU6OLE service, then the linked parents	So that the parent sees the same figure as the child, as parental control tools allow	Performance of the contract
The child's requests: to open a blocked app, to install one (the name they typed), or for more time; then the answer, the name the answering parent has given themselves ("Dad", "Granny"…) and the note they wrote	The LU6OLE service, then the linked parents; the answer comes back to the child	So that the child can ask, and their parents answer	Performance of the contract
The phone's precise location, its accuracy in metres, the time of the reading and the phone's battery level — only if the parent has turned on the "Locate" option on the child's phone, and only when a linked parent asks for it from their page	The LU6OLE service, then the parent who requested it (and the other linked parents)	To know where the child is, as parental control tools allow (the battery shows whether their phone is about to switch off). The phone sends its location every thirty seconds for thirty minutes at most; the child sees "Dad is looking at where you are, until 6:30 PM" for as long as it lasts	Performance of the contract; the option, Android's location permission and its use in the background are granted by the parent, and can be withdrawn at any time
Notification token (Firebase Cloud Messaging) of the child's phone	Google (Firebase), then the LU6OLE service	To alert the phone immediately when a parent changes a setting, answers a request or asks where it is, without waiting for its next connection. The message contains only a "look at your page" signal, never any content	Performance of the contract
The licence: the LU6OLE version, the fingerprint of the certificate that signed the app, a Play Integrity token and, after a purchase, the Google Play purchase token and order number; with them, the phone's randomly drawn identifier	Google Play, then the LU6OLE service	Count the fifteen days of trial and the seven days of grace, check the purchase with Google (three phones at most per purchase) and refuse a modified copy of the app. Nothing about the child or what they do	Performance of the contract
The names of the websites requested by the phone's apps (for example "example.com"), never the full address of a page or its content — only if the parent has turned on the website filter	Cloudflare for Families (1.1.1.3 resolver), directly from the phone, without going through the LU6OLE service	To know whether the site is for adults or dangerous, and to block it. LU6OLE neither keeps nor sends the list of sites; Cloudflare undertakes not to keep the IP address of the query and to erase its logs within 25 hours	Performance of the contract (the filter is turned on by the parent, after a screen that explains it)
IP address and technical connection information	Cloudflare	To route the exchanges, limit code attempts (point 4), protect the service against abuse	Legitimate interest
Google Play's age signal: if it is shared, the age range (for example "9 to 12 years"), its source (declared, managed by a parent, estimated or verified) and whether a parent has approved the latest significant change; otherwise, only "not shared" or "to be checked". With it, the country (and the state, in the United States) of the connection, deduced from the IP address	Google Play, then the LU6OLE service	To comply with the laws that require it (Texas, Brazil, then Alabama, California, Utah and Louisiana): where they apply, until Google Play has confirmed the age, no parent can be linked and nothing is sent to the service — the guardian, for its part, keeps protecting the child. The signal is used for nothing else, never for advertising or statistics	Legal obligation

What a parent's phone receives

The parents' page (lu6ole.app/parent) opens from a phone or a computer, with the parent's Google or Apple account. The first time, the parent types the six-digit code shown by the child's phone: that phone is then linked to their account, and they find it on all their devices when they sign in. Up to four parents (four accounts) can be linked to the same phone.

Data	Recipient	Why	Legal basis
The identifier of the parent's Google or Apple account, their email address and their first name, as Google or Apple pass them on when they sign in (Apple lets them hide the address); or only their email address if they prefer to sign in with a link sent by email (single-use, valid for 15 minutes; the address is the same as that of a Google or Apple account, it is the same account)	The LU6OLE service; for the link, Cloudflare's email-sending service	Recognise the parent on each of their devices, show them the phones linked to them, and write to them about the service if needed. Never advertising, never passed on to the child or to a third party	Performance of the contract
A session cookie (a randomly generated token, of which the server keeps only the fingerprint (hash))	The parent's browser, and the LU6OLE service	Stay signed in on that device, without typing again	Performance of the contract
The verification that the parent is an adult — only if the child's phone is in the United States or Brazil: the parent's email address, the child's country and a randomly generated reference; then the result ("verified") and the transaction identifier returned by Kids Web Services; or, in the United States, the parent's statement that the child is 13 or older	Kids Web Services (Epic Games), then the LU6OLE service	Comply with the laws that require it: in the United States for a child under 13 (COPPA), in Brazil for a child under 16 (ECA Digital). Until it is done, the phone is linked but nothing is shown to the parent or sent to the service — the guardian, for its part, keeps protecting the child. Kids Web Services offers the parent a bank card (a few cents, refunded right away) or an official ID number; LU6OLE never sees the card or that number. Done once, it covers all of the parent's children	Legal obligation; and the parent's agreement, given when they request the verification email after reading what will be collected

LU6OLE never receives the parent's password: signing in takes place at Google or at Apple. It asks only for the basic identity ("openid", email address, first name), never for access to their messages, their contacts or their files. If they choose, the parent receives notifications when a request arrives: their browser provides a subscription address for this, kept by the service, and the notification goes through their browser's notification service (Google, Mozilla, Apple or Microsoft). It contains only "New request" and the name given to the phone; the details are read on the page.

What LU6OLE does not do

No account for the child: no name, no email address and no phone number is requested from them. The child's month and year of birth stay on their phone. From the parent, LU6OLE keeps only what the table above describes, and never their phone number.
No content: LU6OLE reads neither messages, nor calls, nor photos, nor what is typed, nor the content of apps.
No history: not of websites visited, nor of apps opened during the day, nor of past days, nor of journeys: only the last position of a location in progress is kept, and it is erased when the location ends.
No hidden or automatic location: the position is sent only if the option is turned on and a parent asks for it, and the child sees it each time. Without the option, LU6OLE does not know where the child is.
No camera, no microphone, no screenshot. LU6OLE does not have these permissions. It only knows, through Android, that a camera or a microphone is on — never what they film or hear (point 3).
No advertising, no profiling, no usage statistics, no audience measurement tool, no crash report sent automatically.
No resale or disclosure of data to third parties for commercial purposes.
No hidden mode: the child sees the LU6OLE icon and a permanent notification "LU6OLE is active", and can open at any time the screen that shows what their parents have set and the time they have spent today.
The lu6ole.app website sets no cookie other than the session of the parents' page (and, for the length of a Google or Apple sign-in, a ten-minute cookie that protects it), and contains no tracker.

3. The accessibility service (AccessibilityService)

LU6OLE uses Android's accessibility service, called "the guardian" in the app, for two things only:

Knowing which app has just opened — its name, nothing else — to close those that the parent has not allowed, those whose time for the day is used up, those that turn on a camera or microphone the parent has not allowed them, and all of them at night except the phone, emergency calls and SOSBY. It then returns to the home screen: that is the only action it takes. It also counts the time spent today in each app, which the child sees on their screen and the parent on their page.
On the Settings and app installation screens only, reading their texts to recognise those that target LU6OLE, and asking for the parent's code before it is turned off or uninstalled.

It never reads the content of other apps, nor messages, nor what is typed. It never turns on by itself: the parent turns it on, after a screen that explains all this to them and asks for their agreement. They can turn it off at any time, with their code, in Settings, Accessibility.

LU6OLE also uses, with the parent's agreement, a local VPN (Android's VpnService) for its website filter: only the questions "what is the address of such-and-such site?" go through it, never the pages, the videos, the messages or what is typed, and it leads to no LU6OLE server. LU6OLE itself blocks gambling and the services that would allow the filter to be bypassed, and forces safe search on Google, YouTube and Bing; it passes the other questions to Cloudflare for Families (point 4), which answers "site blocked" for adult and dangerous sites. Android shows a key at the top of the screen while it is running.

Camera and microphone, app by app. A parent can leave an app allowed while depriving it of the camera or the microphone. Android does not let LU6OLE take them away from the app; it only tells LU6OLE, without any permission, that a camera has just turned on or that a microphone is recording. If the app on screen is deprived of it, the guardian closes it like a non-allowed app, and the child reads why. LU6OLE sees and hears nothing, keeps nothing, and none of this leaves the phone. SOSBY and system apps (including the phone) are never affected.

LU6OLE also uses, again with the parent's agreement, Android's device administrator function, with no policy at all (neither lock nor wipe), for one thing only: preventing the child from uninstalling LU6OLE without the parent's code. It declares itself to Google Play as a parental control tool.

4. Who receives this data

The parents linked to the child's phone, on the lu6ole.app/parent page (point 2).
Google LLC and Apple Inc. (United States), for the parents' sign-in: it is with them that the parent identifies themselves; they pass on to LU6OLE the identifier of their account, their email address and their first name, according to their own privacy rules.
Cloudflare, Inc. (United States): hosting of the website and of the LU6OLE service; and Cloudflare for Families (1.1.1.3), the DNS resolver that receives the names of the websites requested when the website filter is on.
Google LLC / Google Ireland Ltd: distribution of the app through Google Play; Firebase Cloud Messaging, to alert the child's phone (a signal with no content); if the "Locate" option is turned on, the Google Play location services, which work out the phone's position (satellites, Wi-Fi, mobile towers) according to Android's location settings; and, as for the other browser notification services (Mozilla, Apple, Microsoft), delivery of the notifications to the parents who requested them.
Google LLC / Google Ireland Ltd, for the purchase: Google Play collects the payment (the publisher never sees your bank details) and confirms to the LU6OLE service that a purchase is valid; Play Integrity confirms that the app is the one from the Play Store.
Kids Web Services Ltd (United Kingdom, a subsidiary of Epic Games; the United Kingdom is recognised by the European Commission as providing adequate protection) — only for a child's phone located in the United States or Brazil: it receives the parent's email address, the child's country and an opaque reference; it verifies that the parent is an adult and replies "verified" with a transaction reference. It may keep a fingerprint of the parent's address so as not to ask them for proof again. Its privacy policy: https://www.kidswebservices.com/privacy-policy.
The map on the parents' page: during a location, a small map shows the position. Its images come from OpenStreetMap (OpenStreetMap Foundation, United Kingdom), which receives the IP address of the parent's browser and the map area displayed, never the child's name; the rest of the map (Leaflet) is served by lu6ole.app. If the parent taps "Open in Google Maps" or "Open in Apple Maps", the position is opened at Google or Apple, under their own privacy rules.

Some of these providers are established in the United States: the transfers rely on the EU–US data protection framework and on the European Commission's standard contractual clauses.

The apps that the child uses (and SOSBY, which LU6OLE never blocks) are independent of LU6OLE and apply their own privacy rules.

5. For how long

Six-digit code to link a parent: 10 minutes, and a single use.
Code attempts (IP address and time): 10 minutes, to block serial attempts.
Time spent in apps: the current day only; replaced at each connection, reset at midnight.
Child's requests and parents' answers: 24 hours, then automatic deletion.
Licence: the start date of a phone's trial, for as long as the service exists, so that the trial does not start again; a purchase and the phones it unlocks, for as long as the purchase is valid.
Location: the last position, for the duration of the location (thirty minutes at most), then erasure. Location log (which parent, when, with no place at all), visible to the child and to their parents: 30 days.
Settings, list of apps, state of the protection, phone name, notification token: as long as the phone connects; automatically erased 13 months after its last connection, together with the requests and the parents' links.
A parent's account (Google or Apple identifier, email address, first name): for as long as they use it; erased as soon as they delete it from their page, and automatically 13 months after their last sign-in. Session of a device: 400 days at most, or until sign-out.
A parent's verification (United States, Brazil: address, child's country, reference, result): as long as their account exists, and erased with it. A verification that does not complete, and the link that was waiting for it: 7 days, then automatic erasure.
A parent's link (their account, the name they gave themselves) and notification subscription: until they unlink or are unlinked by another parent, or the phone is erased; a subscription that the notification service declares expired is erased immediately.
On the child's phone: until LU6OLE is uninstalled or its data is erased.
Cloudflare technical logs: a few days, according to the host's rules.
Emails you send us: for the time needed to process your request, then three years at most.

6. Your rights

You have the rights of access, rectification, erasure, restriction, objection and portability, as well as the right to withdraw your consent at any time.

See what is held: everything the service keeps about a phone is displayed on the parents' page.
Unlink a parent: from the Phone tab of the parents' page; their link and their notification subscription are erased.
Delete your parent account: on the parents' page, "My account", then "Delete my account" (or by writing to contact@lu6ole.app). Your account, your sessions, your links and your subscriptions are erased immediately; your children's phones keep applying the last settings, and the other linked parents stay in control.
Turn off location: with the parent's code, turn off the "Locate" option in LU6OLE, or withdraw the location permission in Android's settings. No position is sent any more.
Stop everything: with the parent's code, allow uninstallation in LU6OLE (For parents), then uninstall it. What was on the phone disappears with the app; what the service keeps is erased 13 months after the last connection, or immediately on request.
Exercise the other rights: write to contact@lu6ole.app. We reply within one month. Write from the address of your parent account; otherwise, you may be asked for information that allows the phone concerned to be found (for example the name you gave it, and the time of a connection).

You may lodge a complaint with the CNIL (www.cnil.fr), 3 place de Fontenoy, 75007 Paris, or with the data protection authority of your country.

7. Children

LU6OLE is designed for the phone of a child aged 6 to 15. It is the parent who installs, sets up and activates it: they create the code, they turn on the guardian after reading the explanation, they link their page. The data described in point 2 is processed at the parent's request and under their authority, in the child's interest.

The child knows: LU6OLE has no hidden mode; the child sees the icon, the permanent notification, what their parents have set, the time they have spent today (with a note that their parents see it too), and the answers to their requests, in simple words.
At 15, LU6OLE no longer locks anything: no app closed, no time limit or night limit any more, and uninstalling becomes possible again. Location is only shared with the teenager's agreement, which they give or withdraw on their phone.
The parent sees what is blocked and the time for the day, never the content: no messages, no websites, no photos. If they have turned on the option, they can see where the child is at the moment they ask; the child is warned each time, and finds in their app who located them and when.
In the United States and Brazil, the parent first proves they are an adult (point 2): until they have, nothing from the child's phone is shown on their page or sent to the service.
No data of the child is used for anything other than this service: no advertising, no profiling, no resale.

8. Security

The exchanges between the child's phone, the service and the parents' page are encrypted (HTTPS). The phone's secret and each parent's session token are never kept in clear, only their fingerprint (hash); LU6OLE never sees the parent's Google or Apple password. A six-digit code never says whether it has existed (the same answer for a wrong, expired or already used code), and attempts are limited. The parents' notifications are end-to-end encrypted up to their browser. The app's data is excluded from backups to Google Drive.

9. Residents of the United States

This section is in addition to the above; it does not replace it.

9.1 Children under 13 (Children's Online Privacy Protection Act — COPPA)

Who collects. The operator is Géry ROTSAERT EI (SOSBY), 1 quai Maréchal Joffre, 69002 Lyon, France, reachable at contact@lu6ole.app. No other operator collects data through LU6OLE.

What is collected from a child's phone, and why. A randomly generated identifier (never a hardware identifier); a Firebase notification token, which serves only to alert the phone; the list of installed apps; the time spent today in each; the state of the protection; the requests the child sends to their parents, including the name of an app they type; if the parent has turned on the option, the phone's precise location and battery level during a location requested by a parent (thirty minutes at most, no history). All of this serves one purpose only: that their parents set and follow their phone, as they wished by installing LU6OLE. No advertising, no profiling.

The parent's consent, and its verification. LU6OLE works only once set up by a parent: it is they who install the app, create the code, read the explanation of the accessibility service and turn it on. Then, when they link the phone to their page, they read on that page what will be collected and give their agreement by requesting the verification email; they then prove that they are an adult to Kids Web Services (Epic Games) by one of the methods named in the rule (16 CFR 312.5(b)): a bank card, with a transaction of a few cents that is refunded right away and notified to the cardholder, or an official ID number checked against a database. LU6OLE never sees the card or that number. The verification is done once per parent account; if the parent states that the child is 13 or older, it is not requested. Until then, the child's phone sends the service only what makes it work (its randomly generated identifier, its notification token, the country of its connection and Google Play's age signal), never its apps, its time, its requests or its location. Without verification within 7 days, the parent's link and their request are erased.

To whom it is disclosed. Only to the parents linked to the phone (four at most, each signed in with their Google or Apple account and linked by a code shown by the child's phone). We make no other disclosure, and sell nothing. Our processors (Cloudflare; Google Firebase; the browsers' notification services; Kids Web Services, for the parent's verification only) use this data only to provide their service to us.

The parent's rights. At any time, the parent can review on their page what is held, refuse that we collect more (by uninstalling LU6OLE) and have all the data deleted by writing to contact@lu6ole.app. We never make the use of LU6OLE conditional on providing more information than is necessary.

For how long (written retention policy): see point 5. Nothing is kept indefinitely.

9.2 State privacy laws

We do not "sell" or "share" personal data, within the meaning of US state privacy laws (California — CCPA/CPRA — and comparable regimes). We run no advertising, targeted or not, and no profiling.
Your rights: to know what we hold, to obtain a copy of it, to have it corrected, to have it deleted, and to suffer no difference in treatment because you exercise them. Write to contact@lu6ole.app; we reply within 45 days.

10. Changes

Any substantial change will be announced in the app or on lu6ole.app before it applies. The version in force is shown at the top of this document. This text exists in thirty-five languages; in the event of a discrepancy, the French version prevails, without prejudice to the rights you hold under the law of your country.

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