Privacy Policy

Effective Date: March 13, 2026

Welcome to Growing Monai ("Growing", "App" or "Service"), provided by DIWAND PTE. LTD., with its registered address at 112 Robinson Road, #03-01, Robinson 112, Singapore 068902 ("we," "our," "us"). We are committed to protecting your privacy and ensuring you have a positive experience on our App.

This Privacy Policy explains how we collect, use, share, and protect personal information when you use our App. It applies to all users of the App worldwide, including users in the United States, the European Union and European Economic Area (EU/EEA), Japan, and all other regions where the App is available.

By accessing or using our App, you acknowledge that you have read, understood, and agree to this Privacy Policy.

EU/EEA users: Please also refer to Section 11 for additional disclosures under the General Data Protection Regulation ("GDPR").

Japan users: Please also refer to Section 12 for additional disclosures under Japan's Act on the Protection of Personal Information ("APPI").

1. Information We Collect

We collect information from you when you use our App, including when you register for an account, use our services, or communicate with us. The information we collect may include:

1.1 Information You Provide

When you create an account, upload content, contact us directly, or otherwise use the Service, you may provide some or all of the following information:

Account and Profile Information: In order to create and manage your Growing account, we may collect information that specifically identifies you, including without limitation your name, email, phone number, password, date of birth, gender, and profile image. If you choose to sign up or log in via external third-party services, such as Facebook or Google, you agree we may collect your profile photo, username, and email address associated with the relevant third-party service provider.

User-Generated Contents: Such as profile pictures, photos, images, videos, audio, comments, replies, messages, and other contents or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata.

Albums Information: When you use the albums services (Timeline), you can create albums for your children or other family members. You may share your relation with those persons and information about your children or other family members including the name, birthdate, gender, weight, height, personal milestones, and other such information. If you choose to share your albums with other users of Growing (e.g., by inviting your friends, family members or other users to see and interact with your albums), you agree that they may view or otherwise access the personal information of your albums that you share with them, and acknowledge that we cannot control and/or be liable for how they may use that information.

Payment Information: In order to complete transactions and fulfill orders of the paid subscription products, we collect third-party payment information (such as Apple In-App Purchase, Google Play Billing) for the purpose of payment and billing.

Monitor Information: When you use the baby monitor, you can connect it with the Growing app. During the connecting process, we will collect WiFi information, device identifier information, as well as account information and associated albums information (related to your children or other family members). You can view and control the monitor on the app. To enable the relevant functions, we will collect information about the device's network status, device status, and operational interaction. When you use the Daily Highlights feature, the captured videos will be automatically uploaded to the album (Timeline).

Communications: We may collect records of communications between you and us, including support requests, feedback, and other interactions.

AI Chat Conversation Records: When you use our AI Chat feature to ask parenting-related questions, we collect the questions you submit and the AI-generated responses, including the content and timestamp of each interaction, as well as contextual information such as the language used and session duration.

1.2 Automatically Collected Information

To enhance your experience on our Service, we may automatically collect the following information when you access or use Growing:

Device Information: We collect certain information about the device you use to access our App, including device type, operating system, unique device identifiers, and mobile network information.

Usage Information: We collect information about your interactions with our App, such as features you use, pages you visit, and actions you take within the App.

Location Information: We collect your approximate location data (e.g., IP address).

Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to collect information about your interactions with our App and to personalize your experience.

2. How We Use Your Information

We use the information we collect for the following purposes:

To Provide and Improve Our Service: To operate, maintain, and enhance our App's features and functionality, including the AI Chat feature.

To Personalize Your Experience: To customize content and features based on your preferences and usage patterns.

To Communicate with You: To respond to your inquiries, provide customer support, and send you important updates and notifications.

For Research and Analytics: To analyze trends, monitor usage, and gather demographic information to improve our App.

To Improve AI Capabilities: To use de-identified or anonymized conversation data from the AI Chat feature to improve the AI system's ability to provide helpful parenting guidance. We will not use your identified conversation records for AI model training without your separate consent.

For Legal Compliance: To enforce our Terms of Service, protect the security of our App, and comply with legal obligations.

3. Information Sharing and Disclosure

We do not sell, trade, or otherwise transfer your personal information to third parties without your consent, except as described below:

3.1 Service Providers

We may share your information with third-party service providers who assist us in operating our App, conducting business, or providing services to you. These service providers are contractually obligated to protect your information and may include payment processors, cloud hosting providers, analytics providers, and AI model service providers. For example, we use third-party cloud storage providers to store the photos and videos you upload. All such providers are required to handle your data solely in accordance with our instructions and applicable data protection laws.

3.2 Legal Requirements

We may disclose your information if required by law, regulation, legal process, or governmental request. We may also disclose your information to enforce our Terms of Service, protect our rights or property, or respond to claims of third-party infringement.

3.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of the transaction. We will notify you of any such change in control and provide you with an opportunity to opt-out, where applicable.

3.4 Third-Party Services

Our App may integrate with or contain links to third-party services, including social login providers (such as Facebook and Google) and payment platforms (such as Apple and Google). This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you use in connection with our App.

4. Data Security

We take reasonable and appropriate technical and organizational measures to protect the information we collect from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

Encryption: We use industry-standard encryption technologies to protect sensitive information in transit and at rest, including children's health-related data (such as height, weight, and developmental milestones) stored in our third-party cloud infrastructure.

Access Controls: We limit internal access to your personal information to only those employees or service providers who need it to fulfill their job responsibilities.

Vendor Security: We require our third-party cloud service providers to maintain appropriate security standards consistent with this Policy and applicable laws.

However, no method of electronic storage or transmission over the Internet is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security.

4.1 Security Incident Notification

In the event of a data security incident that affects your personal information, we will take prompt action to contain and assess the incident. Where required by applicable law, we will notify the relevant data protection authorities and, where the incident poses a significant risk to your rights or interests, we will notify you directly without undue delay. Notifications will be provided through the contact information associated with your account or through in-app notices, as appropriate.

5. Data Transfer

Our App is operated globally, and your personal information may be transferred to and processed in the United States, where our primary servers are located. The United States may have different data protection laws than those in your country of residence.

For EU/EEA users: Please refer to Section 11 for specific information about the legal basis for transferring your personal data to the United States and your associated rights.

For Japan users: Please refer to Section 12 for specific disclosures regarding cross-border data transfers to the United States as required under the APPI.

For all other users: By using the App, you consent to the transfer of your personal information to the United States. We will take reasonable steps to ensure that your information is protected in accordance with this Policy and applicable data protection laws.

6. Your Choices and Rights

6.1 Access and Update Your Information

You can review and update certain personal information associated with your account through your account settings. If you need to access, correct, or update other personal information we hold about you, please contact us at support@growingbaby.ai.

6.2 Opt-Out of Communications

You can opt-out of receiving promotional emails from us by following the opt-out instructions provided in those emails. Please note that even if you opt-out, we may still send you non-promotional communications, such as updates about your account or our Terms of Service.

6.3 Cookies and Tracking Technologies

Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. Because each browser is different, please consult the instructions provided by your browser. Please note that disabling certain cookies may limit the functionality of the App.

6.4 Do Not Track

Some web browsers incorporate a "Do Not Track" (DNT) feature that signals to websites that you do not want to be tracked. Because there is not yet a consensus on how to interpret DNT signals, we do not currently respond to DNT signals. You may use other privacy controls available in your account settings to manage data collection and use.

6.5 AI Chat Data

You may opt out of having your de-identified AI Chat conversation data used for AI system improvement by contacting us at support@growingbaby.ai. Please note that this will not affect the use of data that has already been fully anonymized. You may also request deletion of your identified conversation history at any time.

6.6 Account Deletion

You may delete your account at any time by navigating to Settings -> Personal Details -> Delete Account within the App. You may also request account deletion by contacting us using the contact information provided at the end of this Privacy Policy. Upon account deletion, your personal information will be deleted or anonymized within 30 days, except where we are required to retain certain information to comply with legal obligations.

7. Data Retention

We will retain your personal information for as long as your account is active, as necessary to provide you with the App's services, and as required to comply with our legal obligations, resolve disputes, and enforce our agreements.

Upon account deletion, we will delete or anonymize all personal information - including account details, user-generated content, albums data, and AI Chat conversation records - within 30 days, unless a longer retention period is required by applicable law. Once conversation data has been fully de-identified or anonymized for AI improvement purposes, the resulting anonymized dataset may be retained for longer periods, as it no longer constitutes personal information under applicable law.

8. Children and Teens' Privacy

Our App is designed for use by adults (parents and guardians) to manage family photo albums, development records, and related content. Our App is not directed to individuals under the age of 18, and we do not knowingly collect personal information directly from individuals under 18.

While users may record information about their children (such as name, birthdate, height, and weight) within the App, such information is provided by the parent or guardian and is subject to their account's privacy settings. This information is encrypted and stored securely, and is accessible only to the account holder and those they have expressly invited to share the album.

If we become aware that an individual under 18 has independently created an account and provided us with personal information, we will take steps to delete such information. If you believe this has occurred, please contact us immediately at support@growingbaby.ai.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you by posting the updated Privacy Policy on our App and indicating the effective date of the changes. Where required by applicable law, we will seek your prior consent for material changes. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

10. Your California Privacy Rights

Under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), California residents have specific rights regarding their personal information:

Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purpose for collection, and the categories of third parties with whom we share it.

Right to Delete: You have the right to request that we delete your personal information, subject to certain exceptions.

Right to Correct: You have the right to request correction of inaccurate personal information we maintain about you.

Right to Opt-Out of Sale or Sharing: We do not sell personal information or share it for cross-context behavioral advertising. If this practice changes, we will provide notice and an opportunity to opt-out.

Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information to certain permitted purposes.

Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

To exercise these rights, please contact us at support@growingbaby.ai. We will verify your request and respond within the timeframe required by applicable California law.

11. EU/EEA Users - General Data Protection Regulation (GDPR) Disclosures

This section applies to users located in the European Union and European Economic Area (EU/EEA) and supplements the rest of this Privacy Policy. In the event of any conflict between this section and other sections of this Privacy Policy, this section shall prevail for EU/EEA users.

11.1 Data Controller

DIWAND PTE. LTD. is the data controller responsible for your personal data processed through the App.

Contact: support@growingbaby.ai

11.2 Legal Bases for Processing

We process your personal data on the following legal bases under the GDPR:

Creating and managing your account: Performance of a contract

Providing core App features (albums, monitor, AI Chat): Performance of a contract

Processing payments: Performance of a contract

Providing customer support: Legitimate interests

Analytics and service improvement: Legitimate interests

AI Chat improvement using de-identified data: Legitimate interests

Sending promotional communications: Consent

Compliance with legal obligations: Legal obligation

Where processing is based on legitimate interests, we have conducted a balancing assessment and determined that our interests do not override your fundamental rights and freedoms. You have the right to object to processing on this basis (see Section 11.5).

Where processing is based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal.

11.3 Special Category Data

Information you voluntarily record about your children - such as weight, height, and health-related milestones - may constitute health data, which is a special category of personal data under the GDPR. We process such data solely on the basis of your explicit consent, given when you enter this information into the App. This data is:

Stored in encrypted form within our third-party cloud infrastructure;

Accessible only to you and the family members you have expressly authorized;

Not shared with third parties for marketing, analytics, or any purpose other than operating the Service.

11.4 International Data Transfer to the United States

Your personal data is stored and processed on servers located in the United States. The European Commission has not issued an adequacy decision for the United States as a whole. Accordingly, the transfer of your personal data to the United States is made on the basis of your explicit consent under the GDPR.

Before completing your account registration, you will be clearly informed of, and asked to provide explicit consent to, the following:

The fact that your personal data will be transferred to and stored in the United States;

The absence of a European Commission adequacy decision for the United States;

The potential risks associated with such a transfer, including the possibility that your data may be subject to access by U.S. governmental or law enforcement authorities under applicable U.S. law;

Your right to withdraw consent at any time (withdrawal will require closure of your account, as the transfer is necessary for providing the Service).

We implement appropriate technical and organizational security measures - including encryption in transit and at rest, and access controls - to protect your data in the United States.

11.5 Your Rights Under the GDPR

As an EU/EEA resident, you have the following rights with respect to your personal data:

Right of Access: You may request confirmation of whether we process your personal data and, if so, receive a copy of that data and information about how it is processed.

Right to Rectification: You may request correction of inaccurate personal data or completion of incomplete data.

Right to Erasure / "Right to Be Forgotten": You may request deletion of your personal data where, for example, the data is no longer necessary for the purpose for which it was collected, or you have withdrawn your consent and there is no other legal basis for processing.

Right to Restriction of Processing: You may request that we restrict processing of your personal data in certain circumstances, such as while the accuracy of data is being contested.

Right to Data Portability: You may request to receive your personal data in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller where technically feasible.

Right to Object: You may object to processing of your personal data where that processing is based on legitimate interests, including profiling. You also have the right to object to the use of your data for direct marketing at any time, with no exceptions.

Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

Rights Related to Automated Decision-Making: The AI Chat feature provides informational responses to parenting questions and does not make decisions with legal or similarly significant effects on you. However, if you believe that any AI-generated output has significantly affected you, you may contact us to request human review.

To exercise any of the above rights, please contact us at support@growingbaby.ai with the subject line "GDPR Request." We will respond within 30 days of receipt. We may need to verify your identity before processing your request.

11.6 Right to Lodge a Complaint

If you believe we have not handled your personal data in accordance with the GDPR, you have the right to lodge a complaint with the data protection supervisory authority in your EU/EEA member state of residence. A list of EU/EEA data protection authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

12. Japan Users - Act on the Protection of Personal Information (APPI) Disclosures

This section applies to users located in Japan and supplements the rest of this Privacy Policy. In the event of any conflict between this section and other sections, this section shall prevail for Japan users.

12.1 Personal Information Handling Business Operator

DIWAND PTE. LTD.

112 Robinson Road, #03-01, Robinson 112, Singapore 068902

Inquiries: support@growingbaby.ai

12.2 Purposes of Use

We collect and use your personal information for the following specified purposes. We will not use personal information beyond these stated purposes without first obtaining your consent:

1. To create, manage, and operate your Growing account

2. To provide the App's family album (Timeline), baby monitor, and related services

3. To provide the AI Chat feature and deliver responses to parenting questions

4. To process payments for subscription products

5. To send service-related notifications, updates, and important announcements

6. To provide customer support and respond to inquiries

7. To analyze usage patterns in de-identified or aggregated form to improve service quality

8. To improve AI Chat capabilities using de-identified or anonymized conversation data

9. To comply with applicable legal obligations

12.3 Provision of Personal Information to Third Parties

We do not sell personal information to third parties. We may share personal information with third-party service providers as necessary to operate the Service, including cloud hosting providers, analytics providers, and AI service providers. All such providers are bound by contractual obligations to protect personal information and to use it solely for the purposes we specify.

12.4 Cross-Border Transfer to a Foreign Country

Your personal information is stored and processed on servers located in the United States of America. In accordance with the APPI's requirements for cross-border transfers, we provide the following disclosures prior to transferring your personal information to the United States:

a. Destination Country: United States of America

b. Personal Information Protection System in the United States: The United States does not have a single comprehensive federal law governing personal information protection equivalent to Japan's APPI. Data protection in the United States is governed by a combination of sector-specific federal laws and state laws. Reference information about the data protection systems of foreign countries is published by Japan's Personal Information Protection Commission (PPC) and may be consulted at https://www.ppc.go.jp/.

c. Measures Taken by DIWAND PTE. LTD. to Protect Your Personal Information: We implement the following measures to protect your personal information transferred to the United States:

Encryption of personal data in transit and at rest;

Role-based access controls limiting access to authorized personnel only;

Contractual data protection obligations with our U.S.-based service providers;

Regular security assessments of our infrastructure and service providers.

By registering for and using the App, you are providing your consent to the transfer of your personal information to the United States as described above. You may withdraw this consent at any time by contacting us at support@growingbaby.ai; please note that withdrawal will require closure of your account, as this transfer is necessary to provide the Service.

12.5 Handling of Sensitive Personal Information

Information you voluntarily record about your children - including health-related data such as height, weight, and physical developmental milestones - may constitute sensitive personal information under the APPI. We collect such information only with your explicit consent, given when you enter the data into the App. This information is:

Stored in encrypted form within our third-party cloud infrastructure;

Accessible only to you and the family members you have expressly authorized;

Not used for purposes other than providing the App's core service.

12.6 AI Chat Feature

When you use the AI Chat feature, your conversation records (questions and AI-generated responses) are collected and used to provide the service. After de-identification or anonymization processing, conversation data may be used to improve the AI system's capabilities. We will not use your identified conversation records for AI training without your separate consent.

You may request deletion of your AI Chat conversation history by contacting us at support@growingbaby.ai.

12.7 Your Rights Under the APPI

As a user in Japan, you have the following rights with respect to your personal information held by us:

Right of Disclosure: You may request disclosure of the personal information we hold about you, as well as records of any third-party provisions made in connection with your data.

Right to Correction, Addition, or Deletion: If the personal information we hold about you is factually inaccurate, you may request correction, addition, or deletion.

Right to Suspension of Use or Deletion: If your personal information is being handled in a manner that violates the APPI or is no longer necessary for the stated purposes of use, you may request that we suspend use or delete your data.

Right to Suspension of Third-Party Provision: If we are providing your personal information to a third party in a manner that violates the APPI, you may request that we stop doing so.

To exercise any of the above rights, or to submit a complaint regarding our handling of personal information, please contact us at support@growingbaby.ai with the subject line "APPI Request." We will respond without undue delay and in accordance with applicable procedures.

You also have the right to submit a complaint to Japan's Personal Information Protection Commission (PPC): https://www.ppc.go.jp/

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

DIWAND PTE. LTD.

112 Robinson Road, #03-01, Robinson 112, Singapore 068902

Email: support@growingbaby.ai

For EU/EEA users exercising GDPR rights: Please email support@growingbaby.ai with the subject line: "GDPR Request"

For Japan users exercising APPI rights: Please email support@growingbaby.ai with the subject line: "APPI Request"