Your words are yours

This section is the detail behind the plain-language layer above. It sits alongside the full privacy notice, which is the complete Article 13 information. Prodia Systems Limited is the controller.

EyeSay is designed so the communicator's expressive content stays theirs. Message history, Show Me photos and any microphone input remain on the device by default and are not uploaded to us. What is held in the cloud is the adult-created configuration: profile settings, vocabulary definitions and the motor slot map, routines, the people, places, things, interests and activities that make up the communicator's world, team roles, derived measures and version/audit records.

Children hold the rights of access, rectification, erasure, restriction, objection and portability in their own name. In practice a guardian usually exercises them on the child's behalf, and we will take the child's own views into account so far as we reasonably can, having regard to their age and capacity. How to make a request is described in your data rights.

We also treat the plain-language layer above as part of our transparency obligation: a child is entitled to information about their own data in language they can actually understand.

In Ireland, the age of digital consent is 16 under the Data Protection Act 2018 where consent is the lawful basis for offering an information society service directly to a child. Rather than treating a child's tap as legal consent, EyeSay uses guardian-controlled setup: an adult creates and configures the profile, invites the team, and makes the privacy and feature choices.

Other EU/EEA states set this threshold between 13 and 16. Where you use EyeSay outside Ireland, the guardian-controlled model is designed to satisfy the stricter position rather than the looser one.

Consent is not the only, or usually the main, lawful basis here. Providing the service to the adult account holder rests on performance of a contract; security logging and audit records rest on legitimate interests and, where applicable, legal obligation; optional analytics or marketing storage on the public website rests on consent and is off by default. We assess the basis per processing activity rather than applying one label to everything.

• no behavioural advertising, and no advertising SDKs at all;
• no profiling of a child for commercial purposes;
• no emotion recognition, and no inference of behaviour, competence or hidden intent;
• no cloud AI applied to a child's utterances in this phase of the product;
• no raw message content in analytics;
• no speech produced from generated content without the communicator selecting it;
• no sale or sharing of personal data for advertising.

The automation that does exist is described in the AI and automation notice.

Write to Prodia Systems Limited, 27 Pembroke Street Upper, Dublin 2, D02 X361, Ireland, or email contact@prodiasystems.com. You can also complain to the Irish Data Protection Commission, which has a specific remit for children's data.