PRIVACY POLICY

PEEK A BOOK KIDS AUDIOS

Version 1.0 | Effective Date: April 21, 2026

This document is also available in Spanish at https://peekabookkids.com/audios/politicadeprivacidad. In the event of any discrepancy between both versions, the Spanish version shall prevail as the official text, without prejudice to the legal validity of this English version.

DATA CONTROLLER INFORMATION

Controller: Carlos Alberto Duarte Ortega

Tax ID (RFC): DUOC770203MN8

Address: Bosque de Cedros, Manzana 46 Lote 1, Col. Los Héroes de Tecámac Sección Bosques, C.P. 55764, Tecámac de Felipe Villanueva, State of Mexico, Mexico

Email: [email protected]

Application: Peek a Book Kids Audios (FREE)

Data Protection Officer: [email protected]

Availability: Apple App Store, worldwide, free

Website: https://peekabookkids.com (also accessible at https://peekabook.com.mx)

1. INTRODUCTION AND COMMITMENT

We are committed to protecting the privacy of ALL users, especially children and adolescents. This Policy complies with the highest international standards:

✓ COPPA (Children’s Online Privacy Protection Act – United States)

✓ GDPR (General Data Protection Regulation – European Union)

✓ LFPDPPP (Federal Law on Protection of Personal Data Held by Private Parties – Mexico)

✓ Applicable regulations in each jurisdiction where the Application is available

In compliance with Article 35 of the GDPR, we have conducted a Data Protection Impact Assessment (DPIA) confirming that our minimal data processing does not pose a high risk to the rights and freedoms of Users, including minors.

2. APPLICATION MODEL

Free Application: Peek a Book Kids Audios is a completely free application. There are no in-app purchases, subscriptions, hidden charges, or fees of any kind. We DO NOT collect, store, or process any financial data from the User.

Audio content: The Application includes relaxing audios and sounds designed to help children fall asleep, hosted on GHL (Go High Level) servers for streaming playback. Due to the technical nature of the Internet protocol (TCP/IP), the User’s device IP address is transmitted to GHL servers solely to establish the connection necessary for content playback. GHL does not use said IP address to identify, profile, or track Users, and does not receive any other personal data.

Link to Premium Application: The Application contains a link to the Apple App Store directing to "Peek a Book Kids" (a paid application by the same Licensor). This link does not collect additional data and is managed exclusively through the Apple App Store.

No advertising: The Application does NOT contain third-party advertising, banners, or ads of any kind.

Worldwide availability: The Application is available free of charge on the Apple App Store in all countries and regions where Apple operates its digital store.

3. AUDIENCE AND PARENTAL CONSENT

Application for Minors

Peek a Book Kids Audios is specifically designed for children’s use.

Definition of “minor”:

Under 13 years of age in the United States (COPPA)

Under 16 years of age in the European Union (GDPR)

Under 18 years of age in Mexico

The most protective definition shall prevail according to the User’s jurisdiction

MANDATORY Parental Consent

IMPORTANT: Use by minors requires prior, express, and informed consent from a parent or legal guardian.

By downloading and using the Application, the adult:

Confirms being the parent or legal guardian of the minor

Declares having read this Privacy Policy in its entirety

Authorizes the processing of the minor’s data in accordance with this Policy

Commits to supervising the minor’s use of the Application

Revocation: The parent/guardian may revoke consent at any time by writing to [email protected]

4. WHAT INFORMATION WE COLLECT

Principle: DATA MINIMIZATION

We collect ONLY what is strictly necessary. The Application is designed to function with the minimum possible data collection. As a free app with no user registration, data collection is even more limited than in the Premium Application.

Data we DO collect:

1. Technical Device Information (minimal):

Device model and iOS/iPadOS version

System language and time zone

IMPORTANT regarding identifiers:

We DO NOT use IDFA (Identifier for Advertisers)

We DO NOT display the App Tracking Transparency prompt

We DO NOT track across applications or websites

2. Usage Data (anonymized):

Features used (which audios are played)

Approximate usage time

Configuration preferences

3. IP Address (technical transmission):

When playing audio content (streaming), the device’s IP address is technically transmitted to GHL (Go High Level) servers to establish the connection. This IP address is not used by the Controller or by GHL to identify, profile, or track the User.

Data we DO NOT collect:

Full name of the minor or adult

Date of birth

Physical address

Phone number

Email address

Personal photographs

Precise geolocation

Device contacts

Biometric data

Health information

Race, religion, political opinions

Payment or financial data (the Application is free)

Apple ID or Apple account information

5. HOW WE USE INFORMATION

Legal bases for processing (Article 6 GDPR):

Primary Purposes (Necessary):

Provide sleep audio functionalities

Stream audio content hosted on GHL servers

Save configuration preferences locally on the device

Resolve reported technical issues

Prevent fraud and protect the integrity of the Application

You may object to secondary purposes without affecting the Application’s functionality.

6. WHO WE SHARE INFORMATION WITH

We NEVER sell, rent, or commercialize your personal data.

Third parties involved:

1. Apple Inc. (Distribution)

Purpose: Application distribution on the App Store

Location: United States

Data: Apple manages the download. As a free app, NO financial data is processed

2. GHL – Go High Level (Audio content hosting)

Exclusive function: GHL acts solely as a hosting provider for the audios that are part of the Application. Content is delivered via streaming.

Data GHL receives:

Device IP address: Technically necessary for content transmission via streaming (TCP/IP protocol). GHL does not use this information to identify, profile, or track Users

No other personal data: GHL does not receive names, emails, device identifiers, or any other personal data from the User

Server location: United States

3. Competent authorities (only when legally required)

IMPORTANT: The Application does NOT contain third-party advertising. We do not share data with advertising networks, data brokers, or commercial third parties.

7. INTERNATIONAL TRANSFERS

Since the Application is available worldwide, minimal data may be transferred to the United States (where GHL servers are located), in compliance with:

EU Standard Contractual Clauses (Implementing Decision 2021/914)

EU-U.S. Data Privacy Framework

Transfer Impact Assessments (in accordance with the Schrems II doctrine)

In the case of GHL, audio content owned by the Controller is transferred, and, due to the technical necessity of streaming, the User’s device IP address to establish the connection.

8. HOW LONG WE RETAIN DATA

Technical data: Technical logs maximum 90 days, then automatically deleted.

IP addresses at GHL: Not persistently stored in accordance with GHL’s standard retention policy.

Upon uninstalling: iOS automatically deletes local data.

9. SECURITY

We implement robust technical and organizational measures:

TLS 1.3 encryption (in transit) and AES-256 (at rest)

Strict access controls

Continuous security monitoring

Internal information security policies

COPPA and child protection training

Security breach notification:

To authorities: 72 hours (GDPR) / immediately (COPPA)

To affected users: When there is a high risk to their rights

10. YOUR RIGHTS

Rights of parents/guardians regarding the minor’s data:

Access, rectify, erase, restrict, port, object, and withdraw consent. Contact: [email protected].

COPPA Rights (U.S.): Review, request deletion, refuse future collection.

ARCO Rights (Mexico): Access, Rectification, Cancellation, Opposition. Response period: 20 business days.

GDPR Rights (EU): All rights under Art. 15-22 GDPR. Response period: 1 calendar month.

INAI Form (Mexico): Available at https://home.inai.org.mx

11. LOCAL STORAGE TECHNOLOGIES

The Application, being a native iOS app, does not use browser cookies. It employs local device storage mechanisms (such as iOS UserDefaults) exclusively to save configuration preferences and maintain session state.

We DO NOT use:

Advertising or third-party cookies

Cross-site or cross-app tracking

Behavioral profiles

Fingerprinting technologies

12. RIGHTS BY JURISDICTION

European Union (GDPR): All rights in Section 10. ODR Platform: https://ec.europa.eu/consumers/odr

EU Representative: In accordance with Article 27(2)(a) of the GDPR, the Controller has determined that the processing is occasional, does not include large-scale processing of special categories, and is unlikely to result in a risk to the rights and freedoms of natural persons. Accordingly, the appointment of a representative in the EU is not required.

United States (COPPA): Full parental rights. FTC: www.ftc.gov

California (CCPA/CPRA): We DO NOT sell personal data.

Mexico (LFPDPPP): Full ARCO rights. INAI: www.inai.org.mx

Canada (PIPEDA): Privacy Commissioner: www.priv.gc.ca

Brazil (LGPD): ANPD: www.gov.br/anpd

United Kingdom (UK GDPR): ICO: www.ico.org.uk

13. SPECIAL PROTECTION OF MINORS

Best interest of the child. Enhanced protection. Mandatory parental supervision.

Parental consent verification – Methods:

Express declaration upon first use of the Application

Acceptance of Terms and Conditions and Privacy Policy

iOS parental controls (optional, configurable by the parent/guardian)

Appropriate content: All content is reviewed to ensure age-appropriateness. No third-party advertising. No external links leading outside the app (except the App Store link to the Premium Application). No interaction with strangers or social features.

14. MODIFICATIONS TO THIS POLICY

Minor changes: Updated publication in the Application + updated effective date.

Substantial changes: Prominent notice within the Application with 30 days to review the changes.

Continued use = acceptance of the changes made.

15. PRIVACY SUMMARY TABLE

16. CONTACT AND COMPLAINTS

Email: [email protected]

DPO: [email protected]

Mailing address:

Carlos Alberto Duarte Ortega

Bosque de Cedros, Manzana 46 Lote 1

Col. Los Héroes de Tecámac Sección Bosques

C.P. 55764, Tecámac de Felipe Villanueva

State of Mexico, Mexico

Languages of service: Spanish and English

TRANSPARENCY STATEMENT

✓ The Application is FREE and generates no charges

✓ We DO NOT sell personal data

✓ We DO NOT share data for advertising

✓ We DO NOT show third-party advertising

✓ We DO NOT use commercial profiling

✓ We DO NOT track across apps or websites

✓ We DO NOT collect precise geolocation

✓ We DO NOT access device contacts

✓ We DO NOT use facial recognition or biometrics

✓ We DO encrypt data in transit and at rest

✓ We DO minimize data collection to the absolute minimum

✓ We DO comply with COPPA, GDPR, and LFPDPPP

✓ We DO prioritize the best interest of the child

✓ GHL receives only the IP address by technical necessity of streaming

ACCEPTANCE

By downloading and using Peek a Book Kids Audios, the parent/guardian:

Has read this Privacy Policy in its entirety

Consents to the processing of the minor’s data in accordance with this Policy

Authorizes the use of the Application under their supervision

Understands that the Application is free and contains a link to the paid Premium Application

Understands that audios are streamed from GHL servers and that their IP address is technically transmitted for this purpose

© 2026 Carlos Alberto Duarte Ortega.

PEEK A BOOK KIDS is a trademark whose registration is pending before the Mexican Institute of Industrial Property (IMPI). PEEK A BOOK KIDS AUDIOS is an extension of said trademark.

VERSION: 1.0

DATE: April 21, 2026

JURISDICTION: Mexico

OFFICIAL LANGUAGE: Spanish. English version available at https://peekabookkids.com/audios/privacypolicy

AVAILABILITY: Apple App Store, worldwide, FREE

Permanent URL: https://peekabookkids.com/audios/privacypolicy

Alternate URL: https://peekabook.com.mx/audios/privacypolicy

END OF PRIVACY POLICY