Privacy Policy

1. About this policy

This Privacy Policy is published by MFLOW PTY LTD (ABN 39 633 568 635) (“MFLOW”, “we”, “us” or “our”), the operator of BubCue. It explains how we collect, hold, use and disclose personal information, and how you can access or correct it or make a complaint.

It applies to this website, to emails you send to us, and to the BubCue apps, browser viewer and connection service. Our Privacy & security page provides an overview; this policy gives the fuller description and applies if the two differ. It is separate from our Terms of Service. Applicable privacy law takes priority over anything inconsistent in this notice.

The BubCue app is in development and not yet available to download. The app sections describe the current development build and its connection service. They do not mean that every feature is ready for public release. Account creation and subscription billing are not implemented; the plans identified below are not current collection practices. We will revise the policy before introducing those practices.

“Personal information” means information or an opinion about an identified or reasonably identifiable person.

2. Summary

• During ordinary monitoring, live video and sound go directly, encrypted, between the nursery phone and its authorised viewers. Those live streams do not pass through MFLOW’s servers.
• Audio and image analysis runs on the nursery phone. Its results can go to connected viewers and Activity; the app does not automatically send them to MFLOW.
• Activity records stay on your devices unless you turn on sharing or export them. BubCue does not automatically upload Soothe voice-clip files or local diagnostic logs to MFLOW. If someone separately sends us information or files, for example with a support message, we receive and handle that copy under this policy.
• BubCue’s connection service handles network addresses, installation identifiers and session and invitation records so that your phones can find each other. The nursery phone uses it from when you first open pairing until you stop monitoring, whenever the phone has internet, even if everyone watches at home.
• This website uses Google Analytics, which sets cookies. The BubCue app contains no analytics or advertising code.
• We do not sell nursery media, face outlines, voice clips or Activity records. Google’s receipt of website analytics information is described separately below.

3. Information handled by BubCue and MFLOW

When you visit this website

• Analytics information. Through Google Analytics, loaded by Google Tag Manager: pages and referring addresses, visit times and interactions, browser identifiers, device and browser details, language, screen information and approximate location. Google receives the IP address used to make the request. Its handling varies by region and configuration: for example, it uses IP addresses to derive approximate location and, outside the EU, UK and Switzerland, for basic service functions such as spam detection. Google Analytics cookies distinguish browsers and visits. See section 8 and Google’s linked explanations.
• Request information. To deliver and protect the pages, our website host processes IP addresses, browser and request details. MFLOW’s website access logging is disabled; this does not mean the hosting provider keeps no operational or security records. If the domain provider redirects a request to this site, it also receives the address and request information needed for that redirect.

When you contact us

• Your email address, your name if you give it, the content of your message, any attachments and any other information you choose to give us.
• If you report a missed alert, an injury or another problem, your message can contain sensitive information. We use the information needed to investigate and respond, handle incident and security reports, meet applicable reporting duties, seek professional advice, notify any insurer and establish or defend legal claims. Routine support does not require access to your live nursery stream.

When you use BubCue

• Information on your devices. The app processes live video and sound from the nursery phone’s camera and microphone and, when you use Talk, your voice from your phone’s microphone. It creates information such as alerts, Activity records, Soothe voice clips you record, and logs of app events kept on each phone and in each browser viewer. This information stays on the device that created it, or goes directly between the nursery phone and the devices watching it. When a voice clip plays, people watching hear it through the live sound. Activity records leave the phone that saved them only if you turn on sharing or export them. The diagnostic log contains analysis results, such as sound levels, cry and face visibility states and the cry-type guess’s scores and top label, with times and the phone’s local network address, but no audio or video. MFLOW does not receive any of it unless you send it to us. See our Privacy & security page for detail.
• Connection service information. When you open pairing while you have internet, or use an invitation or watch from away, the connection service receives network addresses, installation public keys and identifiers, session and invitation identifiers, permissions, signed access records, changes and cancellations. It also passes connection-setup messages between phones. Those messages can contain local and public network addresses, supported connection details and cryptographic fingerprints; they do not contain the live video or sound. Session, invitation, access and revocation records are stored in its database. Connection messages and short-lived authentication information are handled in memory. Service logs can include network addresses and technical errors.
• App stores and future purchases. Apple and Google operate their own stores and payment services. Our current plan is an annual subscription for monitoring, with no separate subscription for invited viewers. Pricing and purchase terms are not final. No subscription billing is implemented in the current build. Before it is introduced, this policy will identify the transaction, entitlement and account information that the implemented purchase system makes available to MFLOW. Do not send us payment card details or store passwords.
• Accounts. Buying and managing a subscription is expected to need an account. The account design is not final. This notice does not claim that MFLOW currently collects account profiles or provides an account-deletion service.
• Store and operating-system diagnostics. Apple, Google or your device manufacturer may process usage statistics, crash reports and diagnostic information under their own settings and notices. Information they make available to developers is separate from the app’s local diagnostic log. An absence of analytics code in BubCue does not mean your operating system collects no diagnostics.

Information about other people

BubCue is designed to show and play what is happening in a room, so the camera and microphone may capture a baby, other children and anyone else in the room. That information stays on the nursery phone and the devices watching it, as described above.

Analysis on the nursery phone

The app’s audio and image analysis, including cry alerts, the cry-type guess and face visibility (all experimental) and face outlines, runs on the nursery phone. The connection service does not receive the analysis results. We receive health or other sensitive information only if someone sends it to us, for example in a problem or injury report. If you include it in a message to us, you consent to our using it for the purposes described under “When you contact us” above.

The nursery phone calculates face outline points from camera images. Outlines appear while you set up the nursery phone; Start turns their display off, and you can turn Show outlines on again in Settings for that session. With Show outlines on, the points are sent through the encrypted connection to connected viewers. App viewers can draw them; the browser viewer does not draw them. The points are not saved or used to identify who the baby is. They do not pass through MFLOW’s connection service.

Cry details is on by default unless you turn it off. Its suggestion stage uses at most eight seconds of sound held in memory, not an audio recording file. A displayed guess can reach connected viewers and be retained in saved or exported Activity. Scores and the top label can also enter the nursery phone’s local diagnostic log, including when no guess appears. The limitations are in section 9.

4. How we collect and hold personal information

We obtain information directly from your communications, automatically through the website and connection service, and from providers that operate those services. We may also receive information from someone acting for you or reporting an issue involving you. If required information is withheld, we may be unable to identify a request, respond to it or provide the affected connection function.

You can contact us without giving your name, or using a pseudonym. For some requests, such as access to information we hold or a question about a purchase, we may need details that let us find the information and check that it is yours.

We hold personal information electronically: support emails in Apple iCloud Mail, connection-service records in that service’s database and logs, and analytics information in Google’s systems. Section 10 explains how we protect it, and section 11 how long we keep it.

The app requests device access for the function concerned: camera access for nursery video or scanning a code; microphone access for nursery sound, Talk or a deliberate voice recording; and network access for pairing and viewing. You can change permissions in your phone’s settings, which can stop the affected feature. Accepting a general app notice is separate from permission to record a clip, save or share Activity, or invite a viewer.

5. How we use personal information

We use personal information to:

• operate the connection service, so that your phones can find each other, and keep it secure;
• answer your questions, requests and complaints;
• provide, manage and support subscriptions when BubCue is available;
• understand how visitors use this website, so that we can improve it;
• maintain, troubleshoot and improve BubCue using technical information and reports made available to us;
• detect and prevent misuse, fraud and security incidents;
• comply with our legal obligations and exercise or defend our legal rights.

We do not use the app’s nursery media, face outlines, voice clips or Activity records for advertising or to train artificial-intelligence models. Our website analytics is used to understand site visits; Google’s separate handling is explained in section 8. The app does not upload nursery media to an AI service.

6. Who we disclose personal information to

We disclose personal information only as needed for the purposes above, to:

• service providers that host our website and the connection service or provide our domain and its redirect, and Apple, which provides iCloud Mail for our support mailbox;
• Google, which provides Google Analytics and Google Tag Manager for this website;
• Apple and Google, where an app-store support matter requires it;
• professional advisers, such as lawyers and accountants, and any insurer, where needed for advice, a complaint or a claim;
• a prospective buyer or successor, if a business transfer occurs, only to the extent legally permitted and needed for that transaction, with appropriate confidentiality restrictions;
• courts, regulators, law enforcement agencies and others, where the law requires or permits it.

These purposes do not give MFLOW access to records kept only on your devices. Your invited viewers receive the streams and controls you authorise. Saving or sharing Activity and recording a voice clip are separate choices. A viewer can make their own recording; ending access does not erase copies they already hold. Other services you choose for an export or shared invitation handle their copies under their own terms.

7. Overseas disclosure

Information handled by service providers can cross national borders. The connection service runs on servers in Australia; its hosting provider is based in the United States and may handle information there. The website host delivers pages through a worldwide network, including Australia and the United States. Google may process analytics information in the United States and other countries. Our domain provider is based in the United States and may process redirect requests there. The app stores can also handle information outside Australia. Processing locations depend on the service, support arrangements and where the people using it are located.

Our support mailbox uses Apple iCloud Mail. Apple states that personal data it collects worldwide is generally stored by Apple Inc. in the United States, and that Apple-affiliated entities can access or process information in other countries. Its iCloud terms allow storage on Apple’s or third-party providers’ servers. This is not a promise that support messages remain in Australia. See Apple’s Privacy Policy and iCloud terms.

You can ask the Privacy Officer for information about a recipient or transfer relevant to your data.

8. Cookies and analytics

This website loads Google Analytics through Google Tag Manager when a page opens. Google Analytics uses first-party cookies, commonly named _ga and _ga_ followed by an identifier, to distinguish browsers and visits. Google’s default cookie lifetime is two years, can be refreshed on later visits, and is subject to browser limits and configuration. Cookie lifetime is different from how long analytics reports are kept.

Google explains the information it receives and its uses in How Google uses information from sites or apps that use our services, its EU, UK and Switzerland privacy information, and its IP-address information for other regions. Website analytics is separate from the nursery phone’s analysis.

You can block or delete cookies in your browser and, on compatible browsers, use Google’s Google Analytics opt-out browser add-on. Deleting cookies does not delete information already received by Google, and blocking cookies alone does not necessarily stop every analytics request. Reading the pages does not require analytics cookies. The BubCue app contains no analytics or advertising code.

9. Automated decisions

The BubCue app analyses camera images and sound on the nursery phone and decides automatically, without a person’s involvement, whether to show alerts and statuses, such as sound alerts, cry alerts, face visibility and the cry-type guess. Cry alerts, face visibility and the cry-type guess are experimental. The app makes those decisions locally and does not automatically send the results to MFLOW. If someone separately includes results in a report to us, we handle that report for the support, incident-response, security and legal purposes described in this policy.

• The cry-type guess. Experimental guess. Development testing has not demonstrated reliable identification of hunger or tiredness. Independent confirmatory validation has not been completed. The guess can be wrong.
• Face visibility. After detecting a face, the app can show a notice if camera analysis stops detecting it. It cannot determine why. Real-world detection performance has not been established. This feature does not assess breathing, health or safety.

BubCue’s connection service decides automatically, without a person’s involvement, whether a phone can register a monitoring session, use an invitation or join a session. It uses the installation identifiers and the session and invitation records described in section 3.

You can turn Cry details off to stop new cry-type guesses. Show outlines controls the display and transmission of outline points; it does not turn face visibility off. Face visibility runs while monitoring video is active, unless it is unavailable, for example on Android 9 or when the phone is too hot. Cry alerts and face visibility have no separate off switch in the version described here. Stop on the nursery phone ends the monitoring session. These actions do not delete records already saved.

You can contact us about an incorrect result. We cannot review a past camera or audio input that was never retained or provided to us. If applicable law gives you a right to human review of a significant automated decision, you can ask the Privacy Officer to review information held by MFLOW and explain the decision. This does not make MFLOW an emergency monitoring service.

Automated subscription checks are part of the proposed billing system, not an implemented decision in the current build. Their inputs and effects will be described before that system is introduced.

10. Security

Live video and sound use encrypted transport between the nursery phone and its viewers. Saved Activity and voice clips are encrypted on the device and excluded from automatic cloud backup. The website and the connection service’s web-based session and invitation requests use HTTPS. The service that helps discover public network addresses uses ordinary network-address discovery requests; it does not carry video or sound.

A browser viewer’s setup page is served by the nursery phone over plain HTTP. Someone on the same network could tamper with that page and gain access; use the browser link only on your own home network. Encryption does not protect against every compromised phone, exposed invitation, dishonest viewer or other security failure. Protect your phones with a passcode, keep supported software updated and share codes and invitations only with people you trust.

Pairing codes and links contain access information. Sharing or copying one can place it in a clipboard, messaging service or another device. Some device preferences, account settings and app-switcher images are controlled by the operating system; the backup exclusion for Activity and voice clips is not a promise that every device setting or screenshot is excluded. If a security incident involving information held by MFLOW triggers a legal notification duty, that duty continues to apply.

11. Retention

• Connection database. Session access records are retained while the service regards the session as open. Ended session records and the related cancelled or revoked access records become eligible for routine deletion after 24 hours. Starting a later session on the same installation replaces the session registration and retires earlier access records. Deletion depends on the service receiving the relevant end or replacement and running its maintenance task. If it never does, an abandoned session’s records currently have no automatic time limit. Cancelling an invitation does not immediately erase its record.
• Connection messages and logs. Setup messages and authentication data are handled in bounded memory for delivery, authentication and replay protection, rather than kept as a message archive. The configured service logs rotate by size; the elapsed time before an entry is removed therefore varies with activity. A size limit is not a fixed deletion date.
• Analytics. Google’s settings govern retention of user-level and event-level data. These settings do not impose the same deletion period on standard aggregated reports, and a browser cookie’s expiry is not a report-deletion date. Google explains the distinction here.
• Support correspondence. From 7 November 2026, our retention policy is to review the support mailbox monthly and delete routine correspondence once the case has been closed for 12 months. This is a review process, not automatic deletion on the anniversary. Reports of a missed alert, an injury or another product problem, and billing, complaint or legal records, are not routine; we may keep them while they are needed for the matter, a related claim or a legal obligation. You may also ask us to review information held about you.
• On your devices. Unsaved Activity is cleared when the session ends or the app restarts. Saved Activity and voice clips remain until you delete or replace them; turning saving off does not delete existing records. Local logs can remain across sessions, with event-log rotation replacing older entries as the log grows. Deleting the app and its local data removes its local files; offloading an app, deleting a shortcut or withdrawing a permission is different. Copies exported or held by other viewers remain under their control.
• Legal preservation. We may keep information for longer where the law requires it or where it is needed for an investigation, complaint or legal claim.

12. Access and correction

Write to contact (at) bubcue.com to ask for access, correction or a review of information held about you. You can also request deletion, restriction, an objection, portability or withdrawal of consent where those rights apply. Tell us which service and information your request concerns. We may need proportionate information to verify your identity or authority to act for another person; do not send identity documents, a child’s images or access credentials unless we have explained a necessary and secure way to provide them.

There is no charge to submit a request. We will respond within a reasonable period, and within any deadline the law sets. If we cannot fulfil a request, we will explain the reason and available complaint route to the extent the law permits. Some records may need to be retained for legal obligations or claims, or may include another person’s information.

MFLOW cannot retrieve or remotely erase information kept only on a phone or a viewer’s own copy. We can explain the app’s local controls and consider requests concerning information held by MFLOW or its providers. A request to delete a service record, an app’s local data and a store subscription are different matters; requesting one does not automatically perform the others.

13. Complaints

If you have a concern, write to the Privacy Officer at contact (at) bubcue.com. Describe what happened and the outcome you seek. We will acknowledge the complaint, examine the relevant information and provide a written response within a reasonable time. If more information or time is needed, we will explain why.

If you are dissatisfied or have not received a response within 30 days, you can contact the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992. The OAIC determines whether it can deal with the complaint. You can also approach another regulator with jurisdiction.

14. Children

BubCue is intended to be set up by adult parents and authorised caregivers. It processes information about babies and can capture other children or adults in the room. This is not a claim that the service handles no children’s information. Use it only with the authority required for the people and place concerned, inform other caregivers and visitors, and do not use it for covert monitoring.

MFLOW does not request a child’s name, date of birth or health history for the current monitoring functions. Nursery media, local analysis and records follow the device and viewer boundaries described above. Website analytics can nevertheless process the browser information of a child who visits this site. If a child contacts us, or you send information concerning a child, the mailbox can receive it.

Please keep routine support messages free of children’s photos, video, audio and health details, and remove pairing codes, browser links and invitations from screenshots and files. If you believe a child supplied information without appropriate authority, contact the Privacy Officer. A parent or authorised representative can make a privacy request, subject to the child’s rights and the verification required by applicable law.

15. Additional regional privacy information

The following applies where the relevant law covers MFLOW’s processing. The app’s eventual store availability does not by itself determine which privacy law applies, and a regional right remains subject to its statutory conditions and exceptions. Use the contact in section 17 to exercise a right.

European Economic Area, United Kingdom and Switzerland

MFLOW is responsible for the purposes of its website, connection-service administration and support handling described here. Providers can have separate responsibilities for processing under their own notices. For ordinary information handled by MFLOW, our purposes and corresponding legal bases, where these laws apply, are:

• Answering a request for a service: taking steps you request before a contract, or performing the service contract where the processing is necessary for it.
• General enquiries, service administration and troubleshooting: our legitimate interests in answering people, operating the service and resolving problems, subject to the interests and rights of the people concerned.
• Security, misuse prevention and legal claims: our legitimate interests in protecting users and systems and establishing or defending claims, again subject to the required balancing of rights.
• Mandatory reports, recordkeeping or legal process: compliance with an applicable legal obligation where that basis is available; otherwise the appropriate basis must be established under the applicable law.
• Processing requiring consent: your consent, where we ask for it.

You may have rights to access, correction, erasure, restriction and portability; to object to processing based on legitimate interests and to direct marketing; and to protections concerning significant automated decisions. Where processing relies on consent, you can withdraw it without affecting the lawfulness of earlier processing. You may complain to a supervisory authority, including the authority where you live or work or where an alleged infringement occurred. In the UK, contact the Information Commissioner’s Office; in the EEA, the EDPB lists the national authorities. For Switzerland, contact the Federal Data Protection and Information Commissioner.

You may ask for details of the safeguard applicable to a transfer of your information and, where required, a copy of it with confidential material removed.

United States

Where a state privacy law applies, you may have rights to know or confirm processing, access a copy, correct inaccuracies, request deletion, obtain portable information, and opt out of a sale, targeted-advertising sharing or qualifying profiling. California law also provides a right to limit certain uses of sensitive information. We will not unlawfully discriminate against you for exercising a privacy right. An authorised agent may act for you where the law permits, subject to appropriate verification.

The categories processed for the website, the connection service and support are identifiers (including network addresses and installation identifiers), internet and electronic activity, approximate location, and communications you provide. Support messages may contain additional categories, including sensitive information, if you send it. Sources, purposes, recipient categories and retention are described in sections 3–11. The app also processes camera images, sound and analysis results, including face outline points, on users’ devices, as described in section 3; MFLOW does not receive them.

MFLOW does not exchange nursery media, voice clips, face outlines or Activity records for money or provide them to an advertising network. Website analytics is a separate disclosure to Google. You can send a privacy or opt-out request to the Privacy Officer. If a request is refused, you can ask for reconsideration using the subject “Privacy appeal”; where a state law supplies an appeal right, its deadlines and further complaint rights apply.

Brazil

Where Brazil’s LGPD applies, you may request confirmation and access; correction; information about sharing and consent; anonymisation, blocking or deletion of unnecessary, excessive or unlawfully processed data; portability where applicable; and deletion of consent-based data subject to legal exceptions. You may withdraw consent, object to unlawful processing, request review of decisions made solely by automated processing that affect your interests, and petition the ANPD. Submit a request to the Privacy Officer without charge.

Canada and New Zealand

Where Canadian privacy law applies, you may ask for access to information held about you and how it has been used or disclosed, challenge its accuracy, seek correction and raise a complaint with the Office of the Privacy Commissioner of Canada or the competent provincial regulator. Where New Zealand privacy law applies, you may request access and correction; if a correction is not made, you can request a statement of correction. Complaints can be made to the New Zealand Privacy Commissioner.

People elsewhere may have additional rights under their applicable law, including rights to challenge processing or complain to a local authority. These regional descriptions do not restrict those rights.

16. Changes to this policy

We may update this policy when our practices or applicable requirements change. The current version will show its last-updated date. Where the law requires notice or consent before a change takes effect, we will give that notice or ask for that consent.

17. Contact

Privacy contact: Privacy Officer, MFLOW PTY LTD (ABN 39 633 568 635), Australia. Email contact (at) bubcue.com with “Privacy” in the subject line.

Postal address: UL40, Level 2, Suite 664, 1341 Dandenong Road, Chadstone VIC 3148, Australia.