Last updated: 8 October 2026 · Version 4.0

Privacy Notice

Privacy matters especially when a product is used by families and children. Gulino is designed around data minimisation and a local-first approach: information stays on the device when a cloud service is not needed for the feature. This notice explains what actually happens to personal data when you use Gulino.

On this page

  1. Who we are
  2. Who uses Gulino
  3. What data Gulino handles
  4. What never leaves the phone
  5. Why we process it, and our legal basis
  6. Children
  7. Who else is involved
  8. Advertising and selling data
  9. How long we keep things
  10. Your rights
  11. Security
  12. International transfers
  13. Website and cookies
  14. Changes and contact

1. Who we are

GULO GULO SRL
CUI: 42846715
Trade Register: J2020003193239
contact@gulino.app

GULO GULO SRL is the controller for the processing described here. We have not appointed a Data Protection Officer; privacy questions go to the address above.

2. Who uses Gulino

The parent or legal guardian installs Gulino, creates the account where one is used, accepts the Terms and chooses the people, apps and tools that appear on the child's phone.

The child uses the experience the parent configured. A child does not create an account, does not accept the Terms, and is never asked for credentials of their own. The service relationship is with the adult.

3. What data Gulino handles

Gulino is an application that helps a parent configure a simpler, child-oriented experience on a compatible Android phone. It is not designed as a monitoring product. It does not collect screen time, app-usage statistics, browsing history, continuous location, or a date of birth. There is no advertising identifier, no analytics and no crash-reporting service in the app.

A. Parent account

A Parent account is an identity with our authentication provider, Google Firebase Authentication (see section 7). It holds your email address, a display name, an account identifier and whether the email address has been verified. Used to sign in, to let you recover a forgotten Parent PIN, and to confirm it is you before the account is deleted. Held in the cloud. Alongside it we keep the service identifiers that connect your account to the Gulino setup on your phone (see A2) and, once you subscribe, the subscription information described in I. We do not build a profile about you.

You sign in with an email address and a password you set, held by Firebase Authentication. A forgotten password is reset through the email Firebase sends. That is the only sign-in method Gulino offers.

Signing in to Gulino does not use a Google account. Subscribing does: the subscription is bought through Google Play, with the Google account signed in to Google Play on the phone where you subscribe (see I).

A2. Gulino Space

Every child phone belongs to a Gulino Space: the record that connects your Parent Account to the setup on that phone. It holds service identifiers and timestamps — random identifiers for the setup, the child and the phone, your account identifier, and the app version — and no names, addresses, relationships or anything else about the child or the household. Held in the cloud, in our database in the European Union, and reachable only by the account the setup belongs to. It has a single purpose: to make sure that only a Parent Account connected to this child's setup can sign in on the child's phone. A Space belongs only to the account that created it. It is created during first setup and removed when the account is deleted (see section 9).

B. Child profile

The child's display name or nickname, a randomly generated internal identifier, and the buddy theme they chose. Stored on the phone. The identifier alone — not the name — is also recorded in the Gulino Space (A2), so the phone can be tied to the right child. The child's name is not uploaded to our servers.

C. Approved people

For each contact a parent adds: the name the parent typed, the phone number, the directional permissions (calls in, calls out, messages in, messages out), whether the contact is an SOS contact, and an optional emoji or a picture the parent chose. Stored on the phone. None of this is uploaded to our servers.

When a parent uses contact import, only the entries the parent actually selects are kept.

D. Device configuration

The set of choices a parent has made — the approved contacts, the approved app list (the apps the parent selected), the SOS configuration, and device settings such as whether Child Mode is on. This is stored on the phone only, in Gulino's private storage. It is not uploaded to our servers: we hold no cloud copy of a child's configuration.

E. Location, and only for SOS

Gulino requests location only for SOS. When a child triggers SOS, Gulino reads the most recent position the phone already has and includes a map link in the alert message. Afterwards, for up to the time the parent chose in Gulino (two hours unless changed, and never more than 24 hours), or until a parent stops it, it sends further updates when the child has moved meaningfully.

F. Calls and messages

Message text is composed and stored on the phone. Gulino does not upload message content. Calls are placed through the phone's own calling. Gulino uses call information on the phone to show missed-call badges and to notice when an SOS call has ended, so that the next SOS contact can be called, and does not copy it anywhere.

G. Photos and video

Pictures the child takes with Gulino's camera are saved to the phone's own gallery, in Gulino folders. Gulino does not upload them. Gulino Photos shows the child only the pictures taken with Gulino's camera; Gulino does not open the other photos and videos on the phone.

H. Website

Standard request and security information handled by our hosting provider, and the session cookie described in section 13. Email you send us is held in our mailbox.

I. Subscription and purchases

Gulino is a paid service, offered as an annual subscription bought through Google Play. Google processes the purchase and the payment. Your card or bank details are given to Google, not to us: Gulino never receives them and never stores them.

To confirm that your Parent account has access, Gulino receives limited purchase and subscription information from Google Play: the subscription's status (for example free trial, active, cancelled or expired), when it renews or ends and whether it renews automatically, which Gulino subscription it is, and Google Play's identifiers for the purchase and the order. Google Play also tells us when that status changes, for example when the subscription renews, is cancelled or ends. We link this information to your Parent account, so that the subscription works for that account and cannot be used by a different one while the account exists. If you delete the account and keep the subscription, it can be linked to a new Gulino account with Restore purchase. To protect this service from abuse, our servers also keep the times of your account's recent requests to confirm a subscription, used only to limit how often an account can ask. Held in the cloud, in our database in the European Union; your account can read its subscription status, and only our servers can change it. It contains nothing about your child.

The phone keeps a copy of the last status our servers confirmed, so that the app knows whether Child Mode can be started, including for a short time without internet. That copy is cleared when you delete your account.

J. Analytics and crash reporting

None. Gulino does not use analytics, crash-reporting or advertising services in the app.

4. What never leaves the phone

Gulino keeps the following on the phone and does not upload it:

Uninstall, clear storage or reset

Gulino keeps information on the phone wherever it can, and for privacy it does not back that information up to the cloud — not to us, and not to the phone owner's Google account. The trade-off is deliberate: if Gulino is uninstalled, its storage is cleared or the phone is reset, those local settings are gone with the app and are configured again after a reinstall. Signing in again restores the Parent account only — not the Parent PIN, the child profile or the approved people. This is intended behaviour, not a backup failure.

5. Why we process it, and our legal basis

Accepting this notice is not a legal basis for anything, and we do not treat it as one. Each purpose has its own basis.

PurposeDataLegal basis
Create and run the parent accountEmail, credential, identifierPerformance of a contract (Art 6(1)(b))
Verify a parent before a PIN resetAccount re-authenticationContract and our legitimate interest in keeping the gate closed (Art 6(1)(b), 6(1)(f))
Hold the child's profile and the parent's configurationChild name, contacts, app list, settingsOur legitimate interest, and the parent's, in a phone that works as configured (Art 6(1)(f))
Let the child call and message approved peopleContact identifiers, message textContract (Art 6(1)(b))
SOS alerting and location follow-upChild name, SOS numbers, positionVital interests of the child (Art 6(1)(d)), and our legitimate interest in the feature working (Art 6(1)(f))
Provide the subscription and confirm your accessSubscription status and dates, the subscription bought, Google Play purchase and order identifiers, account identifierPerformance of a contract (Art 6(1)(b))
Make sure a subscription is used only by the account that bought itGoogle Play purchase identifiers linked to the account identifier; after an account is deleted, the note that it was deletedLegitimate interest in preventing misuse of purchases (Art 6(1)(f))
Keep the service secure and prevent abuseAccount and request informationLegitimate interest (Art 6(1)(f))
Meet legal and accounting dutiesWhatever the law requiresLegal obligation (Art 6(1)(c))

Where we rely on legitimate interests, we have weighed them against the interests of the child and the parent, and we will provide a summary of that assessment on request.

6. Children

Gulino is designed to be configured by a parent or legal guardian for a child's use. Children deserve additional protection, so we have kept their data to the minimum the product needs:

Because Gulino is not offered directly to a child as an online service — the adult sets it up and holds the relationship — we do not rely on a child's consent for this processing. Where consent is ever the applicable basis for a service offered directly to a child, we apply the parental-authorisation requirements of the applicable law; in Romania that threshold is 16.

7. Who else is involved

ServiceWhat forWhat they handleWhere
Google — Firebase AuthenticationParent sign-inEmail, display name, password, account identifier, connection informationGoogle infrastructure; not restricted to the EU
Google — Cloud Firestore and Cloud Functions for FirebaseStoring the link between your account and your phone's setup, so that sign-in stays restricted to your own setup; confirming subscriptions with Google Play and storing their statusService identifiers, timestamps and the subscription information described in section 3 I. No names, numbers or settingsEuropean Union
Google — Google PlaySelling the subscription and taking paymentYour Google account, your payment method and the purchase. Card and bank details stay with GoogleGoogle infrastructure; not restricted to the EU
CloudflareHosting this websiteRequest and security information, the session cookieGlobal edge network
Your mobile network operatorDelivering calls and SMS, including SOS alertsMessage content and numbers, as for any SMSYour carrier

These providers act on our instructions under data-processing agreements, except your carrier and the contacts a parent chooses, who receive information in their own right, and Google Play, which handles your purchase and payment in its own right under Google Play's terms and privacy policy.

We do not share personal data with anyone else, and we do not hand it to advertisers, data brokers or analytics companies.

8. Advertising and selling data

We do not sell personal data, and we never sell children's personal data.

We do not use children's personal data for behavioural advertising. Gulino uses no advertising, tracking or analytics services in the app.

An app that a parent approves is a separate product with its own privacy practices, which may include advertising. See Safety.

9. How long we keep things

WhatHow long
Parent account and Gulino SpaceUntil you delete the account in the app or ask us to, then removed
Subscription information (status, dates, Google Play purchase identifiers)While your Parent account exists; deleted when the account is deleted. Only a note that the account was deleted remains — a one-way code made from the account's identifier and the date, with no email address, name or purchase identifiers — so that a subscription you keep can be linked to a new Gulino account. Google keeps its own records of the purchase under its own policies
The child's configuration on the phoneUntil you change it, or until Gulino is removed or its storage cleared
Contacts a parent removesRemoved when the parent removes them
LocationNot retained at all. It is used for the alert and discarded
SOS location sharingStops after the time the parent chose (two hours unless changed, at most 24 hours), or sooner if a parent stops it
Messages, photos and video on the phoneThey are yours and stay on the device until you delete them or remove the app
Email you send usWhile we handle your request and for a reasonable period afterwards
Records the law requires us to keepFor the period the law sets; see below

Deleting your account

You can delete your Parent account in the app: Parent Mode → Account & Security → Delete account. The app shows what will be deleted, then asks you to confirm it is you — not with the Parent PIN, but with the account password — and then for a final confirmation. The same check protects a forgotten Parent PIN: once the app has verified your account, you can set a new PIN; the old PIN is not shown. You can also write to contact@gulino.app from the account's email address with the subject Delete my account; we confirm it is you and aim to complete the request within 30 days. Both routes are described in full at gulino.app/account-deletion.

What deletion removes

From our servers: the Parent account with our authentication provider, and the Gulino Space this phone belongs to, with the service identifiers that linked your account to this setup. The account itself is deleted last, once the rest has been removed; the subscription information linked to it is then deleted by our servers, leaving only the note that the account was deleted (see the table above). On the phone: all of Gulino's private storage — the stored Parent PIN, child profile, approved people, SOS settings, app allowlist, message store, acceptance record, account link and the stored subscription status — and the app returns to its first-run state. Photos and videos in the gallery, Android's SMS storage and other apps are not touched.

Deleting your Gulino account does not cancel a Google Play subscription. Google Play keeps renewing it until you cancel it in Google Play, so cancel it there first if you no longer want it. Google keeps its own records of the purchase under its own policies. How to cancel is explained at gulino.app/account-deletion.

What may remain after deletion

Deleting your account permanently removes your Gulino Parent account and Gulino-controlled active child/device data associated with it. We may retain limited information where required by law, such as accounting records relating to a purchase, or where necessary to establish, exercise or defend legal claims. Such information is restricted to those purposes and is not used as an active Gulino account.

10. Your rights

You can ask us to give you a copy of your data, correct it, delete it, restrict what we do with it, or object to processing based on legitimate interests. Where processing is based on consent you can withdraw it at any time, as easily as you gave it, and where it is based on a contract you can ask for your data in a portable form.

Write to contact@gulino.app. We will ask enough to be sure who you are.

Parents may exercise these rights on behalf of their child where the law allows. A person whose number a parent added as a contact can write to us too; we will explain what we can and cannot do.

For questions or concerns about your personal data, contact us at contact@gulino.app. You also have the right to lodge a complaint with the competent supervisory authority.

Erasure. You do not need to write to us to delete your account: the app does it, from Parent Mode → Account & Security → Delete account. What that removes, what it leaves alone and the email alternative are set out at gulino.app/account-deletion.

11. Security

We use appropriate technical and organisational measures to protect the information Gulino handles. In particular:

No service can eliminate every security risk, and we do not claim otherwise.

12. International transfers

Our database is located in the European Union. Some provider infrastructure — sign-in and Google Play in particular — operates globally, so personal data may be processed outside the European Economic Area. Where that happens we rely on the transfer mechanisms our providers make available, such as the European Commission's standard contractual clauses or an adequacy decision.

13. Website and cookies

This website currently uses only strictly necessary storage: a session cookie for the site's access control, and the security cookies our hosting provider sets. There is no analytics, no advertising pixel, no third-party script and no tracking of any kind — so there is nothing to consent to and we have not put a banner in your way.

If we ever add anything non-essential, we will ask for your consent before it loads and make it as easy to withdraw.

14. Changes and contact

When we change this notice we update the date at the top. If a change materially affects how we handle your data, we will tell you rather than quietly re-publishing the page.

GULO GULO SRL
CUI: 42846715 · Trade Register: J2020003193239
contact@gulino.app