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Privacy Policy

Last updated: July 26, 2026

Rusty is a learning app made for children, roughly ages 6–10. Because of that, this policy is written for parents and guardians, and Rusty follows the U.S. Children’s Online Privacy Protection Act (COPPA).

The short version. A grown-up creates the account and proves they are an adult before Rusty asks anything about a child. Rusty keeps the minimum it needs to teach: your child’s first name, age, grade, and what they have actually practiced. Rusty does not save recordings of your child’s voice or transcripts of what they say. Rusty does not sell children’s data and does not show ads. You can review, correct, export, or delete everything at any time.
1.

Who We Are

Rusty is operated by FOUR STAR GROUP INC (“Rusty,” “we,” “us”). We are the operator responsible for the personal information collected through the Rusty iOS app and the website at userusty.xyz (together, the “Service”).

FOUR STAR GROUP INC

340 Millburn Ave, Millburn, NJ 07041

(973) 437-7603

Privacy: privacy@userusty.com

Support: support@userusty.xyz

Rusty is offered in the United States first. Section 11 covers every other company that handles information through the Service and how to contact us about any of them.

2.

How Accounts Work

  • Only an adult can create an account. A child never creates a login, never gives an email address, and never sets a password.
  • Children are profiles inside a parent’s family — not separate accounts. The parent creates, edits, archives, and deletes each child profile.
  • Rusty verifies you are an adult before asking anything about your child. See Section 4.
3.

What We Collect

From the parent

  • Account information — your email address and, if you sign in with Apple or Google, the identifier and name you allow that provider to share. We never receive your Apple or Google password.
  • Family setup — a family name you choose, plus country/region, language, and time zone.
  • Adult-verification result — see Section 4. We record that a check passed, not what you showed to pass it.
  • Your consent choices and the history of changes to them, so we can show what you agreed to and when.
  • Optional contact preference — if you opt in, an email address for account and privacy-policy updates.
  • Subscription status — whether the family has an active plan. Apple processes payment; we never receive your card number.

About the child

  • Profile basics — first name or a nickname, age, grade or year, and a chosen avatar.
  • Learning preferences and goals — subjects you or your child pick, interests, session length, and low-distraction preferences.
  • Learning activity — which activities ran, what the child answered in structured activities, how long a session lasted, which skills were practiced, and structured evidence of progress.
  • Live voice, while a session is running — the child’s speech is streamed to our AI provider to understand what they said and speak back. See Section 5.
  • Safety events — if Rusty detects a possible safety concern, it records a category and a short non-verbatim note so it can alert you. It does not save your child’s exact words.

What Rusty deliberately does not collect

These are product decisions enforced in the software, not just promises:

  • No saved recordings of your child’s voice. Audio is streamed for the live conversation and is not written to our storage.
  • No saved transcripts of what your child said.
  • No free-text answers typed by a child are stored. Where a child picks an answer, we store the fixed choice, not free writing.
  • No photos or homework uploads. The camera and photo library are not used by Rusty at all.
  • No drawings are saved. The whiteboard stays on the device, and Rusty does not interpret it.
  • No precise location, no contacts, no advertising identifiers and no child-facing third-party analytics.
4.

Verifying That You Are an Adult

Before Rusty asks for a child’s name, age, or anything else about them, we verify that an adult is making the decision. COPPA calls this verifiable parental consent.

We use Kids Web Services (KWS), operated by Epic Games, Inc. KWS emails you a link, runs the adult check on its own secure pages, and tells Rusty only whether the check passed.

Rusty never sees and never stores what you give KWS — no card number, Social Security number, ID document, face scan, or answers to identity questions. Rusty stores only a scrambled reference code, which method category was used, whether it passed, and when it expires.

Rusty does not use a math problem, a birth-year prompt, or a “tap if you are a grown-up” button as parental verification. Those are not verification.

5.

AI Voice and Text Processing (Important)

Rusty’s tutoring is powered by an AI model. We use Google’s Gemini models on Google Cloud to understand what your child says, generate Rusty’s spoken reply, and notice possible safety concerns during a session.

What is sent to Google

  • The child’s live speech while a voice session is open.
  • A small amount of context: the name Rusty should use, age, grade, and — only if you turned personalization on — saved goals, interests, and learning preferences.
  • Rusty’s own instructions and the results of activities your child completed.

Your child’s device never holds Google credentials. Sessions are routed through Rusty’s own server, which holds the credential and configures the session.

How long Google keeps it

Google states that it does not use this content to train or fine-tune its AI models. Separately, Google runs automated abuse monitoring:

Please read this part carefully. Rusty has asked Google not to keep any of this content, and Google has not granted that request yet. Until it does: if Google’s automated safety systems flag a session, Google may keep that session’s content for up to 90 days to check it against its abuse rules. This happens only for flagged sessions, the content stays in Google’s United States region, and it is not used to train AI models. Rusty still never saves your child’s raw audio or transcripts.

We ask you to acknowledge this specifically, in the app, before you turn voice on. If Google grants our request, we will update this section and tell you.

Rusty also uses Google to generate short spoken instructions on some screens. The same terms apply.

6.

How We Use Information

  • Run the tutoring session and the activities inside it.
  • Decide what to teach next, based on what your child has actually demonstrated.
  • Show you plain-language summaries of what happened in a session.
  • Detect possible safety concerns and alert you.
  • Keep the Service secure, prevent abuse, and fix problems.
  • Provide and reconcile subscriptions, and meet our legal obligations.
We never: sell or rent children’s personal information; use it for behavioral or targeted advertising; show third-party ads to children; build advertising profiles; or condition your child’s participation on giving us more information than is reasonably necessary for the activity.
7.

How Long We Keep Information

We keep children’s personal information only as long as is reasonably necessary for the purpose it was collected for. We do not keep it indefinitely. The full schedule is on our Child Data Retention page. In summary:

InformationWhy we keep itHow long
Live audio and speech textProduce the current spoken replyNot stored by Rusty. See Section 5 for Google’s abuse-monitoring window.
Child profile, goals, preferencesRun the profile you set upWhile the profile is active and consent is valid
Detailed learning sessions and evidenceProgress and continuity12 months, then deleted automatically
Safety event category and short noteAlert you to a possible concern30 days
Adult-verification result and consent historyShow and administer your authorizationWhile the family account is active
Unsuccessful or pending verification metadataFinish or debug the check30 days
8.

Your Rights as a Parent

At any time, and without giving a reason, you can:

  • Review the personal information Rusty holds about your child, and export it as a file.
  • Correct your child’s profile details.
  • Refuse further collection — turn off voice, personalization, or summaries, or archive the profile.
  • Revoke your consent, which stops the affected processing going forward.
  • Delete an individual child’s information, or your entire account and family.

Most of this is self-service in the app under Parent Settings → Privacy & Data. You can also email privacy@userusty.com. Because these requests concern a child’s information, we take reasonable steps to confirm we are dealing with the child’s parent before acting. Full instructions are on our Contact & Privacy Rights page.

If you revoke consent for something a feature depends on, that feature stops working. If you revoke consent for voice, Rusty’s spoken tutoring stops; the rest of the profile remains until you delete it.

9.

Security

We maintain a written security program for children’s personal information, with safeguards appropriate to its sensitivity and to our size. Information is encrypted in transit and at rest, access is restricted, one family cannot read another family’s data, and one child’s data is isolated from a sibling’s. A device linked to a single child cannot reach parent controls or other children.

No system is perfectly secure. If a breach affects children’s personal information, we will notify affected parents and any regulators as required by law.

10.

Notice and Consent Changes

If we materially change how we collect, use, or disclose children’s personal information, we will send you a new direct notice and obtain your consent again before the change applies to your child. We will also update the date at the top of this page.

11.

Other Companies That Handle Information

These companies process information on our behalf under contracts that require them to protect it and use it only for us. They are not permitted to sell it or use it for their own advertising. The current list, with what each one receives, is on our Service Providers page.

You may contact us at privacy@userusty.com about any of them, and we will respond to questions about all of our providers’ practices.

12.

Questions and Complaints

Email privacy@userusty.com. You may also contact the U.S. Federal Trade Commission at ftc.gov.

Rusty is not certified, endorsed, or approved by the Federal Trade Commission or by any COPPA safe-harbor program, and we do not claim to be. This policy describes our actual practices.