1. Purpose
Standard 1 of the Information Commissioner’s Age Appropriate Design Code requires information society services likely to be accessed by children to act in the best interests of the child. This document records how budgii meets that obligation. It is applicable in the UK and is used as the equivalent internal standard in Australia, New Zealand, and the United States.
It draws on the framework of the UN Convention on the Rights of the Child (UNCRC), General comment No. 25 on children’s rights in relation to the digital environment, and guidance published by the UK Information Commissioner’s Office.
2. Framework
For every product decision that affects Children, budgii considers the following rights drawn from the UNCRC:
| Term | Meaning |
|---|---|
| Article 3: Best interests of the child | In all actions concerning children, the best interests of the child shall be a primary consideration. |
| Article 5: Evolving capacities | Services should respect the responsibilities, rights, and duties of parents and guardians to provide direction to the child in a manner consistent with the evolving capacities of the child. |
| Article 6: Life, survival, and development | Children have the right to develop, and services should support rather than impede that development. |
| Article 12: Right to be heard | Children have the right to express their views freely in all matters affecting them. |
| Article 13: Freedom of expression | Children have the right to seek, receive, and impart information and ideas. |
| Article 16: Right to privacy | Children have the right to be protected from arbitrary or unlawful interference with their privacy. |
| Article 17: Access to information | Children have access to information from a diversity of sources, with appropriate protections from material injurious to their wellbeing. |
| Article 19: Protection from harm | Children have the right to protection from all forms of physical or mental violence, injury, or abuse. |
| Article 31: Rest, leisure, and play | Children have the right to rest and leisure, engage in play appropriate to their age, and participate in cultural life. |
3. Design principles
The following principles operationalise those rights inside the budgii product:
3.1 A Child's participation is supported, not manufactured
Budgii is designed to give Children a genuine role in running the household. Rewards recognise real effort. The reward shop reflects what the Child and the Parent have agreed is valuable. Streaks reflect real consistency. The goal is participation that contributes to the Child’s sense of competence and belonging, in line with Article 12 and Article 6.
3.2 No dark patterns
We do not use manipulative mechanics such as fear of loss, artificial urgency, unpredictable reward schedules, or social pressure to drive engagement. Levels, streaks, and rewards are predictable and transparent. Missing a day breaks a Chain, but the Chain is always rebuildable, and no permanent penalty attaches to a missed day.
3.3 High-privacy defaults
The default for every Child profile is the highest-privacy configuration: no data sharing, no location tracking, no behavioural advertising, no external profiling, no third-party marketing. A Parent cannot reduce these protections below the default through any Admin setting.
3.4 Age-appropriate language and expectations
Child-facing copy is written at a reading level appropriate for age 5 to 12 and reviewed against that benchmark. Onboarding for a Child uses single-line sentences and tap-only interactions. Age bracket informs the reward calibration to avoid demanding developmentally inappropriate behaviour.
3.5 No AI-generated content shown to Children
No AI-generated content about a Child is ever shown to the Child. This includes the Nest Report and any derived observations. Children see their own activity data, levels, Chains, and rewards, which are deterministic and not AI- generated.
3.6 Parental oversight without surveillance framing
Parents see their Child’s activity in budgii because Parents are running the household and are the legal account holders. budgii avoids framing this as surveillance. The Nest Report is written to support the Parent’s understanding of the Child’s development, not to rate or judge the Child.
3.7 No Child-to-Child or Child-to-stranger contact
Budgii has no social, messaging, or peer-to-peer feature open to Children. Children in different households cannot contact each other through budgii. This closes off one of the most significant categories of online risk to Children.
3.8 Protection from coercive use
The Acceptable Use Policy expressly prohibits use of Coins, rewards, or Chain mechanics to withhold essential needs (food, shelter, hygiene, medical care) from a Child. budgii will enforce this policy and may report serious concerns to child welfare authorities.
4. Specific product decisions
Examples of product decisions made in light of this framework:
| Term | Meaning |
|---|---|
| No public profiles | Children have no public profile. Avatars are confined to the household view. (Privacy / Article 16.) |
| No leaderboards between families | Children are never ranked against Children in other households. Comparison is limited to the Child's own history. (Development / Article 6.) |
| No streaks without a soft recovery | A broken Chain restarts without a shaming message. The copy is matter-of-fact, not punishing. (Protection from harm / Article 19.) |
| Child sees their own Coins, not a comparative rank | The Child sees their own balance and progress. They do not see a ranking or scoreboard. (Development / Article 6.) |
| Age-gated reward access | Reward categories are guided by age bracket so that rewards are age-appropriate. |
| No AI writes to the Child | AI does not generate content delivered to a Child. All Child-facing copy is written and reviewed by humans. (Protection / Article 19.) |
| Plain-language Parent report | Nest Report is explicitly non-clinical and non-diagnostic. Safety layer blocks clinical terminology. (Best interests / Article 3, and development / Article 6.) |
| No profiling beyond the app | Children's behavioural data is not used to build external profiles, is not shared for advertising, and is not used to train any AI model. |
| No microtransactions for Children | Children cannot spend real money in the app. Coins are earned only. There are no in-app purchases of any kind targeted at the Child. |
| Account deletion by either Parent | Either adult leader can remove a Child from the household at any time, protecting against scenarios where one adult attempts to lock the other out of the Child's data. |
5. The Child's own voice
Article 12 of the UNCRC guarantees Children the right to be heard in matters affecting them. The budgii approach to this includes:
- Rewards are chosen by the Child from the Nest shop, not imposed. Children's preferences drive what they save for.
- The Child controls when a to-do is marked complete (subject to Parent confirmation).
- A Child can always decline to use budgii. Parents are reminded that budgii is not to be used coercively.
- Future releases will include a mechanism for Children to provide feedback on the app experience to budgii directly, with appropriate safeguards.
6. Tensions we have resolved
6.1 Parental oversight vs. Child autonomy
A Parent can see everything the Child does in the app. This is necessary for the household management model and consistent with Article 5 (evolving capacities / parental guidance). We resolve the tension by limiting the data collected to what a reasonable Parent would observe at home anyway (task completion, participation, effort), and by excluding categories that would extend Parental oversight into deeper surveillance (location, voice, messaging).
6.2 Rewards vs. intrinsic motivation
There is a credible argument that extrinsic rewards can crowd out intrinsic motivation. We resolve this by (i) pairing rewards with Parent-initiated recognition moments rather than rewards alone, (ii) scaling reward intensity by age bracket, and (iii) encouraging Parents through onboarding and editorial content to treat rewards as structure, not bribery. The Resources library specifically addresses this topic.
6.3 Engagement vs. wellbeing
A reward-driven app can pull Children toward excessive engagement. We resolve this by (i) not rewarding time in the app (the Chain rewards consistent completion, not continuous use), (ii) capping daily rewards so there is no infinite grind, and (iii) not sending push notifications to Children.
6.4 AI assistance vs. child safety
AI-generated content creates novel risks when it concerns Children. We resolve this by excluding Children entirely from receiving AI-generated content about themselves, limiting the AI input to non-identifying behavioural data, applying a clinical-term and harmful-content safety layer to every generated Nest Report, and using fallback reports whenever safety validation fails.
7. Review
This assessment is reviewed at least annually, and whenever:
- A new feature likely to be accessed by Children is introduced.
- Applicable Children's rights or data protection law changes materially.
- Regulatory guidance from the ICO, OAIC, OPC (NZ), or FTC relevant to Children's services is updated.
- A safety incident, complaint, or feedback prompts re-examination of a specific decision.
8. Contact
Questions, feedback, or concerns about how budgii serves Children’s interests:
Budgii PTY LTD
ABN 50 696 945 169 | ACN 696 945 169
Sydney, New South Wales, Australia