Hello! At KidsDi we take children privacy very seriously. Our KidsDi puzzles games apps (“apps/app”) are designed especially for children, with special attention to online privacy. This Privacy Policy governs the right of kids and their parents of legal guardians, their use of our apps, as well as their relationship with KidsDi.
KidsDi, as a data controller, fully complies with the General Data Protection Regulation EU 2016/679 (“GDPR”) and the Children’s Online Privacy Protection Act of 1998 (COPPA).
In this Privacy Policy, KidsDi will sometimes be referred to as ‘we’, ‘us’, or ‘our’. Additionally, there are references to “you”. In these instances, “you” – kid’s parent or legal guardian – a user of our apps (“user”).
Our apps provide parents with access to in-app subscription purchases, our privacy policy, terms of use. All such information is secured behind a parental gate.
By downloading any of our apps onto your device, you give us consent to this Privacy Policy and our Terms of Use. We display the link to our Privacy Policy in our website’s footer at https://kidsdi.com/, within the Google Play store and App store listing pages and within the apps.
This Privacy Policy is effective as of February 02, 2021 and was last modified on February 02, 2021.
Definitions
Personal data: Any information that can be used to identify an individual, whether directly or indirectly.
Data subject: You, with regards to your personal data.
Controller: KidsDi Ltd (Company number 12355387) registered at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.
Processor: Any natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Processing: Any operation performed on personal data, whether or not by automated means.
KidsDi puzzles apps:
Personal information we may collect via our app
We do not knowingly collect any personal information from children.
In general, we do not require nor request any personal information from you when you use our apps.
In the event we collect personal information from you, we will only use it to the limited extent required to provide you with the services you have requested (e.g., to send you an e-mail) or to respond to your inquiries. In no event will we ever sell, rent or transfer your personal information to third parties for direct marketing purposes, for monetary or other valuable consideration.
Non-personal information we may collect via our apps
Within the apps’ usage, we may collect the following information:
Apps usage data, the information about how apps are used, including the preferred language (geography), the date and time when the app was firstly installed and the date and time the app was last used.
This data will be retained for the duration of your use of our apps and will be completely deleted after 30 days from the date our app is deleted from your device.
Purchase history, if you choose to purchase an app subscription, the confirmation that you are a paid subscriber to the app.
This data will be retained for the duration of your use of our app and will be completely deleted after 30 days from the date our app is deleted from your device.
Device data, such as your mobile device operating system type and version number, manufacturer and model, device ID, push tokens, Google Advertising ID, Apple Identifier for Advertisers (IDFA), browser type, screen resolution, and other information about the device you are using to visit the apps.
This data will be retained for the duration of your use of our app and will be completely deleted after 30 days from the date our app is deleted from your device.
Online activity data, such as information about your use of and actions on the apps, including pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. We may collect this information directly or through our use of third-party software development kits (“SDKs”) e.g. Facebook)). SDKs may enable third parties to collect information directly from our apps.
This data will be retained for the duration of your use of our app and will be completely deleted after 30 days from the date our app is deleted from your device.
All collected non-personal information listed above are deidentified, in aggregated form.
How we use and disclose the non-personal information that we collect
We do not share non-personal information with third parties, except as necessary for our legitimate business needs, to carry out your requests, and/or as required or permitted by law. This includes:
Service providers
We transfer information only to certain third-party service providers so they can process your information on our behalf to help us operate our app (such as analytics, marketing) or to handling payments through those third-party service providers’ services. We only share non-personal information that allows them to provide their services to us.
Non-personal information is collected for the following purposes and using the following services:
Facebook Analytics
All collected non-personal information is stored on the servers controlled by Facebook (or its wholly-owned subsidiaries).
Facebook Analytics is an analytics services provided by Facebook, Inc. (US) and Facebook Ireland Limited that helps us to measure the apps traffic and to understand how people are using our apps.
For more information on how Facebook uses the collected information, please visit the Privacy Policy page: https://www.facebook.com/about/privacy/
Type of data processed: Device data; App usage data, Online activity data.
Legal basis for processing: your consent; our legitimate interests – meeting our contractual obligations to Facebook under Facebook Business Tools Terms and allowing the Facebook analytics to work on our app.
Opt-out: You can opt out from the Facebook analytics by emailing us at [email protected] with a request to switch off the data collection from analytics Facebook servers.
Security
We and/or our third-party partners have put in place physical, electronic, and managerial procedures to attempt to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information collected through the apps. We take, or obligate applicable third parties to take, reasonable precautions to protect our users' information against loss, misuse, unauthorized disclosure, alteration, and destruction.
If you believe your information is being improperly used by us or any third party, please immediately contact us using “Security Concern” in the subject line.
Storage of information
We will store your personal data for as long as necessary in order to provide you with the apps or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.
Your personal data are deleted or anonymized as soon as it no longer serves one of the above-mentioned purposes.
Access by our contractors
We or our contractors undertake regular maintenance of your data. All third parties must agree to observe the privacy of our users, and to protect the confidentiality of their information. This means your data cannot be shared with others, and there must be no direct marketing by the third parties.
Changes to this Privacy Policy
We reserve the right, at our sole discretion, to change, modify or otherwise alter this Privacy Policy at any time. You can always check the latest version of our Privacy Policy on the app. If you do not agree to any modifications to this Privacy Policy, you can stop to use the app. Your continued use of the app following the posting of any modifications to this Privacy Policy will constitute your acceptance of the revised Privacy Policy.
International Users
Your information may be stored and processed in any country where we and/or our third-party partners have facilities, and by using the app you consent to the transfer of your information to countries, including the United States, which may be outside of your country of residence and may provide for different and less stringent data protection rules than in your country.
If you object to your information being transferred or used as described in this Privacy Policy, please do not use the app and immediately delete it from your device.
The rights of Users
EU and UK residents
The United Kingdom Data Protection Act 2018 (UK GDPR) and The EU General Data Protection Regulation (EU GDPR) provides the following rights for individuals:
How to exercise these rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and at the latest within one month.
Californian users
This part of the document uses the term «personal information» as it is defined in The California Consumer Privacy Act (CCPA). We do not knowingly collect personally identifiable information from children.
All collected personal information listed below are deidentified, in aggregated form. This means that such information cannot be considered in the meaning of "personal information", as it is defined in the CCPA.
Categories of personal information collected, disclosed or sold
Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.
This means that, for example, a sale can happen whenever the app makes statistical analyses on the traffic or views. It is not a sale if a consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party.
We do not share your personal information for money or other valuable consideration. We do share personal information with certain third parties, which may be considered a “sale” under California law even if we don’t receive money in exchange for the information.
You have the right to instruct us to stop the kind of sharing that the CCPA treats as "sales" and not to engage in that kind of sharing in the future unless you choose to allow it (by emailing to us). Please be aware there may be circumstances where we can share information with others even if you instruct us to stop "selling" your personal information, as permitted under the CCPA. For example, we may still be able to share information with our service providers so that they can provide services to us. In addition, your instruction to stop "selling" your personal information will not affect sharing that occurred before you gave us the instruction.
The rights
The CCPA provides the following rights for individuals:
How to exercise these rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and at the latest within one month.
Sources of personal information
How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter in a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.
We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our app, for example to make payment via Google Pay or Apple Pay.
To find out more about the purposes of processing, please refer to the section «Service Providers» of this document.
What are the purposes for which we use your personal information?
We use your personal information to allow the operational functioning of our app and features thereof (“business purposes”).
We also use your personal information for commercial purposes (as indicated within the section «Service Providers» of this document) and you have the right to opt out of the sale of your personal information (as indicated within the section «Service Providers» of this document).
Contact us
KidsDi Ltd
71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
e-mail [email protected]