# Privacy Policy for Learn Animals **Last updated: August 31, 2026** This Privacy Policy describes how Sasa Kolda / BabyNewt ("we," "us," or "our") handles information in connection with the "Learn Animals" mobile application (the "App"), available on iOS and Android (bundle/package identifier `com.babynewt.learnanimals`). By downloading, installing, or using the App, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the App. ## 1. Summary The App is a children's educational card game. It does not require account creation, does not collect your name, email address, or other direct contact information, and does not contain third-party advertising. The App collects a limited amount of anonymous/pseudonymous usage data (through Firebase Analytics) and purchase-status data (through RevenueCat, Apple, and Google) as described below. ## 2. Information We Collect ### 2.1 Information collected automatically (analytics) The App uses **Firebase Analytics** (a service provided by Google) to understand aggregate, anonymous usage of the App so we can improve it. This may include: - App events, such as which screen or theme is opened, which mode (Learn/Test) is selected, and which in-app actions are taken. - Technical/device information, such as app version, operating system and version, device model, language/locale, and general (country-level) location derived from IP address. - A randomly generated, pseudonymous app-instance identifier that is not tied to your name or any other directly identifying information. We do not use this data to build advertising profiles, and the App does not display or serve third-party advertisements. ### 2.2 Purchase and subscription information The App offers an optional one-time ("lifetime") in-app purchase to unlock additional content. Purchases are processed entirely by **Apple App Store** or **Google Play Billing** — we never see, collect, or store your payment card number, bank details, or other payment credentials. To determine what you've unlocked, the App uses **RevenueCat**, a third-party purchase- management service, which receives: - A randomly generated App User ID (not your name or email, unless you have a RevenueCat or platform account you separately choose to link). - Purchase/transaction and subscription-entitlement status (e.g., whether the "unlock all themes" purchase is active), receipt data, and device/platform information needed to validate purchases. ### 2.3 Information stored only on your device Your selected language and audio (mute) preference are stored locally on your device (using on-device storage) so the App remembers your settings. This information is not transmitted to us or to any third party. ### 2.4 Information we do not collect The App does not collect, and does not request permission to access: your precise location, contacts, photos/camera, microphone recordings, calendar, or any other sensitive device data. The App does not require you to create an account, sign in, or provide your name, email address, or phone number. ## 3. How We Use Information We use the limited information described above to: - Operate, maintain, and improve the App (e.g., understand which features are used and fix bugs or crashes). - Determine and unlock purchased content. - Comply with legal obligations and enforce our Terms of Use. We do not sell your information, and we do not use it for third-party advertising or cross-app tracking. ## 4. How Information Is Shared We share information only with the service providers who help us operate the App, and only for that purpose: - **Google (Firebase Analytics)** — processes usage/analytics data as described in Section 2.1. See Google's Privacy Policy: https://policies.google.com/privacy - **RevenueCat, Inc.** — processes purchase/entitlement data as described in Section 2.2. See RevenueCat's Privacy Policy: https://www.revenuecat.com/privacy - **Apple Inc. / Google LLC** — process your purchase and payment as the app-store operator and payment processor for your device's platform. We do not otherwise sell, rent, or share your information with third parties for their own marketing purposes. ## 5. Children's Privacy The App is designed to be suitable for children and is intended to be used by children under the supervision of a parent or guardian. - We do not knowingly collect personal information (such as name, email address, or precise location) from children. - Any purchase in the App is gated behind a **parental gate** (a simple math challenge) specifically designed to prevent a young child from initiating a purchase or leaving the App without an adult's involvement. - The App does not contain third-party advertising and does not use data for behavioral advertising directed at children. - The analytics information described in Section 2.1 is limited, aggregate, and pseudonymous, and is used solely to understand and improve App functionality — not to build advertising profiles of any user, including children. If you are a parent or guardian and believe your child has provided us with personal information in a manner not described here, please contact us at info@babynewt.com so we can investigate and, if applicable, delete it. We comply with the Children's Online Privacy Protection Act (COPPA) and equivalent regulations in other jurisdictions to the extent they apply to the App. ## 6. Data Retention Analytics and purchase-entitlement data is retained by us and our service providers only for as long as reasonably necessary for the purposes described in this Policy, or as required by law, after which it is deleted or anonymized in accordance with our service providers' own retention practices. ## 7. Your Rights and Choices Depending on your location, you may have rights to request access to, correction of, or deletion of personal information associated with you, or to object to certain processing. Because the App does not collect directly identifying information, we may only be able to act on requests tied to information you can help us locate (e.g., an approximate purchase date and platform). To make a request, contact us at info@babynewt.com. You can also reset or limit analytics collection using your device's platform-level privacy controls (e.g., "Limit Ad Tracking" / App Tracking Transparency settings on iOS, or Google's Ads Settings on Android), where applicable. ## 8. Data Security We rely on reputable service providers (Google/Firebase, RevenueCat, Apple, Google Play) that maintain industry-standard technical and organizational safeguards. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security. ## 9. International Data Transfers Our service providers may process and store information on servers located outside of your country of residence, including in the United States. By using the App, you acknowledge that your information may be transferred to and processed in such jurisdictions, which may have different data protection laws than your own. ## 10. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in the App, applicable law, or our data practices. We will update the "Last updated" date above when we do. Material changes will, where required by law, be notified through the App or the applicable app store listing. Your continued use of the App after a change becomes effective constitutes acceptance of the revised Policy. ## 11. Contact Us If you have questions about this Privacy Policy or our data practices, contact us at: Sasa Kolda / Baby Newt info@babynewt.com Zagreb, Croatia