Privacy Policy

Little Grandmasters Ltd. (“Little Grandmasters”, “we”, “us” or “our”) is committed to protecting the privacy of users of our website at little-grandmasters.com, jupo.world and sakkpalota.app and our apps, Jupo World App and Sakkpalota App (together, the “Platform”), and of the parents/guardians and children who use our products and services (“Services”). This Privacy Policy (“Policy”) explains how we collect, use, disclose, retain, and safeguard your personal information, including information about children, and how you can exercise your privacy rights.

This policy sets out:

• the information we collect about you when you visit our website, use our products or services, or otherwise interact with us;
• how we use, share, store, and secure the information; and
• how you may access and control the information.

In this policy, “Little Grandmasters” or “we” refers to Little Grandmasters Limited of The Coach House, Eton Avenue NW3 London, UK and “Platform” means our website at little-grandmasters.com, sakkpalota.app and jupo.world and our software, namely Sakkpalota App and Jupo World App.

In this policy, “personal information” refers to any data, information, or combination of data and information that is provided by you to us, or through your use of our products or services, that relates to an identifiable individual.

By accessing or using the Platform or otherwise interacting with us, you agree that your personal information will be handled as described in this Policy.

We may update this Policy from time to time in accordance with applicable law. If we make material changes, we will provide appropriate notice and, where required, secure parental consent for any changes affecting children's data practices.

1. What information we collect about you

1.1. We collect the following types of information about you:

• account and profile information that you provide when you register for an account or sign up for our products or services, for example name, user name, email or other whatever is allowed (collectively, “Account Data”);
• information you provide through support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data”);
• communication, marketing, and other preferences that you set when you set up your account or profile, or when you participate in a survey or a questionnaire that we send you (collectively, “Preference Data”);
• details of any transactions, purchases, or orders that you've made with us (collectively, “Transaction Data”);
• payment information, for example card details and other tbc (collectively, “Financial Data”);
• information about your device or connection, for example and information we collect through cookies and other data collection technologies (please read our Cookies Policy for details) (collectively, “Technical Data”); and
• information about your use of or visit to our Platform, for example (collectively, “Usage Data”).

1.2. Information Collected Automatically. We collect certain information automatically when you use our Services. This information may vary, but primarily includes the following:

• App and Sites activity and usage data
• Types of content viewed, downloaded, or interacted with
• Functions used and actions performed
• Information on when a user takes a screenshot within the app (note that we cannot see the contents of the screenshot)
• Frequency of use and duration of the activities and games
• Progress and achievements: activities completed, curriculum progress, grades, and progress reports (Plus version)
• Age of the account (account tenure)
• Activation of notifications, including push notifications (collected only from users who have completed the onboarding process)
• Session duration
• Total time spent actively using the App
• Device and other mobile identifiers, including cookies
• Device language
• IP address
• General device location data (derived from IP address)
• Internet service provider
• User settings

1.3. Crash Reports. If you provide crash reports, we may collect personal information related to such crash reports, including detailed diagnostic information about your device and the activities that led to the crash.

1.4. Cookies and Other Tracking Technologies. We and our service providers also collect data through cookies, pixel tags, web beacons, and other technologies (“Technologies”). These technologies collect information about your use of our services, see Cookies Policy.

We do not collect sensitive data or special category data about you. This includes details about your race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual orientation.

1.5. Information from Third Parties. We may obtain information from third-party services or partners, for example: identity information you provide through third-party login services (e.g., Apple/Google); aggregate analytics from service providers used to support improvement and personalisation of the Platform.

2. How we use information we collect

2.1. We only use your personal information where the law allows us to. We use your personal information only where:

• we need to perform the contract we have entered into (or are about to enter into) with you, including to operate our products or services, to provide customer support and personalised features, and to protect the safety and security of our Platform;
• it satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests, for example for research and development, and in order to protect our legal rights and interests;
• you've given us consent to do so for a specific purpose, for example we may send you direct marketing materials or publish your information as part of our testimonials or customer stories to promote our products or services with your permission; or
• we need to comply with a legal or regulatory obligation.

2.2. If you have given us consent to use your personal information for a specific purpose, you have the right to withdraw your consent any time by contacting us (please refer to paragraph 13 for contact information), but please note this will not affect any use of your information that has already taken place.

2.3. We do not share your personal information with any company outside our group for marketing purpose, unless with your express specific consent to do so.

2.4. Marketing and Promotion. With parental consent, to communicate about new features, offers, or promotions via email or in-app messaging. We do not use child-collected information for marketing or advertising.

2.5. We only use personal information when permitted by law, including when necessary to perform a contract (e.g., subscription fulfillment), comply with legal obligations, protect our legitimate interests, or where you have consented.

3. Children's privacy

Protecting the privacy of children is especially important to us. Our Services are designed to be a closed ecosystem in which children cannot access broader internet content, share information with others, or be targeted with advertisements.

3.1. Parental Consent and Control.

• Only a parent or legal guardian may create an account for a child and provide their information.
• We do not require more information than reasonably necessary for the child to participate in educational activities.
• Parents may review, correct, delete, or refuse further collection of their child's personal information at any time by contacting us or using tools available in the Platform.

3.2. Use of Children's Information. Children's personal information is used to:

• Personalise learning content and progress tracking.
• Estimate usage patterns for educational insights.
• Generate reports on progress for parental review.

Parents may object to processing at any time. Other than as described in this Policy, children's personal information is never sold, rented, or shared with advertisers or ad networks.

3.3. Disclosure of Children's Information. We may disclose children's information:

• To service providers acting on our behalf under contract.
• If required by law, legal process, or to protect rights, safety, or property.
• If a parent chooses to share content from the App (such as achievements) via secure shareable links.

If we learn we have inadvertently collected personal information from a child without appropriate consent, we will delete it promptly.

4. How we share information we collect

4.1. We share information with other companies in our group in order to operate our Platform and to offer and improve our products and services.

4.2. We may share personal information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our products and services.

4.3. If you use any third-party software in connection with our products or services, for example any third-party software that our Platform integrates with, you might give the third-party software provider access to your account and information. Policies and procedures of third-party software providers are not controlled by us, and this policy does not cover how your information is collected or used by third-party software providers. We encourage you to review the privacy policies of third-party software providers before you use the third-party software.

4.4. Our Platform may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party websites before you submit information to them.

4.5. We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.

4.6. If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify you if such transaction takes place and inform you of any choices you may have regarding your information.

5. Retention of your data

We retain personal information only as long as necessary to fulfil the purposes for which it was collected, including to comply with legal obligations, resolve disputes, or enforce agreements. After the retention period, personal information is securely deleted or anonymised.

6. Security of your data

We implement organisational, technical, and administrative safeguards to protect personal information from unauthorised access, alteration, loss, disclosure, or destruction, consistent with industry standards. However, no system can be completely secure; therefore, we cannot guarantee absolute protection. In the event of a security breach that could materially affect user privacy or rights, we will provide notice as required by law.

7. Cookies and tracking technologies

We use cookies and similar technologies to support the functionality and analytics of our Site and Platform. These can be managed via browser or device settings. See also the Cookies Policy below.

8. How we store and secure information we collect

8.1. We use data hosting service providers such as Firebase or similar services to host the information we collect.

8.2. We have adopted the following measures to protect the security and integrity of your personal information:

• access to your personal information is restricted to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality; and
• our information collection, storage, and processing practices are reviewed regularly.

8.3. We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.4. While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.

8.5. We only retain personal information for so long as it is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After such time, we will delete or anonymise your information, or if this is not possible, we will securely store your information and isolate it from further use. We periodically review the basis and appropriateness of our data retention policy.

9. How we transfer information internationally

9.1. We collect information globally. We transfer, process, and store your information outside your country of residence where we or our service providers operate for the purpose of providing our products and services to you.

9.2. Some of the countries in which our companies or service providers are located may not have the privacy and data protection laws that are equivalent to those in your country of residence. When we share information with these companies or service providers, we make use of contractual clauses, corporate rules, and other appropriate mechanisms to safeguard the transfer of information.

10. Your rights

10.1. You have the right to:

• be informed of what we do with your personal information;
• request a copy of personal information we hold about you;
• require us to correct any inaccuracy or error in any personal information we hold about you;
• request erasure of your personal information (note, however, that we may not always be able to comply with your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);
• object to or restrict the processing by us of your personal information (including for marketing purposes);
• request to receive some of your personal information in a structured, commonly used, and machine readable format, and request that we transfer such information to another party; and
• withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent).

10.2. You may opt out of receiving marketing materials from us by using the unsubscribe link in our communications, by updating your preferences within your account on our Platform, or by contacting us. Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary for the use of our products or services.

10.3. As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.

10.4. Any request under paragraph 10.1 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.

10.5. We will aim to respond to all legitimate requests within one (1) month at the best of our ability. Occasionally, it may take us longer than a month, especially if your request is particularly complex or if you have made a number of requests.

11. Changes to this policy

We may amend this policy from time to time by posting the updated policy on our Platform. By continuing to use our Platform after the changes come into effect, you agree to be bound by the revised policy.

12. Policy towards children

If we become aware that an individual under 4 has provided us with personal information, we will take steps to delete such information. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under 4.

COPPA. With regards to the Children's Online Privacy Protection Act (“COPPA”), we collect personal information from children under the age of 13 for the sole purpose of performing internal operations. If we discover that we have unknowingly collected additional personal information from these children, we will delete it. If you believe this to be the case, please contact us.

13. Contact us

13.1. Please contact us at privacy@little-grandmasters.com or submit any written request to:

Little Grandmasters Limited
The Coach House, Eton Avenue, NW3 3EL London, UK
Attn: CEO

We will respond in accordance with applicable law.

13.2. Please contact us in the first instance if you have any questions or concerns. If you have unresolved concerns, you have the right to file a complaint with a data protection authority in the country where you live or work or where you feel your rights have been infringed. If you reside in the United Kingdom, you may file a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

Cookies Policy

The full list of what this website stores, and how to change your choice, is on the Cookies page.

Cookies are small text files that are placed on your device by a web server when you access our Platform. We use cookies to identify your access and monitor usage and web traffic on our Platform to customise and improve our products and services.

We use both persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session lasts (usually the current visit to a website or a browser session).

We use the following types of cookies:

• Strictly necessary cookies: these are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies: these allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are easily finding what they are looking for.
• Functionality cookies: these are used to recognise you when you return to our site.
• Targeting cookies: these cookies record your visit to our site, the pages you have visited, and the links you have followed.

You can block cookies by activating the setting on your browser that allows you to refuse the use of all or some cookies. However, if you do so, you may not be able to access all or parts of our site.

Analytics on this website

We use GameAnalytics to understand how this website and our web version of the game are used: for example which pages are visited and whether visitors go on to download the app. GameAnalytics stores a randomly generated identifier in your browser's local storage so that repeat visits can be counted as one visitor rather than many. That identifier is not linked to your name or email address, is not used for advertising, and is not sold or shared with advertisers.

Analytics are only enabled if you accept them. When you first visit, we ask; if you decline, the analytics software is never downloaded and nothing is recorded. You can change your mind at any time by clearing this site's data in your browser settings, which will remove the stored choice and the identifier, and we will ask again on your next visit.