Privacy Policy

This policy explains what information Jupo World collects, why, who helps us handle it, how long we keep it and what you can do about it. Jupo World is a learning game for children aged 4 to 10, built on the Chess Palace method. Children play; grown-ups set things up, manage accounts and make the choices this policy describes.

It covers the Jupo World app on iPhone, iPad and Android, the Jupo World game in a web browser at play.jupo.world, and this website, jupo.world, including the signed-in areas for families. It does not cover the Sakkpalota app or sakkpalota.app, which have their own privacy policy.

The short version

• We collect what we need to run the game, save progress and look after your family's account. We do not show ads and we do not sell personal information.
• Children never need an email address or a password. A parent or another adult sets up and manages the family.
• Website analytics only run if you say yes, and never on pages for children, in the game or in the signed-in areas.
• You can download your family's data, remove a child or delete everything yourself, from the web or the app.
• Most of our data is stored in the European Union. Some services we use are in the United States, and we protect those transfers with standard contracts.
• This is a draft. Some features it mentions are not available yet; where that is the case, we say so.

1. Who we are and how to reach us

Jupo World is run by Little Grandmasters Limited, a company registered in the United Kingdom (company number [PLACEHOLDER: PH-01 company number], registered office The Coach House, Eton Avenue, London NW3 3EL, UK). In this policy "we", "us" and "our" mean Little Grandmasters Limited. We decide how and why your information is used, which makes us the controller under data protection law.

For anything about privacy, write to privacy@little-grandmasters.com. You can write in any of our eight languages: English, Hungarian, German, Spanish, French, Italian, Finnish or Turkish.

Our representative in the European Union: [PLACEHOLDER: PH-04 EU representative name and address]. You can contact them instead of us about anything in this policy.

Data protection officer: [PLACEHOLDER: PH-05 DPO appointed or not, and contact].

2. Who this policy is for

• Parents and other adults who manage a family (we call them parents in this policy, including guardians and other carers).
• Children who play. Our Children's Privacy Notice explains, for parents, exactly what we collect from children and why. Read it together with this policy.
• Teachers and schools. Teacher accounts are covered here. Classroom play under a school's authority is covered by the Schools Privacy Notice.
• Ambassadors and partners, in section 13.
• Website visitors, in section 9 and on our Cookies page.

3. What we collect

3.1 About parents and other adults

• Sign-in details. On the website you sign in with Google, Apple or a link we email to you. There are no passwords. In the app, a parent can save the family's progress by signing in, for example with Apple on iPhone and iPad or with Google on Android. We receive the email address and account identifier from the sign-in service. If you use Apple's Hide My Email, we receive the relay address, not your real one.
• Country of residence. When you first sign in on the website we ask which country you live in. We use it to show the right notices and to check which features are open where you live.
• Your choices and consents, with the date, the notice you saw and how you gave them.
• Purchase records. If you subscribe through the App Store or Google Play, Apple or Google handles the payment. We receive a record of the purchase (the product, dates, price, the store's country and whether it renewed or was refunded) through RevenueCat. We never see card details.
• Codes you redeem, and which offer they carried.
• Messages you send us, for example support requests, and our replies. A message sent with our contact or privacy request form goes, in full and with your email address as the reply address, to our team's email inboxes (Google Workspace), where we answer it. Our support records keep a copy with email addresses and phone numbers hidden. When you send the form you also confirm that you are an adult, and we keep that confirmation with the request.
• Sign-in sessions on the website: when you signed in, a rough description of the browser (for example "Safari on iPhone") and when the session ends. This lets you see and close your sessions.
• Newsletter, if you sign up: your email address, language, the topics you chose, where on the site you signed up, your confirmation that you are an adult, and proof of your consent (which version of the sign-up wording you saw, when you asked and when you confirmed, and scrambled forms of your IP address and browser that cannot be turned back into them). See Newsletter.

3.2 About children

A parent creates a profile for each child in the app or the web game. Most of what we know about a child is what the game needs to work:

• A first name or nickname and an age, entered by the parent.
• Avatar choices, such as the character's look.
• Progress and play history: games played, levels reached, rewards, which days the child played and for how long.
• Learning estimates: a running estimate of how the child is doing in each skill area, so the game can pick the next activity and the parent can see a learning picture. There are no scores or rankings. A parent can switch them off for each child (section 5).
• Device and account identifiers that let the game save and sync progress, as listed in the Children's Privacy Notice.

We never ask a child for an email address, phone number, photo, voice recording or location. There is no chat, and children cannot share anything with other players.

3.3 Collected automatically

• Game analytics. The app and the web game send game events (for example "level finished") to our own analytics store, keyed by a random account identifier and including the child's age. We use them to fix problems and improve the game.
• Third-party analytics in the app. The app on iPhone, iPad and Android sends game events to GameAnalytics, and uses AppsFlyer in anonymized mode to measure installs. Neither is told a child's name or the parent's email.
• Server logs. Our servers record technical details of each request, such as the IP address and the time, for security and to keep the service running.
• Website analytics, only if you say yes (section 9).

We do not collect special category data, such as health, religion or biometric data.

4. Why we use information, and our legal bases

Each purpose below is followed by its legal basis under UK and EU data protection law.

• Running the game and saving progress across devices: to perform our contract with the parent.
• Parent accounts, signing in and linking devices: contract.
• Showing a parent their child's progress: contract.
• Taking payments and keeping tax records: contract and legal obligation.
• Redeeming codes: contract.
• Emails you ask for, such as a weekly progress email (not available yet): your consent, which you can withdraw at any time.
• Newsletters and marketing messages to adults: your consent.
• Website analytics: your consent, given in the cookie banner.
• Remembering which partner sent you (referral codes): our legitimate interest in paying our partners correctly, and your consent where anything is stored on your device.
• Game analytics, fixing problems and improving the game: our legitimate interest in a game that works and keeps getting better, balanced against children's interests. See the note above.
• Security, preventing fraud and abuse, and keeping records of what our staff do: legitimate interest and legal obligation.
• Answering support requests: contract and legitimate interest.

Do you have to give us this information?

No law makes you give us anything. Some information is needed to provide what you ask for:

• To play, a child needs a profile with a name or nickname and an age. Without them the game cannot pick activities at the right level.
• To save progress across devices or use the website account, you need to sign in, which gives us an email address. Without it the game still works on that one device, but progress is not saved to an account.
• To buy a subscription, the store needs to process the payment. Without it you keep the free part of the game.
• For the newsletter, we need your email address. Without it you simply do not get the newsletter.
• To answer a message, we need an email address to reply to.

Everything else, such as website analytics, is optional and off unless you say yes.

5. Children

Every child who plays Jupo World is below the age at which they could consent to data processing themselves, in every country we serve (13 in the UK, the US and Finland, 14 in Italy and Spain, 15 in France and 16 in Hungary and Germany). So we never ask a child to agree to anything. A parent makes every choice.

We protect children's information in these ways:

• No ads, no selling, no profiling for marketing. The learning estimates exist only to choose activities and to show the parent a learning picture.
• No incentives to children. Children never see prices, codes, links to buy or rewards for getting a grown-up to pay. Purchases sit behind a grown-up check in the app.
• Grown-up checks. Settings, account and purchase screens in the app are behind a parent gate.
• Layered parental consent. Anything beyond running the game for the family needs a parent's consent first, and anything that would share a child's information with a teacher or school from home needs a stronger check. The Children's Privacy Notice describes each layer.
• High privacy by default, in line with the UK Age Appropriate Design Code: no location, no chat, no public profiles, nothing shared by default, and notifications to parents only.

Automated decisions and profiling

The game keeps a learning estimate for each child (section 3.2) and uses it to choose the next activity, such as an easier or harder puzzle. This is profiling in the legal sense. It is done only to make the game fit the child, it never has a legal or similarly significant effect on the child or the family, and no person is judged by it. It is not used for advertising or marketing, and it is not shared outside Jupo World. You can see the learning picture in the parent area. If you do not want learning estimates for a child, switch them off for that child on the My family page of the website. We then delete the estimates we hold for that child and stop making new ones. Your child keeps playing every game, and the game picks activities without them. Phones and tablets catch up the next time they go online. You can switch estimates back on at any time; they then start again from the beginning. Removing the child's profile also deletes the estimates. We do not make any other automated decisions about you or your child.

6. Who we share information with

We never sell personal information and never share it for advertising. We share it only with:

• Service providers who run parts of Jupo World for us under contract and only on our instructions (listed below).
• Apple and Google, when you sign in with them or buy through their stores. They act as independent controllers under their own privacy policies.
• Authorities, when the law requires it, or to protect someone's safety.
• A buyer of our business, if Jupo World is ever sold. We would tell you first and this policy would keep applying to your information.

Service providers we use today

• Google Cloud and Firebase: hosting of the website and game, sign-in (including the emails that carry sign-in links, sent by Firebase Authentication), databases, server functions, storage, analytics storage (BigQuery), logs and push delivery. Data stored in the EU, with some server functions in the US.
• Google Workspace: our team's email inboxes, where messages from the contact and privacy request forms arrive in full and where we answer them. Region [PLACEHOLDER: PH-17 Google Workspace data region].
• RevenueCat: manages subscriptions bought in the App Store or Google Play. United States.
• GameAnalytics: game analytics in the app on iPhone, iPad and Android, and website analytics if you say yes. Region [PLACEHOLDER: PH-12 GameAnalytics data region].
• AppsFlyer: install measurement in the app, in anonymized mode. Region to be confirmed.

Added when the feature launches

We will update this list before any of these starts handling your information:

• Brevo: will send the newsletter and its confirmation emails, and deliver contact form messages to our inboxes. European Union. Not in use yet.
• Anthropic (Claude API): helping us translate support messages, with names and identifiers removed first. Not in use yet.
• Stripe: card payments for plans bought on jupo.world, through RevenueCat's checkout, with Little Grandmasters Limited as the seller. [PLACEHOLDER: PH-11 Stripe's region and data processing terms]. Not open yet.
• Wise: paying ambassadors. Not open yet.
• Browser push services (Apple, Google, Mozilla): delivering notifications to a parent's browser. Not in use yet.
• E-signature provider: school agreements. Not chosen yet.

Earlier newsletter lists

Before this website, people signed up for news about Jupo World through forms on our old website (Wix and Formspree) and in other ways. We no longer collect sign-ups through those forms. Before we write to anyone on those lists, we ask them whether they want to stay subscribed, and we remove everyone who does not confirm.

7. Where your information is stored and international transfers

• Our main database is in the European Union (Google Cloud multi-region "eur3").
• The website runs in the Netherlands (Google Cloud europe-west4).
• Analytics storage (BigQuery) is in the European Union.
• Some of our server functions run in the United States (Google Cloud us-central1), so information passes through the US when they run.
• RevenueCat is in the United States.
• The website and the game are delivered through content delivery networks with servers around the world.

When information leaves the UK or the European Economic Area, we protect it with the European Commission's standard contractual clauses and, for UK data, the UK International Data Transfer Addendum, or rely on an adequacy decision where one applies. You can ask us for a copy of the safeguards.

8. How long we keep information

• Active accounts: while the account is in use.
• Inactive accounts: 24 months after the last activity, then deleted. Any play on any of the family's devices, or a parent or guardian signing in, counts as activity. If we have a verified email address, we write 30 days before.
• Game progress that was never saved to a signed-in account: also deleted 24 months after the last play. If that device comes back later, the game starts fresh.
• When you delete your account: deleted straight away from our live systems, with copies in backups gone within 14 days. We offer you a download first.
• Proof of consent: a stripped record of what you agreed to and when (without your name, email or child's details) for 3 years after the account is deleted.
• Purchase and tax records: as long as tax law requires.
• Support messages: we intend to keep them for 24 months after the request is resolved. Automatic deletion is not switched on yet, so today they are kept until we delete them by hand. Messages in our team's inboxes follow the same rule.
• Newsletter sign-ups that were never confirmed: deleted 30 days after the sign-up. Automatic deletion is not switched on yet.
• Newsletter after you unsubscribe: we delete your email address straight away. We keep a short record, without your address, that a scrambled form of it must not be mailed again, together with the proof of when you agreed and when you stopped, for [PLACEHOLDER: PH-18 how long unsubscribe and consent proof records are kept].
• Analytics events: 25 months, then only totals that cannot identify anyone.
• Server logs: 30 days.
• Website sign-in sessions: 30 days after the session ends.

Not switched on yet. Automatic deletion of inactive accounts, support messages and unconfirmed newsletter sign-ups is being introduced in stages. For inactive accounts: first a four-week test run that only counts what would be deleted, then the deletion itself. Until then we do not delete inactive accounts automatically. We will update this section on the day it starts.

9. Website cookies and analytics

The website stores only what it needs to work, unless you say yes to more. We use GameAnalytics to count visits only if you accept in the cookie banner, and we never use advertising or tracking cookies. Analytics never runs in the game at play.jupo.world, on the signed-in pages, on sign-in, code or payment pages, on pages for children or on our Turkish pages. If your browser sends a Global Privacy Control signal, we treat it as a no. The Cookies page lists everything and lets you change your choice.

10. Your rights

You have the right to:

• know what we hold and get a copy, including in a machine-readable format;
• correct anything that is wrong;
• have your information deleted;
• object to, or ask us to restrict, how we use it;
• withdraw any consent, at any time, without affecting what happened before;
• complain to a data protection authority.

How to use them

• On the website: sign in and open Privacy and data. There you can download your family's data, remove a child, see your consent history and delete your family's account. For safety we ask you to sign in again before these steps.
• In the app: open the Parent Portal (behind the grown-up check). The Data page lets you delete the account.
• By email or the privacy request form: write to privacy@little-grandmasters.com. If you are not signed in, we will write back to confirm it is you before we act, for example by asking for the support code shown in the app.
• Children in a class: classroom information belongs to the school. Ask the school; if you write to us, we pass your request to them.

Only the adult who owns the family account can download data, remove a child or delete the account.

We answer within one month. If a request is complex we may need up to two more months and will tell you why. Using your rights is free.

You can complain to the UK Information Commissioner's Office (ico.org.uk), to the Hungarian National Authority for Data Protection and Freedom of Information (naih.hu), or to the authority where you live or work. We would like the chance to help first.

11. Notifications and emails

• In the app, if you allow notifications on the device, the app can send them. They are written for parents and never include a child's name. Two kinds are sent today, at weekends: a tip for playing together, and a short summary of the family's week, for example "Your child finished 7 rounds across 1 game this week", with the games and skills practised. The summary is built from your children's play, so it does carry information about their activity, but never a name.
• These two are on by default for a new family. When you set up the app, we ask whether you want notifications. If you say yes and allow them on the device, the weekend tip and the weekly summary are switched on. If you say no, or do not allow notifications on the device, none are sent.
• To turn them off later, switch off notifications for Jupo World in your device's settings: on an iPhone or iPad, open Settings, then Notifications, then Jupo World; on Android, open Settings, then Apps, then Jupo World, then Notifications. Nothing else in the app changes, and you can switch them back on the same way.
• Account emails: sign-in links, security alerts and receipts. You cannot turn these off while you have an account, because they protect it.
• Newsletter: see below.
• Weekly progress email and browser notifications for parents (not available yet): when they launch, each will be off until you turn it on, a child's name will appear only if you choose so, and you will be able to stop them with one tap. Marketing notifications to parents will need their own separate yes.

Newsletter

The newsletter is for adults. You sign up with your email address and confirm that you are an adult, and nothing is sent until you open the confirmation email and press the button on our page. We use your address only to send the topics you chose, in your language. The legal basis is your consent, which you can withdraw at any time with the unsubscribe link in every email or on the preferences page. What we keep, and for how long, is in sections 3.1 and 8. Newsletter sign-up is not open yet.

12. Teachers and schools

Teacher accounts hold the teacher's name, email, school and role. We use them to run teacher features under our contract with the teacher or school. When a school uses classroom mode, the school decides how pupils' classroom information is used and we act on its instructions: see the Schools Privacy Notice. Classroom mode is not available yet.

13. Ambassadors and partners

This section covers applications to our ambassador programme, which will start in Hungary and is not open yet.

• What we collect when you apply: your display name and full name, the country where you live, your preferred language, where you would share Jupo World and who would see it (with any links you give us), roughly how many people you reach if you tell us, your organization's details if you apply for one, a confirmation that you are 18 or over (we keep only the result, not your year of birth), whether you want programme news, and the messages between you and our team about your application.
• Why: to review your application and reply to you, which you ask us to do before any agreement (contract), and to send you programme news only if you ask for it (consent).
• Who sees it: our staff who review applications.
• How long: while your application is open. Applications we decline are deleted after 6 months. This deletion is not switched on yet.
• If we accept you: we send you the ambassador agreement privately. It explains anything else we collect to run the programme with you, such as your code, the totals linked to it and how you are paid, and how long we keep it.

14. Turkey

Our app is available in Turkey and families there use it. Turkish data protection law (KVKK, Law No. 6698) requires companies outside Turkey to register in the data controllers' registry (VERBIS) and to appoint a representative in Turkey. We have not done this yet. Until we have, we do not offer Jupo World accounts on the website, code redemption, web purchases or the ambassador programme to people who live in Turkey, and our Turkish web pages carry information only. Families in Turkey can keep using the app as before. When we complete these steps, we will publish a Turkish privacy notice (aydınlatma metni) and update this section.

15. Security

We protect information with access controls, encryption in transit, short-lived sign-in sessions and records of what our staff do. No system is perfect; if something goes wrong that puts your information at risk, we will tell you and the authorities as the law requires. Our Security page explains how to report a problem.

16. Changes to this policy

Each version of this policy has a version number and a date. Earlier versions are kept on our legal versions page. If we make a change that matters, we will tell you before it takes effect and, where the law requires, ask for your consent again.

17. Contact

Little Grandmasters Limited
The Coach House, Eton Avenue
London NW3 3EL
United Kingdom
privacy@little-grandmasters.com