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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:


(1) the information we collect about you when you visit our website, use our products or services,
or otherwise interact with us;
(2) how we use, share, store, and secure the information; and
(3) 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”);

(a)

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”)

(b)

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”);

(c)

details of any transactions, purchases, or orders that you've made with us (collectively,
Transaction Data”);

(d)

payment information, for example Card details and other tbc (collectively, “Financial
Data
”);

(e)

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

(f)

Information about your use of or visit to our Platform, for example (collectively,
Usage Data”)

(g)

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

(g)

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 wecannot 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 fromusers 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

(i)

(ii)

(iii)

(iv)

(v)

(vi)

(vii)

(viii)

(ix)

(x)

(xi)

(xii)

(xiii)

(xiv)

(xv)

Crash Reports.

(b)

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.

Cookies and Other Tracking Technologies

(c)

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.

1.3

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.

1.4

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.

1.5

2.           HOW WE USE INFORMATION WE COLLECT

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

2.1.

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;

(a)

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

(b)

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

(c)

we need to comply with a legal or regulatory obligation.

(d)

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.

2.2.

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.

2.3.

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.

2.4.

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.

2.5.

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.

Parental Consent and Control

3.1.

Only a parent or legal guardian may create an account for a child and provide their
information.

(a)

We do not require more information than reasonably necessary for the child to
participate in educational activities

(b)

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.

(c)

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

3.2.

Personalise learning content and progress tracking.

(a)

Estimate usage patterns for educational insights.

(b)

Generate reports on progress for parental review.

(c)

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.

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

3.3.

To service providers acting on our behalf under contract.

(a)

If required by law, legal process, or to protect rights, safety, or property.

(b)

If a parent chooses to share content from the App (such as achievements) via secure
shareable links.

(c)

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

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

4.1.

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.

4.2.

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.

4.3.

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.

4.4.

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.

4.5.

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.

4.6.

5.          RETENTION OF YOUR DATA

We retain personal information only as long as necessary to fulfill 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 Cookies Policy.

8.           HOW WE STORE AND SECURE INFORMATION WE COLLECT

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

8.1.

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

8.2.

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

(a)

our information collection, storage, and processing practices are reviewed regularly.

(b)

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.

8.3.

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.

8.4.

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.

8.5.

9.           HOW WE TRANSFER INFORMATION INTERNATIONALLY

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.

9.1.

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.

9.2.

10.          YOUR RIGHTS

10.1.        You have the right to:

be informed of what we do with your personal information;

(a)

request a copy of personal information we hold about you;

(b)

require us to correct any inaccuracy or error in any personal information we hold about
you;

(c)

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);

(d)

object to or restrict the processing by us of your personal information (including for
marketing purposes);

(e)

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

(f)

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).

(g)

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.

10.2.

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.

10.3.

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.

10.4.

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.

10.5.

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

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.

13.1.

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).

13.2.

Last updated: 16th January 2026

COOKIES POLICY

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.

(a)

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.

(b)

Functionality cookies – these are used to recognise you when you return to our site.

(c)

Targeting cookies – these cookies record your visit to our site, the pages you have
visited, and the links you have followed.

(d)

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.

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