Children's Privacy Notice
Draft for legal review.
Our lawyers are still checking this text, so it may change before it takes effect.
This notice is for parents and other adults who look after a child who plays Jupo World. It explains what we collect from or about your child, why, and what you can do. It is our direct notice to parents under the US Children's Online Privacy Protection Act (COPPA) and part of our Privacy Policy, which has the full details.
Who we are
Jupo World is run by Little Grandmasters Limited, The Coach House, Eton Avenue, London NW3 3EL, UK. Email privacy@little-grandmasters.com, phone [PLACEHOLDER: PH-07 phone number for privacy questions]. We are the only operator collecting children's information through Jupo World.
What we collect from or about your child
- First name or nickname and age, which you enter when you create the child's profile. A nickname works just as well.
- Avatar choices: how your child's character looks.
- Play and progress: games played, levels and rewards, which days your child played and for how long.
- Learning estimates: how your child is doing in each skill area, so the game can choose the next activity and you can see a learning picture. No scores, no rankings, no comparisons with other children. You can switch them off for your child on the My family page of the website; we then delete them and the game keeps working without them.
- Identifiers that let the game work (see "Internal operations" below).
We do not ask your child for an email address, phone number, photo, voice, location or any free text. There is no chat. Children cannot post, message or share anything, and they never see other players' information.
We will not ask for more information than the game needs, and your child can play fully without giving any more.
How we use it
- to run the game, save progress and sync it across your family's devices;
- to choose the next activity at the right level;
- to show you, the parent, how your child is getting on;
- to keep the service secure and working, and to improve it.
We never use your child's information for advertising, never sell it and never use it to contact your child.
Internal operations
Some information is collected only to support the internal operations of the game. COPPA allows this without asking you first, as long as it is used for nothing else. These are the identifiers we use, and what each is for:
- Account identifier (a random ID created by Firebase when the game first starts): saves and syncs progress, and links your child's profile to your family.
- Device and installation identifiers: tell your family's devices apart, so progress syncs to the right place and you can see and remove devices.
- Push notification token: lets the app deliver notifications on that device. Notifications are written for parents. Today the app can send, at weekends, a tip for playing together and a short summary of the family's week (rounds played, games and skills practised). The summary is built from your children's play but never includes a name. Both are on by default for a new family: if you say yes to notifications when you set up the app and allow them on the device, they are sent. To stop them, switch off notifications for Jupo World in your device's settings (on an iPhone or iPad: Settings, then Notifications, then Jupo World; on Android: Settings, then Apps, then Jupo World, then Notifications).
- Subscription identifier (our account identifier, shared with RevenueCat): unlocks the subscription the family paid for, on every device.
- Analytics identifiers: game events stored by us and sent to GameAnalytics from the app on iPhone, iPad and Android help us find problems and improve the game. AppsFlyer, in anonymized mode, tells us an install happened.
Safeguards: these identifiers are never used to contact a child directly, to build a profile of a child for any other purpose, for advertising or for anything other than running and improving the game. Service providers that receive them may use them only for us, under contract.
Who we share it with
We share children's information only with service providers that run parts of Jupo World for us, under contracts that limit them to that work:
- Google Cloud and Firebase: hosting, databases, sign-in, analytics storage and notification delivery.
- RevenueCat: subscriptions bought in the App Store or Google Play (it holds the account identifier and purchase records, not your child's name).
- GameAnalytics (the app on iPhone, iPad and Android) and AppsFlyer (anonymized install measurement): analytics as described above.
We never share your child's information with advertisers or data brokers. We may disclose it if the law requires, or to protect a child's safety.
Teachers and schools receive nothing about your child's home play unless you turn that on yourself (see "Consent layers" below). That choice is not available yet.
Consent layers: how we check it is you
We ask for a parent's consent in layers, so the check matches what you are agreeing to. Each step is recorded with the date, the notice you saw and how we checked.
- Playing the game. Your child can play, and progress is saved to an account, without any further step from you, because this information is used only to run the game (internal operations).
- Layer 1: email confirmation. Before new features that send your child's information to you by email or with your child's name, such as a weekly progress email or a notification showing your child's name, we ask you to confirm at your verified email address. We then send a second email a day or two later, with a one-tap link to change your mind. Nothing at this layer goes to anyone else. The weekend summary the app already sends (see "Internal operations") carries no name and does not use this step today.
- Layer 2: a payment. When you make your first paid purchase on jupo.world for your own family, we show this notice and ask for your consent before you pay, and we email you a confirmation afterwards. Free trials, codes, gifts and purchases in the App Store or Google Play do not count for this layer.
- Layer 2D: before anything goes to a school or teacher. If you ever choose to let your child's teacher see home play, we will need a stronger check (such as a qualifying payment already on file or a signed consent form) and a separate yes for each school. This is switched off and will stay off until our lawyers have approved it.
- Schools. When a child plays in class under a school's authority, the school gives consent for classroom use only. That information is never used commercially. See the Schools Privacy Notice.
These features are being introduced over time. Today the website offers your account, your family's data and the privacy tools in section "Your choices"; progress emails, notifications with names, web purchases and school links are not available yet.
Your choices
As the parent you can at any time:
- see what we hold about your child, and download it: on the website at Privacy and data after signing in;
- correct your child's name or age;
- remove a child: on the website at Privacy and data, which deletes that child's profile and progress;
- delete everything: on the website, or in the app's Parent Portal on the Data page;
- stop further collection by deleting the child's profile or the account, and withdraw any consent you gave, from the link in our emails or from your account;
- ask us at privacy@little-grandmasters.com.
If you remove a child or delete the account, we delete the information from our live systems straight away. Backups are gone within 14 days. We keep only a short record of what consents were given and when, without your child's details, to show we followed the law.
How long we keep it
As long as your family uses Jupo World. If nobody in the family plays or signs in for 24 months, the account and your child's information will be deleted automatically. Automatic deletion is not switched on yet; our Privacy Policy explains how it is being introduced and lists every retention period.
Children who are not ours to know about
Jupo World is for children aged 4 to 10 with a parent's set-up. Adult areas such as the website account, codes and purchases are for adults only. If you think a child has created an adult account or sent us information without a parent, write to us and we will delete it.
Changes
We will tell you before any change to how we handle children's information takes effect and, where the law requires, ask for your consent again. Earlier versions are on our legal versions page.