Last updated on August 29, 2022
COPPA & GDPR Compliant apps that respect your privacy.
Hello! At Avokiddo we take your privacy very seriously. Our apps are designed specifically for children, with special attention to online privacy. We follow the best practices for kids’ apps as specified by the “Know what’s inside” program. This Privacy Policy is also part of the Terms and Conditions that govern your rights and your use of our apps, services and website, as well as your relationship with Avokiddo.
If you do not agree with parts or the whole of this Privacy Policy please do not use Avokiddo’s apps, services and websites.
Our apps:
Are 100% COPPA & GDPR compliant
Do not knowingly collect any personal information from children
Do not collect location data
Do not have third party advertisements
Contain a child-locked parental gate
“We” or “Avokiddo” are a private company, established as Avokiddo Ltd. and this privacy policy tells you all you need to know about what we do with your personal data. As a data controller, we fully comply with the General Data Protection Regulation EU 2016/679 (“GDPR”) and the Children’s Online Privacy Protection Act of 1998 (COPPA).
Definitions
Personal data: Any information that can be used to identify an individual, whether directly or indirectly.
Data subject: You, with regards to your personal data.
Controller: Avokiddo, to the extent Avokiddo determines the purpose and means of the processing of personal data.
Processor: Any natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Processing: Any operation performed on personal data, whether or not by automated means.
Cookie: A small piece of data generated by a website and stored on the user’s computer by the web browser while browsing the website.
School versions
Thinkrolls Play & Code is available for Schools as a special educational version. While the app is similar to the subscription version, the school edition is specifically designed for educational institutions and can be purchased via the Apple School Manager. For more information about Thinkrolls Play & Code for Schools, please contact us at hello@avokiddo.com.
Thinkrolls Play & Code for Schools is COPPA & GDPR compliant, has no ads, no in-app purchases or subscriptions, does not collect or transmit any type of data (personal or non-personal, analytics or otherwise) and does not include any external links. The app does not use push notifications, does not collect location data and does not store anything on web servers. Everything is processed, stored and accessed locally and securely on the device, following Apple’s security guidelines and privacy frameworks.
Data we may collect
There are two ways we may collect personal or non-personal data: via our apps and via our website. Details are given below.
Data we may collect via our apps
We do not knowingly collect any personal information from children. If you believe we have mistakenly collected such information please contact us immediately at privacy@avokiddo.com
The only cases where we may collect personal information from adults through our apps are:
1. In the subscription version of Thinkrolls Play & Code, if you subscribe to a monthly or annual subscription plan, and/or voluntarily create an Avokiddo account within the app. Both these processes/actions are secured behind a parental gate. While you do not need to create an Avokiddo account to use Thinkrolls Play & Code, you have the option to do so at your own will, provided you are an adult. You may want to create such account to easily share your subscription across multiple iOS devices. It is complementary to the overall experience and provides an easy way to sign-in to multiple family devices through one adult-controlled account.
2. In the subscription version of Thinkrolls Play & Code, if you choose to share your puzzle with Avokiddo for possible inclusion in the ‘Community Puzzles’ section. The puzzle sharing feature is secured behind a parental gate, and you may also completely disable this feature through the app’s settings in the Parents area. In order to share your puzzle you need to provide a parent’s e-mail. This email will only be used to contact you if your puzzle is selected for inclusion. You can optionally send us a ‘nickname’ for your child which will be published alongside your puzzle in the ‘Community Puzzles’ section. We strongly advise you not to use your child’s real name. Additionally, you have the option to send us a short message/story. Your e-mail and message/story are not publicly displayed and are not shared with any third-parties.
Our apps may provide parents with access to additional settings, information about Avokiddo, information about subscriptions and how to manage them, ability to create and sign-in to an Avokiddo account, our privacy policy, terms of use and e-mail contact for support. All such information is secured behind a parental gate.
As mentioned above we may collect the following information (personal or non-personal) from the subscription version of Thinkrolls Play & Code:
Data type
Is this Data Personal?
Purpose of processing
Retention time
e-mail address
Yes
1. Registration and verification of account sign-in 2. Sharing puzzles for the ‘Community Puzzles’ section.
Removed upon request or inactivity
Password
No, the password is encrypted
Registration and verification of account sign-in
Removed upon request or inactivity
Nickname
Possibly, depending on the name you choose to provide
Published alongside your puzzle in the ‘Community Puzzles’ section. If you don’t provide a nickname, your puzzle will be anonymous.
Removed upon request or inactivity
Message/story
Possibly, depending on the information you choose to share with us.
Not shared with anyone and is solely used by Avokiddo in order to improve the quality of our apps, or to reply to your inquiry.
Removed upon request or inactivity
Device name
Possibly, depending on the name you set on your device
We use this data solely at the back-end and only for technical purposes and to provide you better support with your subscription status.
Removed upon request or inactivity
Device model
No
For technical support issues
Removed upon request or inactivity
OS version
No
For technical support issues
Removed upon request or inactivity
– We do not collect any other personal information.
– We do not use tools or third-party analytical software to gather or analyze personal information.
– We develop our apps with Solar2D, an open source software development kit that does not track users and does not gather personal or non-personal data. You can read more about it here: https://solar2d.com
– We do not display third-party advertising via our apps.
– We do not use push notifications and do not collect location data through our apps.
– Our apps may contain information or links to other apps by Avokiddo. Links to other Avokiddo apps that direct the user outside the app are child-locked.
Thinkrolls Play & Code uses the AppsFlyer attribution platform (appsflyer.com/privacy-policy). In particular it implements the ‘Strict Mode’, a limited version of the software that is specifically built for kids apps and protects their privacy. We use this tool to record anonymous installs and subscription events in order to evaluate and optimize our marketing campaigns.
Data we may collect via our website
We do not collect any personal data when you browse our website (https://www.avokiddo.com/), unless you decide to provide us with such information in the following ways:
Action
Data type
Purpose of processing
Retention time
Using our contact form
e-mail address. Possible personal data provided in the message
To reply to your inquiry
Removed upon request
Sending us an e-mail
e-mail address. Possible personal data provided in the message
To reply to your inquiry
Removed upon request
Signing up to our newsletter
e-mail address
To inform you about app updates, releases, new products, sales and special offers via a low volume newsletter
Until you unsubscribe by clicking on the “unsubscribe” button provided on the newsletter e-mail.
Cookie policy
Our website is built with WordPress (https://wordpress.org) and by default it sets on your browser system-required cookies in order for the site theme and plug-ins to operate correctly. Such cookies are used solely for functionality purposes and do not set, collect, transmit or access any personal information.
Our website uses Google Analytics (policies.google.com/privacy): Collects anonymized statistical data with regards to the use of our website.
You may consent to the use of such cookies by clicking on the “I accept” button on the footer of our site. Alternatively, you may disable ‘Cookies’ on your browser or choose to not use our website.
Children
We do not seek to collect and do not knowingly collect any personal information from children via our website. If you believe we have mistakenly collected such information, please contact us immediately at privacy@avokiddo.com.
Links
Our website may contain links to third-party websites i.e. social media sites. Following links to third-party websites is subject to their data privacy policies as stated on their respective websites and we assume no responsibility or liability for your use of such websites.
Legal basis for processing of personal data
We process the personal data we collect under any of the following legal bases :
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Processing is a legal or contractual obligation of Avokiddo.
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Processing is necessary for Avokiddo to enter into or execute an agreement, or to carry out and complete transactions in the context of its commercial activities.
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Processing serves the operational needs as well as the business and commercial interests of Avokiddo, such as provision of information about and the promotion of Avokiddo’s services and products .
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You have in advance expressly and specifically consented to the processing of your personal data in a specific way and for a specific purpose.
Disclosure of personal data
We may disclose your personal data to third parties only in the following cases:
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To the personnel or to business partners of Avokiddo on a need-to-know basis in order for them to perform their tasks and/or to provide their services to Avokiddo, in the context of the business activity of Avokiddo and under a relevant contract which includes specific terms and conditions, covenants and obligations concerning the protection of personal data by such persons.
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If disclosure is obligatory by law or results from an order, a decision, an investigation or an inspection by any competent administrative, judicial, police or other authority etc.
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You have in advance expressly and specifically consented to the disclosure of the personal data in a specific way and for a specific purpose.
The information may be stored and processed both within and outside of the EU and/or the United States. We use the following GDPR compliant subcontractors (data processors):
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We use Google Cloud (GDPR Compliant) to store your data. You may read more information on Google Cloud’s GDPR compliance here: https://cloud.google.com/security/gdpr
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Our website is hosted by SiteGround. You may read more information on SiteGround’s GDPR compliance here: https://www.siteground.com/blog/siteground-is-gdpr-compliant/
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We also use MailChimp as our newsletter provider (GDPR Compliant) which means that the personal data we collect via our newsletter subscription forms are stored and managed via MailChimp’s servers and online tools. You can read MailChimp’s privacy policy here: https://mailchimp.com/legal/privacy/
Security
Avokiddo takes all necessary organizational and technical measures to protect the data from accidental or unlawful destruction, accidental loss, alteration, prohibited dissemination or access and any other form of unlawful processing. We are storing all data in secure firewall enabled operating environments and all data are transmitted via Secure Socket Layer (SSL).
Your Rights
In brief, you have the following rights with regards to your personal data:
1. Right to information: You may request additional information on how we use your personal data and what your rights are.
2. Right of access: You may request access to your own personal data and to related information such as the processing purposes, the data categories, their origin and their recipients, if any.
3. Right to rectification: You may rectify your personal data if they are inaccurate or incomplete.
4. Right to erasure: You may request that we erase your personal data when (a) they are no longer necessary for the purposes for which they were collected or (b) there is no lawful justification for us to continue using them or (c) if you wish to withdraw your consent.
5. Right to restriction of processing: You may restrict, under certain circumstances, the further processing of your personal data.
6. Right to data portability: You may request to receive your personal data and/or that we transmit them to another data controller.
7. Right to object: You may object at any time to the processing of your personal data for certain reasons relating to public interest duties, the exercise of public authority, or a legitimate interest.
For any further questions or queries concerning the use of your personal data, we shall make best efforts to respond in writing to you within thirty (30) days from the date of the request. Within the same time frame we will inform you of any important reasons which might not allow us to respond to such request. In any event, the information will be provided free of charge with the exception of profoundly groundless, exaggerated or repeated requests, for which a reasonable fee may be charged. In all cases mentioned above and for any question or concern regarding your personal data please contact us at privacy@avokiddo.com