Privacy Policy

1. Introduction

Tiny Minies is an interactive learning app where young children learn through games, books, tales, songs, videos, printable worksheets and other activities.

Gamester Egitim Bilisim ve Yazilim Teknolojileri A.S. ("Gamester Kids," "we," "us," or "our") is firmly committed to your privacy and the privacy of your child. We want you, as a parent or legal guardian ("Parent"), to feel safe and confident in how we handle data, whether you use our mobile application ("App"), our websites, or otherwise interact with us (together, our "Services").

This Privacy Policy explains what we collect, why, how we use it, and how you can exercise your rights. We may modify it in accordance with applicable law. If we make a material change we will provide notice as required, and we will obtain verifiable parental consent where a change in practice requires it.

What you need to know

• We ask children for nothing. Every piece of information about a child - a nickname, an age group, interests - is optional, entered by the Parent, and editable or removable at any time.
• Parents are in control. Parents set up profiles, set daily screen time limits, choose what content is available, review progress and can delete profiles or the account from the Parents Area.
• The App is a closed ecosystem. Children cannot reach the wider internet, cannot message anyone, and cannot share information with anyone outside the family. Anything that leaves the children's area sits behind a parent gate.
• There is no advertising in the App - none of any kind, from us or from third parties - and we never use information collected from children for marketing.
• Our promotional website is for adults and uses standard web tracking for advertising and analytics. You can control this through our cookie banner. We do not use data collected from children for these purposes.
• We collect only what the Services need. The App does not collect biometric identifiers such as facial geometry or voice prints, does not request precise location, and does not ask for sensitive information such as race, religion, sexual orientation or health data.

2. Information We Collect

A. Information provided directly

Account creation (optional).

Tiny Minies can be used without an account. If you choose to create one - which allows use on more than one device and keeps progress safe - we collect:

• Adult's email address
• A one-time confirmation code sent to that address to sign you in. We do not use passwords.

Child profile information (all optional).

• Child's nickname or first name
• Child's age group
• Child's interests

Up to five child profiles can be created under one account. None of these fields are required, and a Parent can change or remove them at any time in the Parents Area.

Payment information.

We do not collect or store payment card details. Purchases in the App are processed by Apple or Google under their own terms and policies. We receive confirmation of a subscription and its status, not your card details.

Access codes.

If a school, employer or partner provides an access code, we collect the code you redeem in order to activate the relevant access.

Your communications with us.

When you contact us for support, feedback, press, careers or partnership enquiries, we collect your name, email address and whatever else you choose to include.

Device permissions.

Some activities may ask for access to the device microphone or camera. Any voice, image or video data stays on the device: it is not transmitted to us, not stored on our servers, and we cannot access, play or broadcast it. These permissions are optional and the rest of the App works without them.

Research and events.

We may invite adults to take part in optional interviews or surveys, always with consent and with the purpose explained in advance. We may also collect business contact details at events, and information submitted through job applications.

B. Information collected automatically

• Activities opened, played and completed, and time spent on them
• Progress and achievements used to generate Progress Reports for the Parent
• Screen time used against the daily limit set by the Parent
• Session duration and frequency of use
• Notification settings
• Device identifiers and, on our websites, cookies
• IP address, and approximate location (country or city) derived from it
• Device type, operating system, language and settings
• Crash and diagnostic data

Section 4 lists exactly which persistent identifiers are collected in children's sessions, what each is used for, and the safeguards applied.

C. Information from third parties

If you sign in using a third-party service such as Apple, we receive the information you have chosen to share through your privacy settings. On our adult-facing websites and campaigns, we receive analytics and campaign measurement information from our partners.

3. How We Use Information and Our Legal Bases

A. Providing the Services

• Creating and managing accounts and child profiles
• Delivering activities and saving progress, including across devices where an account exists
• Applying the daily screen time limit chosen by the Parent
• Generating Progress Reports for the Parent
• Providing customer and technical support
• Activating subscriptions and access codes
• Debugging and repairing errors

Legal basis (EEA/UK): performance of our contract with you.

B. Personalization and Progress Reports

We use activity data from each child profile to adapt difficulty to the child and to produce Progress Reports for the Parent. A report may show time spent by category, progress across our six developmental domains based on how the child performs, a comparison with typical results for the same age group, and suggestions for what to encourage next.

These reports are produced by a combination of fixed rules and, in part, automated analysis. They are shown to the Parent only. They are never shared with third parties, never used for advertising and are not an assessment, a diagnosis or a measure of ability. A Parent can remove this data at any time by deleting the child profile.

Legal basis (EEA/UK): performance of our contract with you. This processing does not produce legal or similarly significant effects and is not automated decision-making within the meaning of Article 22 GDPR.

C. Administrative purposes

• Measuring interest and engagement in the Services
• Improving and developing our products
• Security, fraud prevention, quality control and safety
• Requesting feedback from adults

Legal basis (EEA/UK): our legitimate interests, balanced against your rights and freedoms.

D. Legal obligations

To comply with legal and regulatory obligations, respond to lawful requests, enforce our agreements and carry out audits.

Legal basis (EEA/UK): compliance with a legal obligation.

E. Marketing to adults

We may send adults email about our Services, and advertise our Services on third-party platforms. We measure the effectiveness of those campaigns. We do not advertise inside the App, we do not use information collected from children for marketing, and we never disclose your information to third parties for their own advertising. You can unsubscribe at any time using the link in any marketing email.

Legal basis (EEA/UK): consent where required, otherwise our legitimate interests.

4. Children's Privacy

Children deserve enhanced protection, and our Services are designed so that Parents remain in control. An adult sets up the account and each child profile. Every field about a child is optional. We do not condition a child's use of the Services on providing more information than is necessary.

How we use a child's information.

• To deliver activities and save progress, stickers and albums
• To adapt difficulty so that activities stay achievable
• To produce Progress Reports for the Parent
• To understand overall usage in aggregate and improve the App

What we never do.

• We never sell, rent or trade children's personal information
• We never show advertising to children, or use their information for marketing
• We never allow children to communicate with anyone outside the family through the App

Persistent identifiers collected from children

When a child uses the App we automatically collect the identifiers below, solely to support internal operations. They are not used to contact any individual, to build a profile for advertising, or for any purpose other than those stated.

We do not collect advertising identifiers (such as Apple's IDFA or Google's advertising ID) in children's sessions, and we do not use children's data for attribution or advertising measurement.

Retention and deletion of children's data

We keep information collected from children only as long as it is needed for the purpose it was collected for.

Deletion procedures.

• Data in live systems is permanently deleted, or irreversibly anonymized where we have a genuine need for aggregate figures.
• Backups are encrypted and inaccessible for ordinary operations. Deleted data is overwritten as backups rotate, within 35 days.
• When an account is deleted, deletion requests are sent automatically to the third-party services that hold associated data.
• A Parent may request deletion of a child's information at any time. We complete verified requests within 30 days.
• If a Parent withdraws consent, we stop collecting new information immediately and delete what we hold for that child.

5. How We Disclose Information

A. Service providers

We use a small number of providers to run the Services: hosting and infrastructure, product analytics, crash reporting, email delivery and customer support, including Amplitude, AppsFlyer, Crashlytics, Sentry and others listed in our current vendor list, available on request. They act as our processors under data processing agreements, may use information only to provide services to us, and must keep it confidential.

Campaign measurement for adults.

We measure how many adults install the App after seeing our advertising. This measurement covers adult acquisition only and does not use information from children's sessions.

B. Business partners

Where you obtain access through a partner, we share only what is needed to activate and administer that access.

• Mobile operators and similar partners receive confirmation that a code has been redeemed or that a subscription is active. They do not receive usage data.
• Schools and institutions may, where a school specifically requests it and a separate agreement is in place, receive information about use within their own closed group. This never extends beyond that school's own pupils and is governed by that agreement.

C. Advertising partners

On our adult-facing websites we work with advertising partners who may set cookies and similar technologies. This never applies to children or to child-directed parts of the Services, and we do not disclose children's information to advertising partners.

D. Legal and safety

We may disclose information where we believe in good faith it is necessary to comply with law or legal process, to protect rights, property or safety, to enforce our terms, or to assist an investigation.

E. Corporate transactions

If we are involved in a merger, acquisition, financing, reorganization or sale of assets, information may be transferred as part of that transaction. Where children's information is involved, the recipient must honor the commitments in this Policy.

6. Retention

Children's data retention is set out in Section 4. For other information:

7. Security

We use appropriate technical and organizational measures to protect personal information, including encryption in transit and access controls. No system is completely secure and we cannot guarantee absolute security. If we become aware of a breach affecting your personal information we will notify you and the relevant authorities as required by law.

8. Your Choices and Rights

Managing your information.

• Review and update your information, and your children's profiles, in the Parents Area
• Change your account email in the Parents Area, confirming with a code sent to the existing address
• Delete your account and associated data from the Parents Area, or by contacting us
• Unsubscribe from marketing email using the link in any such email. We will still send essential account messages such as sign-in codes and receipts

Deleting your account does not cancel a subscription bought through the App Store or Google Play. Subscriptions must be cancelled in the store where they were purchased.

Your rights.

Depending on where you live, you may have the right to access your personal information, request correction, request deletion or anonymization, restrict or object to processing, withdraw consent, request portability, be told with whom your information has been shared, and ask us to review decisions based solely on automated processing. To exercise any of these rights, contact us using the details in Section 10. We may ask you to verify your identity first.

Do Not Track and Global Privacy Control.

We do not respond to Do Not Track signals. Where our website detects a Global Privacy Control signal, we treat it as an opt-out request where applicable law requires.

Türkiye (KVKK)

If you are in Türkiye, we process personal data as a data controller under Law No. 6698 on the Protection of Personal Data (KVKK), and we are registered with VERBIS. You have the rights set out in Article 11 of the KVKK, including the right to learn whether your data is processed, to request information about it, to request correction, deletion or destruction, to object to results arising from automated analysis, and to claim compensation for damages arising from unlawful processing. Requests may be sent to the address in Section 10.

European Economic Area and United Kingdom

Where the GDPR or UK GDPR applies, our legal bases are set out in Section 3. We are established in Türkiye, and where we transfer personal information from the EEA or UK we rely on appropriate safeguards such as Standard Contractual Clauses. You have the right to lodge a complaint with your local supervisory authority.

United States - California, Colorado and Virginia

If you are a resident of California, Colorado or Virginia, you may request access to the personal information we hold about you, request its deletion, and request correction of inaccurate information. You may also ask us to confirm the categories of information we collect, the purposes for which we use it, and the categories of recipients.

We do not sell personal information, and we do not sell or share the personal information of anyone under 16. We will not discriminate against you for exercising your rights. Requests may be sent to the address in Section 10, and we may take reasonable steps to verify your identity. Where our decision is to refuse a request, you may appeal by replying to our response.

9. Cookies

We use cookies and similar technologies on our websites for technical purposes, to remember your preferences, and to measure and support our advertising to adults. We do not use cookies for advertising inside the App. You can manage your choices through the cookie banner on our website. Full details are in our Cookie Policy.

10. Contact Us

For questions about this Privacy Policy, or to exercise your rights:

Email: help@tinyminies.com

Gamester Egitim Bilisim ve Yazilim Teknolojileri A.S.

Bilisim Vadisi Kocaeli Merkez Kampusu - Muallimkoy Mh. Deniz Cd. No:143-5 Gebze Kocaeli, Turkiye