Privacy Policy

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, religious beliefs or health. We do not ask for health information or diagnoses, and we do not process sensitive personal information.

Do we collect any information from third parties? Only from Apple and Google: they confirm a sign-in and tell us the state of a subscription. We do not collect information about you from any other source.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting https://bulbee.org/en/delete-account, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW DO WE HANDLE SIGN IN WITH APPLE?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. CHILDREN AND BULBEE
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• contact or authentication data
• a child's profile: first name or nickname, year of birth and a badge colour
• the adult's consent to the processing, with its version and time
• messages the adult sends to support

Sensitive Information. We do not process sensitive information.

Payment Data. We do not collect payment card details. The subscription is bought only through the App Store or Google Play, and only from the menu for adults; all payment data is handled and stored by Apple (App Store) and Google (Google Play). You may find their privacy notices here: https://www.apple.com/legal/privacy/ and https://policies.google.com/privacy.

Apple and Google tell us the state of the subscription: the product, its dates, the free trial, renewal and any refund, so that we can open the game and remind the adult before the first payment.

Sign in with Apple. You may sign in with your Apple account instead of a code sent by email. Apple then tells us an identifier for your account and an email address, which may be a private relay address that Apple creates, as described in the section called 'HOW DO WE HANDLE SIGN IN WITH APPLE?' below. Sign-in by email code needs no password.

Application Data. If you use our application(s), we also collect the following information:

• Mobile Device Data. After you sign in, the app sends the device model, the operating system version, the app version and build, network errors, the frame rate and the time-zone offset. We do not collect the device name, its language, its location or any advertising identifier.
• Push Notifications. We may ask to send you notifications, for example the two reminders before the first payment. If you wish to opt out from receiving them, you may turn them off in your device's settings.

This information is needed to keep our application(s) working and secure and to find and fix errors.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as what the child does in a lesson and technical details of the device — is collected automatically when you use our Services.

We automatically collect certain information when you use the Services: what happens in lessons and games, technical details of the device and the app, and records of errors. This information is needed to provide the lessons, to keep the Services working and secure, and to find and fix errors. The app uses no third-party analytics, advertising, attribution or crash-reporting tools and sets no cookies; the pages with this notice, our terms and account deletion set no cookies either.

The information we collect includes:

• Log and Usage Data. Technical records of requests to our servers and of errors. Our request logs do not store IP addresses.
• Device Data. The device model, the operating system version, the app version and build, network errors, the frame rate and the time-zone offset. Not the device name, language, location or any advertising identifier.
• Learning and play data. What the child does in Bulbee: the cards and exercises shown, the topic chosen, the answer given, response times and touches, reward games, and development-game attempts and levels with the child's age at the time
• Launch history before sign-in. A random launch ID, the screens opened and errors, with no name, email, child data or free text

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. (Retention period: until the account is deleted, then erased within 30 days; sign-in codes are kept for one day and sessions for up to 90 days after last use)
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. (Retention period: until the child or the account is deleted, then erased within 30 days)
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. (Retention period: until the question is resolved and for up to 12 months after that)
• To send administrative information to you. We may process your information to send you sign-in codes, the two reminders before the first payment, and notices about changes to our terms and policies. We do not send marketing. (Retention period: until the account is deleted, then erased within 30 days)
• To manage your subscription. We may process the subscription state that Apple or Google send us to open the full game, to remind you before the first payment and to keep our accounts. (Retention period: store records of subscriptions are kept for 6 years for accounting, also after the account is deleted)
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. (Retention period: launch history until 12 months after the last launch; error records for 12 months; backups for 30 days)
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
• To adapt the lessons to the child. We use the child's answers and response times to choose each next exercise and to show the adult what the child already understands (Retention period: Until the child or the account is deleted, then erased within 30 days)
• To find and fix errors. We look at the launch history and error records, with the device model, system version and app version (Retention period: launch history until 12 months after the last launch; error records for 12 months)

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. Before a child plays, the adult agrees on the screen «Що ми зберігаємо» (What we store) to the processing described there on the child's behalf; we keep the version and time of that consent. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We process personal information when it is necessary to provide the Services you asked for: the account and sign-in, the lessons and their adaptation to the child, the development games, the child's progress for the adult, the subscription and the emails about it.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to diagnose problems and/or prevent fraudulent activities, and to keep the app working and secure for families.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work.

We do not sell personal data and do not share it for advertising. The third parties we share personal information with are as follows:

• Cloud computing — DigitalOcean. Hosting of the server, the database, media and backups. The server is in London (United Kingdom); encrypted copies of backups may be kept in Frankfurt (Germany). DigitalOcean acts as our processor.
• Sending emails — Plunk. Sign-in codes and the reminders before the first payment: the email address and the text of the email. Plunk acts as our processor.
• Sign-in and payments — Apple (App Store, Sign in with Apple) and Google (Google Play). They act as independent controllers, and their own privacy notices apply.

The pictures and voices in the game are made from texts written by our team with the help of OpenAI, Google Gemini and ElevenLabs. These services receive no personal information.

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. HOW DO WE HANDLE SIGN IN WITH APPLE?

In Short: If you choose to sign in with your Apple account, Apple tells us only what we need to recognise you.

Our Services let an adult sign in with an Apple account instead of a code sent by email. Where you choose to do this, Apple tells us an identifier for your account and an email address. The email address may be a private relay address that Apple creates; emails we send to it reach you through Apple. We do not receive your Apple password, your contacts or your profile picture.

We use this information only to sign you in and to write to you about your account and subscription. Please note that we do not control, and are not responsible for, other uses of your personal information by Apple. We recommend that you review Apple's privacy notice to understand how Apple collects, uses and shares your personal information.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United Kingdom and Germany. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?' above), including facilities in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses:

Apple, Google and, possibly, Plunk may process personal information in the United States. They do so under the European Commission's Standard Contractual Clauses or the UK International Data Transfer Agreement in their own terms. These clauses require the recipients to protect personal information originating from the EEA or UK in accordance with European and UK data protection laws. Further details can be provided upon request.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). If you are located in the EU or UK, see section 'HOW DO WE PROCESS YOUR INFORMATION?' for our retention periods by purpose.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or delete your account at any time.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.

How to contact us:

• Email: support@bulbee.org
• Post: See 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'

What happens after you complain

• We will acknowledge your complaint within 30 days of receiving it.
• We will investigate without unjustifiable or excessive delay.
• We will keep you informed of progress and explain the outcome.

If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office, the UK supervisory authority.

• Website: ico.org.uk/make-a-complaint
• Helpline: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

If you are located in Ukraine, you may contact the Ukrainian Parliament Commissioner for Human Rights (Уповноважений Верховної Ради України з прав людини), ombudsman.gov.ua.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
• Contact us using the contact information provided.
• In the app, open the menu for adults and choose «Видалити дитину або акаунт» (Delete a child or the account); everything is erased within 30 days.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at support@bulbee.org.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. In any case, we do not track you across other websites or apps. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

11. CHILDREN AND BULBEE

Bulbee is made for children aged five and under. A parent or other adult aged 18 or over creates the account and the child's profile and agrees to the processing on the child's behalf. We collect only what the game needs. There is no advertising, no third-party analytics, no profiling for marketing and no sharing of a child's data with others for their own purposes. A child cannot buy anything or leave the app: purchases, settings and links are behind a gate for adults. Adults see their child's progress and can delete the child or the account at any time.

We do not ask for health information or diagnoses. Bulbee is also designed for children with special educational needs, so the way a child plays may say something about the child's development; we treat this information with particular care and use it only as this notice describes.

Development games. Some games after a lesson (development games) record the child's attempts and levels, together with the child's age at the time. They are part of how Bulbee teaches: the results help us check the games and choose tasks that suit the child, so they cannot be switched off separately. The levels are steps of a game, not a norm or a diagnosis, and we draw no conclusions about the child's health from them. At present only our team can see them. We never use them for advertising and never share them. They are erased together with the child's profile or the account.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Last updated' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we tell adults about them in the app and by email before they take effect. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@bulbee.org or contact us by post at:

DEEP THOUGHT SOLUTIONS LIMITED, registered in England and Wales, company number 14299488

Unit 2 Pondtail Farm, Coolham Road, West Grinstead

Horsham, West Sussex RH13 8LN

England

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://bulbee.org/en/delete-account.