Frutebowl Privacy Policy

1. Information We Collect

We collect information to operate the game, personalize your experience, and improve our services. The information we collect falls into two categories:

a. Data We Collect Automatically

• Device & Gameplay Data: We collect non-personal data about your device type, operating system, and in-game activity logs (e.g., sessions, crashes). This data is used to analyze performance, fix bugs, and ensure the game runs smoothly for everyone.
• Game Progress Data: We track your progress, including XP, badges, learning achievements, and leaderboard rankings. This data is essential for the game's core functionality and to save your progress.

b. Data You Provide Directly

• Guardian/Parent/Educator Accounts: Adult accounts (guardians, parents, and educators) require an email address and birth year for account creation, verification, and important communications about child accounts under their supervision.
• Teen Accounts: Teens (13-17) can register independently by providing an email address and birth year during self-registration.
• Child Player Profile: Children only provide a nickname when added to a guardian account via guardian code - no email address, birth date, or other personal information is required from children.
• Avatar Customizations: Players may select avatar customizations and preferences within the game.

2. How We Use Your Information

We use the data we collect for the following purposes:

• To provide the game: To create your player profile, save your progress, and allow you to play and interact with others in the game.
• To improve the game: To analyze how the game is used so we can improve features, fix bugs, and optimize performance.
• For safety and security: To moderate chat and ensure a safe, positive environment for all players.
• For communication: To send important, non-promotional messages to parents or guardians about the account or app updates.

We do not sell, rent, or share your personal information for advertising or marketing purposes.

3. How We Share Your Information

We share limited information with third-party service providers who help us operate and improve the app. These providers are strictly prohibited from using your data for any other purpose and are contractually bound to protect it.

• Analytics: We use aggregated, anonymized data to understand game performance and user behavior.
• Cloud Services: We use secure cloud hosting providers (e.g., AWS, Azure) to store game data, including progress and profiles.

We will only share your information if required by law or to protect the safety of our users or our service.

Child and Teen Safety: Ad-Free Experience

Frutebowl is committed to providing a completely safe, ad-free environment for all users:

• Zero Advertisements: Frutebowl does not display any advertisements, promotional content, or marketing materials to any users. The app is completely ad-free for all account types.
• No Tracking: We do not track users for advertising purposes or share any data with advertising networks or third-party marketers.
• No External Links for Minors: Child and teen accounts cannot access external websites, social media, or third-party services. External links (such as privacy policy or support pages) are completely hidden from minor user interfaces.
• Contained Minor Experience: All game content and educational materials for children and teens are contained within the app environment without any external navigation or web browsing capabilities.
• Educational Content Generation: The app uses secure, automated services to generate age-appropriate educational content (such as spelling words) behind the scenes. This content generation does not involve any user data or personal information and operates invisibly within the app's educational framework.

4. Children's Privacy & Parental Consent

Frutebowl is designed for children. We strictly adhere to the Children's Online Privacy Protection Act (COPPA) in the U.S. and the UK Age-Appropriate Design Code to ensure a safe and private experience for all our players.

Guardian Code System

Frutebowl uses a guardian code system to ensure parental control and child safety:

• Guardian Account Creation: Parents, guardians, or educators create an adult account using their email address that generates unique guardian codes.
• Adding Children: Children are added to guardian accounts and only need to provide a nickname - no email address or other personal information is required from children.
• Guardian Code Authorization: Children must enter a valid guardian code generated by their parent/guardian to access the game.
• Remote Control: Guardian account holders can remotely logout their child from the game and disable access by removing or deactivating the guardian code from their guardian account.
• Account Supervision: All child accounts are linked to and supervised by guardian accounts, ensuring complete parental oversight and control.

Parents can contact us at [email protected] at any time to:

• Review the minimal information we have collected from their child (nickname and game progress only - no birth date or personal information).
• Request that we delete their child's account and game data.
• Get assistance with guardian code or account issues.
• Report any concerns about their child's app usage.

5. International Data Transfers

Your data may be processed and stored on secure servers located outside of your country of residence, including in the UK, EU, and the United States. When we transfer your data internationally, we implement appropriate safeguards, such as Standard Contractual Clauses, to ensure your data is protected to the same high standards as in your home country.

6. Data Retention

• We retain your account and progress data for as long as your account is active.
• If an account is inactive for more than 12 months, we may anonymize or delete the data.
• You or your parent/guardian can request account and data deletion at any time by contacting us.

7. How We Protect Your Data

We are committed to protecting your data. We use industry-standard security measures, including:

• Encrypted connections (HTTPS) to protect data in transit.
• Secure, access-controlled storage systems for data at rest.
• Strict internal policies to limit staff access to user data.
• Regular security audits and vulnerability scanning.

While no system is completely foolproof, we work diligently to protect your information and privacy.

8. Your Rights

Depending on your location (e.g., GDPR in the EU, CCPA in California), you may have the following rights regarding your data:

• The right to **access** your data.
• The right to **correct** inaccurate data.
• The right to **delete** your data.
• The right to **object** to or **restrict** certain data processing.
• The right to **data portability** (receive your data in a structured, common format).

To exercise these rights, please contact us at [email protected].

9. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the updated policy in the app or on our website.

10. Contact Us

If you have any questions or concerns about this policy or our privacy practices, please contact us at:

General Privacy Inquiries:
Email: [email protected]
Telephone: 0330 229 0695
Mail: 714 London Road, Larkfield, Kent, ME20 6BL

Data Protection Officer:
For privacy-specific inquiries, data protection matters, and exercising your rights under GDPR/CCPA, you can contact our Data Protection Officer:
Bonnie Jennings, DPO
Email: [email protected]
The DPO is available to assist with data protection compliance, privacy concerns, and ensuring your rights are respected.

Thank you for learning and playing with Frutebowl!