Privacy Policy

Service: kids51.com (the website, the installable web app, and any future iOS/Android apps — together, the “Service”) Version: DRAFT v0.1 — 14 October 2026 — not yet in force Effective date: [EFFECTIVE DATE]

This policy explains what information we collect, why, how long we keep it, who helps us process it, and the choices you have. It is written for parents and guardians first, because parents are the only people who can create an account on kids51.com. Children use the Service only through a profile that a parent creates and controls.

The part of this policy that applies to information about children is in Section 4 (Children’s privacy / COPPA). Our full data retention schedule is in Section 7 and in our Data Retention Policy.

1. Who we are and how to reach us

The Service is operated by:

Dzmitry Pliachko ul. Stanisława Drabika 63/19, 52-131 Wrocław, Poland Sole proprietor registered in CEIDG (Poland) · NIP: 8992909337 · REGON: 520256406 Email: hello@kids51.com Telephone: +48 699 810 680

We are the only operator that collects or maintains personal information from children through the Service. Parents can direct all questions about this policy and about their child’s information to the contact details above.

Because our company is established in Poland (European Union), we also act as the “controller” of personal data under the EU General Data Protection Regulation (GDPR), and GDPR applies to our processing wherever our users live. [TO CONFIRM: whether a Data Protection Officer is designated; if not, delete this sentence. If yes: DPO contact: [DPO EMAIL].]

2. The short version

• Parents create the account with an email address (we sign you in with a one-time email link — no password).
• A child profile contains only a nickname, an avatar picked from our fixed set, and, if the parent chooses, an age band (5–6, 7–8 or 9–11). We never ask for a child’s real name, photo, voice, birthdate, school, or location.
• We record practice results (for example, “7 × 8, correct, 3.1 seconds”) so the app can adapt to your child and show you progress. Raw practice events are deleted after 90 days.
• No ads. There are no advertisements anywhere on the Service, and there will never be ads in the children’s area.
• No third-party trackers, SDKs or cookies on children’s screens. Our analytics are first-party, cookieless and contain no identifiers.
• Audio in the games is pre-recorded text-to-speech that we host ourselves. We never record or transmit a child’s voice, and we never ask for microphone, camera or location access.
• We do not sell or share personal information, and we do not use it for targeted advertising or to build profiles for anyone else.
• You can view, export (JSON), and delete your child’s data and your account at any time from the parent dashboard, or through our public deletion form.

3. Information we collect about parents (account holders)

Payment card details are entered on Stripe’s hosted checkout page, not on our site. We never see or store your full card number. Stripe also collects your billing address so that the correct sales tax can be calculated (see Section 6).

4. Children’s privacy / COPPA

This section is our online notice under the U.S. Children’s Online Privacy Protection Act (COPPA) and the FTC’s COPPA Rule (16 CFR Part 312). It describes our practices for children under 13. We apply the same practices to every child profile, whatever the child’s age.

4.1 How children use the Service

• Without an account a child can play the games on our public pages. Progress is saved only on that device (in the browser’s local storage) and is not sent to us. We collect no personal information from that play other than what any web server must process to deliver a page (see 4.4).
• With a parent account, a parent creates up to 4 child profiles and links a child’s device to a profile with a short pairing code. Only then does the child’s practice sync to our servers, so the parent can see progress and the app can adapt across devices.
• Children cannot create accounts, cannot sign in with an email address, cannot type free text to us or to anyone else, and cannot chat, post, or make anything public. There is no way for a child to make personal information publicly available on the Service.

4.2 What we collect about a child — only after a parent consents

What we never collect from or about a child: first or last name, photo, video, voice or other audio, birthdate, school, home address, geolocation, phone number, email address, government ID, biometric data, contacts, or free-text messages. Our games do not request microphone, camera or location permissions, and our servers send headers that block those permissions on every page.

A child’s name on printables. Some printable worksheets let a parent type a child’s name to appear on the page. The PDF is created entirely on your device; the name is not sent to us and we do not store it.

4.3 How we use a child’s information

Only to provide the Service to the parent and child: running and adapting the practice, syncing between the family’s devices, showing progress in the parent dashboard, generating worksheets from mistakes, keeping the Service secure, and complying with law. We do not use children’s information for advertising of any kind, for profiling for anyone else’s purposes, or to train third-party AI models, and we do not send it to any AI provider.

4.4 Persistent identifiers used for internal operations

Like any website, our servers must process a device’s IP address to deliver pages and audio. On children’s screens we use:

• the device’s IP address, only transiently, to deliver content and to derive a country for aggregate counts; our server logs mask IP addresses and are deleted after 7 days;
• the device link token described above (after parental consent only), to authenticate the paired device;
• when a device is being paired with a code, a keyed hash of its network address (never the IP address itself), to limit pairing attempts to 20 per hour so codes cannot be guessed; it is deleted automatically 1 hour after the attempt.

We use these only to support the internal operations of the Service: to deliver content and keep it working, to authenticate the paired device and personalize practice, and to protect security. We prevent their use to contact a specific child, to build a profile on a child, or for behavioral advertising by: (1) running no third-party scripts, SDKs, ad networks or analytics on children’s screens (enforced by a strict Content-Security-Policy and an automated test that fails our build if any outside request appears); (2) not storing IP addresses or device information with analytics; and (3) never giving these identifiers to anyone other than our hosting provider acting for us.

4.5 Analytics on children’s screens

We count anonymous events such as “a game started”, “a round was finished in calm mode” and how long a session lasted in broad buckets (0–2, 2–5, 5–10, 10+ minutes), together with the page template, country and device class (phone/tablet/desktop). On children’s screens we do not use any visitor ID, daily hash, cookie, or fingerprint, so these events cannot be linked to a child, a device, or a family. They are stored in our own Cloudflare account and deleted after 3 months.

4.6 Disclosure of children’s information

We do not disclose children’s personal information to third parties, and we do not make it public. Children’s information is stored by Cloudflare, our hosting provider, which processes it only on our behalf and under a written agreement. We never send any child information to Stripe (payments) or to our email provider; [TO CONFIRM — engineering: emails to parents, including the weekly progress email, must contain no nickname or progress data and only a link to the dashboard]. We may disclose information if required by law (for example, a valid court order), or to protect the safety of a child or the security of the Service, as permitted by 16 CFR 312.5(c)(6).

4.7 Parental consent

We ask for the parent’s consent before we collect any information about a child. When a parent creates the first child profile, we show a notice describing our practices (also sent by email) and ask the parent to confirm that they are the child’s parent or legal guardian and consent. The parent is already signed in through a link sent to their email address. We then send a confirmation email to that address [TO CONFIRM: 24 hours] later, which repeats this notice and explains how to withdraw consent. The email has two one-time links, valid for 30 days: one to confirm the consent (we record the consent as confirmed only when the parent opens it and presses the confirm button), and one to withdraw it without signing in. When a parent later subscribes, the card payment through Stripe gives us further confirmation that an adult account holder is involved. Details: Direct Notice to Parents.

If we make a material change to how we collect, use or disclose children’s information, we will notify parents directly and ask for new consent before applying the change to their child’s information.

4.8 Parents’ rights and how to use them

At any time a parent can:

• review the child’s information — in the parent dashboard, or by downloading a JSON export of all data in the account;
• delete a child profile — immediately, from the dashboard; this deletes the profile, its practice events and skill progress, and unlinks it from devices;
• refuse further collection — by deleting the profile or unlinking the child’s devices; the child can still play without an account, with progress kept only on the device;
• delete the whole account — from the dashboard, or through our public form at https://kids51.com/delete-my-data/ if you cannot sign in (we verify the request by sending a confirmation link to the account email);
• withdraw consent — from the parent dashboard (“Withdraw consent”), with the one-time withdrawal link in the consent confirmation email (no sign-in needed; you confirm on the page), by deleting the profile(s), or by writing to hello@kids51.com. Withdrawing consent stops all collection immediately: the child’s devices are unlinked, practice events and skill progress are deleted, and the profiles are paused (only the nickname and avatar remain, so you can switch them back on). Your parent account and any subscription are kept. You can give consent again later from the dashboard; until then nothing is collected for those profiles.

To protect your child, we confirm that a request comes from the parent: through your signed-in session (sensitive actions such as deletion and billing require a sign-in from the last 15 minutes), or through a confirmation link sent to the account email. We will not refuse the Service to a child for any reason other than the parent’s choice to stop collection, and we never require a child to provide more information than is reasonably necessary to play.

4.9 Teachers and classes (coming later)

We plan to let teachers create classes with a class code. That feature will be offered only under a separate Teacher & School Terms for school-authorized educational use, will use only a nickname and an avatar for each student, and will carry no advertising and no commercial use of student data. This section will be updated before the feature launches. [TO CONFIRM launch; see teacher-school-terms.md]

5. Information collected automatically from all visitors

Cookies and similar storage. We use one first-party cookie, only in the parent area, to keep you signed in (strictly necessary). [TO CONFIRM: storage mechanism for the device link token on a paired child device — local storage or cookie.] Games may store progress in your browser’s local storage on your device. We use no advertising, analytics or social-media cookies, and no cross-site tracking. Because we do not track you across sites, we do not respond differently to “Do Not Track” signals; we honor Global Privacy Control signals by default because we never sell or share data. [TO CONFIRM: whether Cloudflare Turnstile is used on the parent sign-in form; if yes, add it here and in Section 6 as a security service that processes device signals on that form only.]

6. Service providers (processors) we use

We share personal information only with these providers, who process it on our behalf, under written agreements that require confidentiality and security:

Not a recipient of user data: we use ElevenLabs to generate the game audio (text-to-speech) before publication, from our own scripts. ElevenLabs receives only our content text — never any information about parents or children — and children’s devices never connect to it. [TO CONFIRM: if the planned “custom words” feature sends parent-entered words to ElevenLabs at runtime, this paragraph and Section 4.6 must be updated before launch.]

Stripe may keep certain transaction data after we delete your account, as required by its own legal obligations (for example, anti-fraud and financial regulation); for that processing Stripe acts under its own privacy policy: https://stripe.com/privacy.

International transfers. Our providers may process data in the United States and other countries. Where GDPR applies, transfers out of the European Economic Area rely on the EU–US Data Privacy Framework where the provider is certified, or on the European Commission’s Standard Contractual Clauses. [TO CONFIRM: each provider’s transfer mechanism; D1 database location/jurisdiction setting.]

Other disclosures. We may disclose information if required by law or valid legal process, to protect rights, safety and security, or as part of a merger or sale of our business — in which case the buyer must honor this policy for information collected under it, and parents will be notified before any change to how children’s information is handled.

7. How long we keep information

We keep information only as long as needed for the purposes above, then delete it. We never keep children’s information indefinitely. The full schedule, with the business reason for each period, is in our Data Retention Policy. Key points:

• practice events: 90 days; child profiles and skill progress: until the parent deletes them or the account;
• inactive accounts: deleted after 24 months of inactivity plus a 30-day email warning;
• unused child-device links: revoked after 90 days;
• analytics: 3 months; server logs: 7 days; pairing abuse-protection counters (hashed network address): 1 hour;
• if a parent withdraws consent without deleting the account, practice events and skill progress are deleted immediately and the paused profiles keep only nickname and avatar until the parent re-consents or deletes them;
• when you delete your account, deletion runs automatically and immediately; we promise completion within 7 days. Deleted data disappears from our database backups within 30 days.
• we keep only financial records (5 years from the end of the tax year, no email, no child data), proof that we honored a deletion request (3 years, hashed email only), and [TO CONFIRM — R3] proof of consent.

8. Security

We protect information with measures appropriate to its sensitivity, including: encryption in transit (HTTPS) for every connection; storing sign-in links, session IDs and device tokens only as hashes; one-time 15-minute sign-in links; re-authentication for billing and deletion; strict isolation of children’s screens from any outside service; two-factor authentication on our administrative accounts; and a written information security program with a named coordinator and at least annual risk assessments. No method of transmission or storage is perfectly secure. If a security incident affects your information, we will notify you and the authorities as required by law.

9. Your privacy rights

Every account holder, wherever you live, can ask us to access, export, correct, or delete personal information, and to withdraw consent (for example, for marketing emails). Most of this you can do yourself in the dashboard; otherwise write to hello@kids51.com. We respond within 30 days [TO CONFIRM — GDPR requires one month; keep 30 days or “one month”]. We will not discriminate against you for using your rights.

U.S. state privacy laws. We do not sell personal information, do not “share” it for cross-context behavioral advertising, do not use it for targeted advertising, and do not use it for profiling that produces legal or similarly significant effects. We do not knowingly process the personal information of minors for any of those purposes.

EU/EEA and UK users (GDPR). In addition to the rights above, you have the right to object to processing based on legitimate interests, to restrict processing, and to data portability. You can lodge a complaint with the Polish supervisory authority, the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO), ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl, or with the authority in your country. Providing your email address is necessary to have an account; everything else is optional.

10. Changes to this policy

We will post the updated policy with a new effective date. If a change is material, we will email account holders before it takes effect, and where the change affects children’s information we will ask parents for new consent first, as described in Section 4.7.

11. Contact

Dzmitry Pliachko, ul. Stanisława Drabika 63/19, 52-131 Wrocław, Poland · hello@kids51.com · +48 699 810 680