Children’s Privacy Policy

1) Who operates the Kids App (Data Controller)

• Data Controller: Nevzat Atilla Özder
• Address: Çavuş Mah. Muhteşem Sk. 6B/16 Şile / İstanbul, Türkiye
• Email: support@atillaozder.com
• DPO: No DPO appointed.

2) What we collect from children

We designed the Kids App to collect as little information as possible.

A) Information we DO NOT collect in the Kids App

• No ads.
• No analytics SDKs.
• No third-party tracking.
• No push notification token collection.
• No user accounts or login.
• No user-generated content (no chat, no profile, no uploads).
• No precise location (GPS), contacts, photos, camera, microphone, or health data.

B) Information processed by Apple (App Store / In-App Purchases / Diagnostics)

The Kids App uses Apple’s App Store and In-App Purchase system (StoreKit). We do not receive your payment card information. Apple may process personal data when you download the app and when you make a purchase (for example, account and purchase information) under Apple’s own privacy policies.

Apple diagnostics (optional): If the device owner has opted in to share technical diagnostics with app developers in iOS settings, Apple may provide us with anonymized or aggregated crash and performance information to help us fix bugs. This information is provided through Apple’s developer tools and is not used for tracking.

C) Information you choose to send us (optional)

If a parent/guardian contacts us for support by email, we will receive the information in that email (for example: the email address and message content). We do not ask children to submit personal information in the Kids App.

Unsolicited information: If we discover that we have received personal information from a child without a parent/guardian’s involvement (for example, an unsolicited email), we will delete that information as soon as reasonably possible.

3) How we use information

Because we do not use analytics/ads SDKs in the Kids App, our use of personal data is limited to:

• Responding to parent/guardian support requests sent to support@atillaozder.com
• Maintaining and improving the Kids App based on our own testing and user feedback (without in-app analytics tracking)

We do not use information for behavioral advertising or tracking.

Automated decision-making: We do not use automated decision-making that produces legal effects or similarly significant effects on children or parents.

4) How we share information

We do not sell or rent personal information.

We may share information only in these situations:

• With Apple: To process downloads and in-app purchases via the App Store.
• Legal / safety reasons: If required to comply with applicable law or to protect users and the integrity of our services.

5) Data retention

• In-app data: We do not maintain a user account database for the Kids App.
• Support emails: If you email us, we retain the email as long as reasonably necessary to respond and for recordkeeping and legal compliance. You can request deletion (see Section 8).

6) International transfers

We are located in Türkiye. Apple and its service providers may process App Store, purchase, and optional diagnostics data in the United States and other countries under Apple’s privacy policies.

7) Security

We use commercially reasonable safeguards for the information we control (such as support emails). No method of transmission or storage is 100% secure.

8) Your rights (parents/guardians) and how to contact us

A) United States (COPPA & California/State Laws)

COPPA: COPPA applies to online services directed to children under 13. Because we do not knowingly collect personal information from children in the Kids App, we do not request parental consent for data collection inside the Kids App.

California & U.S. state rights: We do not sell or share (for cross-context behavioral advertising) the personal information of children or consumers of any age.

If you believe your child has provided personal information to us, contact us and we will take appropriate steps to delete it where feasible.

B) GDPR / UK GDPR (EEA/UK)

If you are in the EEA/UK, you may have rights such as access, correction, deletion, restriction, objection, portability, and the right to withdraw consent (where consent applies).

C) Türkiye KVKK (Law No. 6698)

For users in Türkiye: You have rights under Article 11 of KVKK, including (among others) the right to:

• learn whether your personal data is processed,
• request information if processed,
• learn the purpose of processing and whether it is used in accordance with that purpose,
• know third parties to whom personal data is transferred (domestic/abroad),
• request correction of incomplete/incorrect data,
• request deletion or destruction under applicable conditions,
• request notification of correction/deletion to third parties to whom data was transferred,
• object to a result against you arising from analysis exclusively by automated systems, and
• request compensation for damages arising from unlawful processing.

How to exercise rights (email only)

Email: support@atillaozder.com
Please include the Kids App name, your request type (access/deletion/etc.), and enough detail to help us locate the relevant communication (for example, the email thread).

9) Third-party links and Parental Gates

The Kids App is designed to provide a safe environment.

Parental Gates: If the Kids App includes any link that leads outside the app (such as a link to our support email, website, privacy policy, or other apps), that link is intended to be protected by a “Parental Gate” (a challenge designed to help ensure the user is an adult) to prevent children from accessing external content without supervision.

Third parties: If a parent/guardian chooses to navigate to a third-party website or service, that third party’s privacy practices will apply.

10) Changes to this policy

We may update this Children’s Privacy Policy from time to time. We will post the updated version with a new “Last updated” date.

11) Contact

• Nevzat Atilla Özder
• Çavuş Mah. Muhteşem Sk. 6B/16 Şile / İstanbul, Türkiye
• Email: support@atillaozder.com