Children's Privacy Notice

Welcome to our Privacy Hub – your go-to spot for all things privacy-related.

As passionate creators of engaging mobile games for your little ones, we prioritize their safety and aim to enhance their app experiences. We understand the importance of online privacy, and it's our commitment to ensure a secure and enjoyable environment.

When your child immerses themselves in our games, rest assured, we're not in the business of collecting personal information like full names, addresses, or contact details. Our focus is on providing a wholesome and safe digital space.

However, we do gather general data, such as the country of residence, time spent in our games, and the types of devices being used. Fear not, this information is aggregated and anonymized – it's more like statistical puzzle pieces than individual profiles. This data aids us in understanding our audience better and refining our games.

Now, about those in-game ads – we've got it covered. Our Ads Quality Team meticulously ensures that all ads are child-appropriate, and no personal information regarding your child's interactions with ads is collected.

For those inclined towards a deeper dive into our privacy practices, feel free to peruse the remainder of this document. And should any queries arise or if you seek further clarification on our Privacy Policy, reach out to us at [email protected]. We're here to address any concerns you may have.

Thank you for entrusting us with your child's digital adventures.

TutoTOONS Privacy Policy

Last Revised: 21st of October, 2025

At TutoTOONS, ("TutoTOONS", "we") we take privacy seriously and this this Privacy policy is designed to share what information we collect and how we use it. This Privacy Policy is in compliance with the US Children's Online Privacy Protection Act (COPPA) and the European General Data Protection Regulation (GDPR). If you have questions about this Privacy Policy or wish to exercise your rights, please do not hesitate to contact us by email at [email protected].

TutoTOONS Limited is a company with registered office in Kintail House, Beechwood Park, Inverness, Scotland, IV2 3BW.We are the Data Controller responsible for your Personal Data.

Our contact details:
TutoTOONS LIMITED
Kintail House, Beechwood Park, Inverness, Scotland, IV2 3BW
Phone: +37037300833
Email: [email protected]

While you visit our website at www.tutoclub.com or you play TutoTOONS games ("Services" or "Games"), we may collect information about you ("Personal Data"). By this Privacy Policy, we want to clearly and comprehensively explain what data we collect, how we use, disclose and transfer it.

From time to time, we may change the terms of this Privacy Policy, so do not forget to read this Privacy Policy on a regular basis to understand how we use your Personal Data. If we make a material change to this policy, we will post a notice on our website prior to making the change. If we have your parent email address, we will contact you to let you know about the changes.

Note: You must update any mobile applications downloaded before 2018 May 25th

Personal data is any information that relates to an identifiable individual. When you you visit our website at www.tutoclub.com or you play TutoTOONS games ("Services" or "Games"), we may we may collect and process the following personal data about you:

Contact Information

You may provide us with your Contact Information, such as your phone number and email when you contact us with a question or request.

Note: If a child under the age of 13 years old in the USA or under the age of 16 years old in the EU has contacted us through email, and we need to communicate with the child more than once to resolve the query, we will ask the child to provide us with the child's parent or guardian's email. Then we will send the parent or guardian a notice telling that his/her child has contacted us. If we do not obtain parental consent after a reasonable time from the date of the data collection, we will delete such data from our records.

Location Data

We do not collect data about your exact location (address) in any case. We can collect data about your location, i.e. city or country. We collect this data automatically when you use our Services or play our Games.

Technical Data

We may collect such information as your IP address, advertising ID, and other technologies on the devices that you use in our Services or play our Games. We can also collect non-personal Technical Data about the mobile operating system, mobile browser type, screen resolution, device vendor, language. We collect this data automatically when you use our Services or play our Games.

Usage Data

We can collect statistics on how you use our Services or play our Games, including the information about our apps installed on your device. This information does not contain information that will help us identify you. We need this information so that we can provide you with the Services, improve their quality, adapt them to your needs.

Please note, if you decide to purchase the TutoTOONS games subscription, we may collect and use additional personal data as stated in section 7. TutoTOONS Subscription.

Age Information

In some of our games, we may ask users to voluntarily provide their age or age range as part of an in-game survey. This information is collected solely to help us understand audience demographics and improve the overall game experience. Participation in the survey is optional, and users may choose not to provide this information.

The age data is anonymised and not used to identify individual users, nor is it used for advertising, profiling, or any form of personalised marketing. We do not use age data to track users across apps or services, and we do not collect any additional personal data in connection with this survey, regardless of the user’s age.

We are not collecting or storing any of your financial data as management of any payments is done by the respective platform you are using to download our apps from, such as iTunes, Google play, Amazon or others.

If you make a subscription purchase through our official webshop at www.tutoclub.com, your payment is securely processed by our third-party payment provider, Stripe. In this case, we do not collect or store your payment details, and all financial data is handled directly by Stripe in accordance with their privacy and security policies.

We do not collect and do not intend to collect "special categories of data", such as any information about health, race, religion, political opinions or philosophical beliefs, sexual beliefs or orientation, as well as any data that is not necessary for the provision of our services.

We use several methods to collect Personal Data:

Personal Data is provided directly by you

You provide us with your data when you contact us by email, social networks or phone, ask to answer your question.

We collect Personal Data automatically

When you use our Services, e.g. visit our website, play our games, we can automatically collect technical information about your IP address, promotional identifiers, equipment, browsing actions and models you use, as well as statistics. We collect this Personal Data using cookies, automated event logs and other similar technologies.

We collect Personal Data from third parties

We may receive Personal Data about you from third-party sources, i.e. from other companies and persons (see section Our third-party data controllers and processors).

We will only use your Personal Data as permitted by law. Usually, we will use your Personal Data in the following circumstances:

Provide our services or

Pursue legitimate business interests related to providing our services to you

In order to fulfil our obligations when you use our website or our mobile applications, e.g. to ensure that the Services are provided, to improve the Services, to identify subscribers and manage subscriptions, to personalize the content you use, to respond to your requests and inquiries. Also, in order to fulfil our legal obligations, we may ask for the child's parent or guardian's email when we must obtain the consent of parents or guardians to use the child's Personal Data (email and name).

When it is necessary to fulfil our contractual obligations or safeguard our legitimate interests, we use your Personal Data, e.g. to provide you with contextual advertising, to analyse your behaviour using our Services, to ensure the security and integrity of our Services.

Establish, exercise or defend legal claims

We may also use your Personal Data to enforce or defend our rights, protect your interests, prevent and/or detect fraud or deceptive behaviour.

We will not use your data to provide you with behavioural advertising, as well as remarketing, profiling and automated decision making.

Generally, we collect and process your personal information only in order to fulfil our obligations to you, use it for legitimate interests and protect your rights (support for the internal operations), or if we have your consent to do so.

Below, we provide you with information on the purposes and grounds for usage of your Personal Data.

Activity	Data type	Legal basis for data processing according to GDPR / COPPA
Manage and protect our website and our mobile applications	Contact Data Technical Data Usage Data	(a) Necessary for our legitimate interests (GDPR) (b) Necessary for support for the internal operations (COPPA)
Provide Services, improve Services, customize Services for your individual needs	Technical Data Usage Data	(a) Necessary for fulfilling our contractual obligations (GDPR) (b) Necessary for support for the internal operations (COPPA)
Identify games subscribers and manage games subscriptions (only if you get subscription plan)	Contact Data Usage Data	(a) Necessary for fulfilling our contractual obligations (GDPR) (b) Necessary for fulfilling our contractual obligations (GDPR)
Submit contextual advertising to you, analyse your behaviour using our Services	Technical Data Usage Data	a) Necessary for our legitimate interests and for fulfilling our contractual obligations (GDPR) b) Necessary for support for the internal operations (COPPA)
Reply to your applications, requests, notifications	Contact Data Contact data such as email or phone number	a) Necessary for fulfilling our contractual obligations and for legitimate interests (GDPR) If a child under the age of 13 years old in the USA or under the age of 16 years old in the EU has contacted us through email, and we need to communicate with the child more than once to resolve the query, we will ask the child to provide us with the child's parent or guardian's email. Then we will send the parent or guardian a notice telling us that his/her child has contacted us. If we do not obtain parental consent after a reasonable time from the date of the data collection, we will delete such data from our records.
Get the child's parent's or guardian's consent	Contact Data (email)	a) Necessary to comply with our legal obligations (GDPR) b) Exception to prior parental consent (COPPA)

We will use your Personal Data for the purposes for which we have collected them, unless we reasonably believe that we must use it for another purpose that is compatible with the original purpose.

Please note that in cases where we must process Personal Data when required by law, we may process your Personal Data without your knowledge or consent.

If you would like a carefully curated selection of TutoTOONS games for your child that cherish creativity and help develop useful skills with no in-app purchases (including no ads). In that case,we will need to identify you by creating a subscriber account. To get access to TutoTOONS games subscription, a child's parent or guardian is required to agree to our Terms of Use and Privacy Policy as well as login by choosing a preferable login method (platform you’re using to play our games, such as Google Play, Apple App Store, etc.).

Personal data we collect

If you decide to get a TutoTOONS games subscription for your child, we may collect and use some of your personal data, such as chosen login method, email address, current subscription plan, billing, connected devices, unique ID, advertisement ID and device ID.

We are not collecting or storing any of your financial data as management of any payments is done by the respective platform you are using to download our apps from, such as iTunes, Google play, Amazon or others.

By creating your Tutoclub account, you may agree to receive our newsletters or other emails promoting any special offer(s). You can always opt out from receiving special promotions or marketing correspondence from us by unsubscribing as noted in the respective email correspondence.

How and why we use this data

We will use this data only to authenticate a user and manage the user's subscription (e.g. to determine on how many devices subscription has been activated). We process your personal data ourselves, therefore personal information is not disclosed to any third party.

Please note that you have the right to cancel your subscription anytime, however your personal data collected before subscription cancellation will be stored for a period of three years in order to comply with our legal obligations and protect our legal interests.

When you use our services, we may use industry-wide technologies such as cookies and/or other technologies, hardware-based device identifiers, flash cookies, operating system-based identifiers and web beacons.

Cookies are small text files that we place in visitors’ computer browsers to store their preferences. The cookies are created for each session, they do not include or collect any information about you other than your session key, and they are removed as soon as the session ends (usually done automatically by your web browser).

You can disable cookies on your device or set your device to alert you when cookies are being sent to your device.

If you do not accept, block or erase cookies, or change the settings, your online experience may be limited.

We may also use certain third-party cookies (e.g. Google Authentication). These are different kinds of cookies that are stored on your computer by third parties. This kind of cookie is only read (and is not altered by the Service) each time you use our Services. Third party cookies store only Usage Data, such as the different pages you have visited strictly within the Service (such the “About” page, the “Contact Us” page, the duration of your browsing session, etc.).

We use CookieYes Ltd. to manage cookie consent across our website in compliance with applicable privacy laws such as the GDPR and ePrivacy Directive. CookieYes enables us to display cookie banners, record user preferences, and maintain a log of consent records. CookieYes does not collect any personal information for its own purposes and only processes data required for consent tracking and compliance. For more information, see their privacy policy.

We may share your personal information with a few selected third parties, such as:

Companies of our group, third-party service providers and other partners (e.g. to ensure the provision of our Services, to provide services or to improve our Services security), as well as to those who otherwise process Personal Data for the purposes specified in this Privacy Policy. Here is a list of our current service providers and partners (see section Our third-party data controllers and processors).
To any competent law enforcement authority, regulatory authority, government agency, court, or other third party, if we consider that disclosure is necessary (i) in accordance with applicable laws or regulations, (ii) to exercise or to protect our rights, or (iii) to protect our or any other person's interests;
A potential or actual buyer (and its representatives and advisers) involved in the purchase, merger or acquisition of a proposed or actual any part of our business, provided that we inform the buyer that it will have to use your Personal Data only for the purposes specified in this Privacy Policy;
Any other person with your consent to disclose information.

KIDOZ

KIDOZ is an advertising service provided by KIDOZ Ltd. KIDOZ uses Personal and Non-Personal Data only for internal purposes.