Games Pricing Blog FAQ
Profile

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 plays our games, we do not collect personal information such as full names, home addresses, or direct contact details. We do collect certain technical data automatically (such as IP addresses, device identifiers, and country-level location) to support the operation and improvement of our games. This technical data is described in detail in the “What Data We Collect and Why” section below.

We also gather general usage data, such as the country of residence, time spent in our games, and the types of devices being used. Where possible, this information is aggregated or pseudonymised. We use this data to understand our audience better and to improve our games.

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.

TUTOCLUB.COM Privacy Policy

March 2026

About This Policy

We are TutoTOONS Ltd., a company with registered office at Kintail House, Beechwood Park, Inverness, Scotland, IV2 3BW. We are the data controller responsible for your personal data.

This notice explains how TutoTOONS collects and processes personal data relating to users of TutoClub (the “Service”) and any services we provide in connection with TutoClub, including our website at www.tutoclub.com. When we decide how and why your personal data is processed, we act as the data controller.

If you have any questions about this notice or your personal data, contact us at [email protected]. Our Data Protection Officer can be contacted at [email protected].

This notice covers only the TutoClub Service and the website at www.tutoclub.com. For the general TutoTOONS privacy policy covering all other TutoTOONS games and services, please see tutotoons.com/privacy_policy. Where the Service links to websites or services not operated by TutoTOONS, please refer to their own privacy notices.

This Privacy Policy is in compliance with the US Children’s Online Privacy Protection Act (COPPA), the European General Data Protection Regulation (EU GDPR), the UK General Data Protection Regulation (UK GDPR), and the Data Protection Act 2018.

The data we collect depends on how you use the Service. We only collect personal data when we have a lawful reason to do so. This section sets out each type of data, its purpose, and the legal basis we rely on.

Operating the Service (Legal basis: contract performance and legitimate interest)

To provide you with the Service and to manage, protect and improve our website and mobile applications, we collect:
  • Technical Data - your IP address, advertising identifier, device type, mobile operating system, browser type, screen resolution, device vendor, and language settings;
  • Usage Data - statistics on how you use the Service, including information about apps installed on your device, pages visited, session duration, and browsing actions;
  • Location Data - your country (derived from your IP address). We do not collect your exact address or precise location.

This data is collected automatically when you use the Service. We use it to ensure the Service is provided, to improve and customise it, to ensure its security and integrity, and to submit contextual (non-behavioural) advertising.

We do not use your data to provide behavioural advertising, remarketing, or profiling. We do not carry out any automated decision-making (as defined in Article 22 of the GDPR/UK GDPR) that produces legal effects or similarly significantly affects you.

Managing TutoClub Subscriptions (Legal basis: contract performance)

When you subscribe to TutoClub, we collect and use additional personal data to create and manage your subscriber account:

  • Subscription Data - your chosen login method, email address, current subscription plan, billing status, connected devices, unique ID, and device ID.

We use this data to authenticate you and manage your subscription (for example, to determine on how many devices the subscription has been activated). We process your personal data ourselves; it is not disclosed to any third party for their own purposes.

We do not collect or store any of your financial data. Payments are handled by the platform you use to download our apps (such as Apple App Store, Google Play, or Amazon). If you purchase a subscription through our webshop at www.tutoclub.com, your payment is securely processed by our third-party payment provider, Stripe. We do not collect or store your payment details.

Responding to Your Requests (Legal basis: legitimate interest)

When you contact us by email, social networks, or phone, we collect your Contact Data (such as your phone number and email address) and any information you provide in your request. We use this data to respond to your query.

If a child under the age of 13 (USA) or under 16 (EU) contacts us and we need to communicate with them more than once, we will ask for their parent or guardian’s email address. We will then notify the parent or guardian that their child has contacted us. If we do not obtain parental consent within a reasonable time, we will delete the data from our records.

Age Surveys (Legal basis: legitimate interest)

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 is optional.

The age data is anonymised and not used to identify individual users, nor is it used for advertising, profiling, or personalised marketing. We do not use age data to track users across apps or services.

Marketing Communications (Legal basis: consent)

By creating your TutoClub account, you may agree to receive our newsletters or other emails promoting special offers. You can always opt out from receiving promotional or marketing correspondence from us by unsubscribing as noted in the respective email correspondence.

Cookie-Based Analytics and Advertising Measurement (Legal basis: consent)

We use Meta Pixel (Facebook Pixel) on our website at www.tutoclub.com for analytics and advertising measurement purposes. Meta Pixel uses cookies (including _fbp, _fbc, and fr) to track website interactions and measure the effectiveness of our advertising campaigns. These cookies are non-essential and are only activated after you provide consent via our cookie banner.

For more information, see Meta Platforms, Inc. in the “Who We Share Your Data With” section below.

Obtaining Parental Consent (Legal basis: legal obligation)

Where we must obtain the consent of parents or guardians to use a child’s personal data (email and name), we collect the parent or guardian’s email address. This is necessary to comply with our legal obligations under COPPA and GDPR/UK GDPR.

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, or any data that is not necessary for the provision of our services.

We keep your data only for as long as it is needed for the purposes described in this notice. When data is no longer needed, we delete it or anonymise it. The following retention periods apply to specific categories of data:

  • Contact Data (e.g. email from enquiries) - retained for the duration of the enquiry plus 12 months, unless a longer period is required to resolve a complaint or legal matter.
  • Technical Data and Usage Data and Location Data (country) - retained for the period needed to provide services.
  • Subscription Data (TutoClub) - retained for the duration of the subscription plus 3 years to comply with legal obligations and protect our legal interests.
  • Meta Pixel / Cookie Data - retained in accordance with the cookie lifetimes specified in the “Cookies and Similar Technologies” section and Meta’s data retention policies.

In some cases, we may need to retain data for longer where required by law. If we do, we will keep it secure and continue to respect your rights where possible.

You can request deletion of your data at any time by emailing us at [email protected].

We share your data only where necessary and only with the following recipients:

  • Companies of our group - third-party service providers and other partners to ensure the provision and improvement of our Services and their security.
  • Law enforcement and authorities - where required by law, to comply with legal obligations, or to protect the rights and safety of our users.
  • Corporate transactions - if TutoTOONS undergoes an investment, merger, acquisition or sale of assets, personal data may be shared as part of that process, provided the buyer agrees to use your data only for the purposes specified in this notice.
  • Any other person with your consent to disclose information.
    • TutoTOONS does not sell your personal data to third parties.

    Our Third-Party Data Controllers and Processors

    We work with the following third-party service providers. Each processes data only for the purposes described and in accordance with their own privacy policies:

    Advertising Networks

    Legal basis for all advertising network processing: legitimate interests (support for internal operations).


    Analytics, Attribution and Monitoring

    Legal basis for analytics processing: legitimate interests (support for internal operations), except Meta Pixel which relies on consent.


    Consent Management and Payments

    • CookieYes Limited - cookie consent and compliance solutions. Processing location: UK. Privacy policy: cookieyes.com/privacy-policy/
    • Stripe, Inc. - payment processing for webshop subscription purchases. Processing location: USA / Ireland. Legal basis: necessary for contract performance. Privacy policy: stripe.com/privacy

    Your data is stored on rented and properly protected servers based in Lithuania, operated by “Interneto vizija”, UAB.

    Some of our service providers are based outside the United Kingdom and European Economic Area. Where we transfer personal data to a country that does not provide an equivalent level of protection, we put appropriate safeguards in place as required by law:

    • Adequacy decisions - we may transfer data to countries that the European Commission or UK Secretary of State has determined provide an adequate level of data protection.
    • EU-US Data Privacy Framework (DPF) - for transfers to the United States, we rely on the EU-US Data Privacy Framework where the recipient is a certified participant, and the UK Extension to the DPF, where applicable.
    • Standard Contractual Clauses (SCCs) - where no adequacy decision or DPF certification applies, we use the European Commission’s Standard Contractual Clauses (June 2021 version). For UK transfers, we supplement these with the UK International Data Transfer Addendum (IDTA) issued by the ICO.
    • Transfer Impact Assessments - where required, we conduct transfer impact assessments to evaluate the level of data protection in the recipient country and implement supplementary measures where necessary.

    For more details about the specific transfer mechanism used for a particular service provider, contact us at [email protected].

    When you use our services, we may use industry-wide technologies such as cookies and/or other technologies, hardware-based device identifiers, 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. If you do not accept, block or erase cookies, or change the settings, your online experience may be limited.

    We also use Meta Pixel (Facebook Pixel) on our website at www.tutoclub.com for analytics and advertising measurement purposes. These cookies are non-essential and are only activated after you provide consent via our cookie banner.

    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.

    You can request deletion of your data at any time, free of charge, regardless of where you are located. Email us at [email protected].

    We will act on your request within 30 days. In some cases, we may need to retain certain data where required by law (for example, to comply with a legal obligation or to resolve a dispute). If any exception applies, we will explain why.

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

    Depending on where you are located, you may have rights under applicable data protection laws. These include the right to:

    • access the personal data we hold about you;
    • correct any inaccurate or incomplete data;
    • request deletion of your personal data;
    • request a copy of your data in a structured, commonly used, and machine-readable format (data portability);
    • restrict how we process your data;
    • object to our processing of your data where we rely on legitimate interests; and
    • withdraw your consent at any time.

    To exercise any of these rights, email us at [email protected]. We will respond within 30 days. If we need more time, we will let you know within that period and explain why.

    These rights are not absolute - in some circumstances, we may be unable to fulfil a request in full. If that happens, we will explain why.

    If you are not satisfied with how we handle your request, you have the right to lodge a complaint with your local data protection authority. The relevant supervisory authority for TutoTOONS Ltd. is the Information Commissioner’s Office (ICO). If you are in the EU, you can find your supervisory authority via the European Data Protection Board.

    TutoTOONS is committed to protecting children’s privacy. TutoClub is a subscription product designed for children, and we take particular care to ensure that our data practices are appropriate for younger users.

    We do not knowingly collect personal information such as full names, home addresses, or direct contact details from children. We do collect certain technical data automatically (such as IP addresses, device identifiers, and country-level location) to support the operation and improvement of our games. This technical data is described in detail in the “What Data We Collect and Why” section above.

    We also gather general usage data, such as the country of residence, time spent in our games, and the types of devices being used. Where possible, this information is aggregated or pseudonymised. We use this data to understand our audience better and to improve our games.

    If you are a parent or guardian and believe that a child has provided TutoTOONS with personal data without your consent, please contact us at [email protected]. We will delete the data without delay.

    ICO Age Appropriate Design Code (Children’s Code)

    As a UK-registered provider of online services likely to be accessed by children, TutoTOONS is committed to complying with the ICO’s Age Appropriate Design Code (the “Children’s Code”). The Children’s Code sets out 15 standards of age-appropriate design that we apply across our games and services, including:

    • Best interests of the child - the best interests of the child are a primary consideration in the design and operation of our games.
    • Data minimisation - we only collect and retain the minimum amount of personal data necessary to provide our services.
    • Default settings - privacy settings in our games are set to high privacy by default.
    • Transparency - we provide clear, age-appropriate information about how we use personal data.
    • Detrimental use - we do not use children’s personal data in ways that are detrimental to their wellbeing, and we do not use personal data for behavioural advertising or profiling.
    • Parental controls - where applicable, we provide mechanisms for parents and guardians to exercise control over their child’s data.

    For more information about the Children’s Code, visit the ICO’s website.

    If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). The categories of personal information we collect are described in the “What Data We Collect and Why” section above.

    We do not sell or share your personal information for cross-context behavioural advertising. We do not use or disclose sensitive personal information for purposes other than those permitted by the CCPA.

    Under California law, you have the right to:

    • request access to the categories and specific pieces of personal information we have collected about you;
    • request deletion of your personal information;
    • request correction of inaccurate personal information;
    • opt out of the sale or sharing of your personal information (though TutoTOONS does not sell or share personal information); and
    • limit the use of sensitive personal information.

    We will not discriminate against you for exercising any of these rights. To make a request, contact us using the details in the “How to Contact Us” section. We will respond within 45 days, as required by California law.

    TutoTOONS works with PRIVO on the following apps: Kpopsies, Fluvsies, Smolsies, My Baby Unicorn, My Baby Unicorn 2, Jungle Animal Hair Salon, Jungle Animal Hair Salon 2, Sweet Baby Girl Cleanup 5, Sweet Baby Girl Summer Fun 2 and Kiki & Fifi Pet Friends. PRIVO is an FTC-approved COPPA Safe Harbor and operates a GDPR kids™ Privacy Assured Program.

    Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification & GDPRkids™

    TutoTOONS Ltd. is a member of the PRIVO Kids Privacy Assured Program (“the Program”) for COPPA Safe Harbor Certification and GDPRkids™. PRIVO is an independent, third-party organization committed to safeguarding children’s personal information collected online.

    The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO Seal. The PRIVO COPPA certification Seal posted on this page indicates TutoTOONS Ltd. has established COPPA-compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at +370 37 300 833 or [email protected]. If you have further concerns after you have contacted us, you can contact PRIVO directly at [email protected].

    The PRIVO GDPRkids™ Privacy Assured Program supports child-directed services known as Information Society Services under the General Data Protection Regulation (GDPR), to comply with the requirements of this legislation.

    The apps listed above do not actively collect personal information from children. We may collect technical data, including an IP address, equipment, browsing actions, country code, user agent, app version, operating system, and models you use, as well as statistics.

    Party Popteenies and Candylocks are trademarks of Spin Master Ltd., used under license. © Spin Master Ltd. All rights reserved.

    We have implemented security measures to ensure that your personal data is not lost, used or accessed without authorisation, altered or disclosed. We restrict access to your personal data to those employees, representatives and other third parties who need to know your details. They will process your personal data in accordance with our instructions and will be subject to confidentiality obligations.

    We have put in place procedures to combat any alleged breach of personal data security and we will inform you and all authorities of the breaches that we are required to notify about.

    We may update this notice from time to time - for example, when our services change or when the law requires it. When we do, we will update the date at the top of this notice. For significant changes, we may also notify you directly.

    If we have your parent's email address, we will contact you to let you know about the changes.

    We encourage you to review this notice regularly.

    If you have any questions about this notice or wish to exercise your rights, contact us at:

    TutoTOONS Ltd.

    Kintail House, Beechwood Park, Inverness, Scotland, IV2 3BW

    When making a data rights request (such as a deletion or access request), please include the nature of your request in the subject line so we can respond promptly.

    Supervisory Authority

    If you are not satisfied with our response or believe we are processing your personal data unlawfully, you have the right to lodge a complaint with:

    Information Commissioner’s Office (ICO)

    Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

    Tel: 0303 123 1113

    Website: ico.org.uk