Privacy Policy
Effective: 2026-07-16
Pumlo ("the App", "we", "us") is a collection of mini-games designed for children ages 2 through 9. We treat children's privacy as a first-class design constraint. This Privacy Policy explains, in plain language, what information the App processes, what it does not, who has access to that information, and what controls parents have.
The App is operated by an independent individual developer (the "Developer"), reachable at butyoux@163.com. For purposes of the EU/UK General Data Protection Regulation, the Developer is the data controller for the limited information processed in connection with subscriptions, as described below.
1. Information We Do NOT Collect
We do not require an account, registration, or login of any kind. We do not collect or transmit your child's name, phone number, email address, mailing address, birthday, exact age, gender, photographs, voice recordings, contacts, precise location, biometric data, or any other personally identifying information.
2. Information Stored Locally
The App stores the following on the device only, in a private application sandbox:
• The age band you selected during onboarding (one of 2–3, 4–5, or 6–9). This is used to choose age-appropriate games and is never transmitted off the device. • The daily play-time limit, if you set one in Settings. • Game completion history and play durations, used to avoid back-to-back repeats and to enforce the daily limit. • Sound and language preferences. • A randomly-generated anonymous local identifier (UUID) reserved for future internal-anonymous deduplication. It is not linked to your child's identity and is never sent to third parties. • Timestamps recording when you accepted the Privacy Policy and Terms of Service.
You can erase all of the above at any time from the Parent Area → Delete Local Data screen.
3. How Local Information Is Used
Locally stored information is used solely to operate the App: to choose age-appropriate games, to enforce the daily play limit you set, and to remember your preferences across launches. It is not used for advertising, profiling, recommendations driven by behavioural inference, or anything beyond the gameplay loop you see on screen.
4. Subscriptions (Apple App Store Only)
Subscriptions, if you choose to purchase one, are sold and processed entirely by Apple App Store. We never see your payment details.
To check whether a device has an active subscription and to support the "Restore Purchase" feature, the App uses Apple's standard on-device StoreKit framework, which talks directly to Apple. No third-party subscription service is involved, and the App sends nothing about you or your child to anyone. Subscription state is tied to your Apple ID and handled under the Apple Media Services Terms and the Apple Privacy Policy.
5. Third Parties We Do NOT Use
The App does not integrate with advertising networks, behavioural-tracking SDKs, cross-app trackers, social-login providers, analytics services that profile users, or any other third party that would receive a child's information. No data leaves the device except the standard communication between your device and Apple that every App Store purchase uses (Section 4).
6. Permissions We Do NOT Request
The App does not request access to the camera, microphone, photo library, contacts, calendar, location services, Bluetooth, motion sensors, or push notifications. If a future feature requires a permission, the App will request it only at the moment you choose to use that feature, with a clear explanation of why.
7. Your Rights and Parental Controls
All purchase, restore, and data-deletion actions are gated behind a Parent Area that requires reading a spelled-out number — a challenge designed for adults, with a cooldown after repeated wrong answers. Inside the Parent Area you can:
• Delete all locally stored data with one tap. • Restore a previous subscription on the same Apple ID. • Start or review the subscription.
This Privacy Policy, the Terms of Service, and the Child Information Protection summary are reachable from Settings without the gate.
Deleting local data does NOT cancel an active App Store subscription. To cancel, open Settings → your Apple ID → Subscriptions on this device.
8. Children's Privacy (COPPA)
The App is intended for use by children ages 2–9 with adult supervision. Because the Developer does not collect any personal information from children, the App does not require verifiable parental consent under the U.S. Children's Online Privacy Protection Act (COPPA) for data collection — there is no data to consent to. All purchase and account actions are additionally gated behind the Parent Area to prevent accidental in-app charges by children.
9. EU / UK Users (GDPR & UK GDPR)
If you reside in the European Union, the European Economic Area, the United Kingdom, or Switzerland, you have the following rights with respect to any personal data the Developer holds about you:
• Right of access (Art. 15) • Right to rectification (Art. 16) • Right to erasure (Art. 17) • Right to restriction of processing (Art. 18) • Right to data portability (Art. 20) • Right to object to processing (Art. 21) • Right to lodge a complaint with your local data protection supervisory authority
In practice, because no personal data about your child or you is collected (Section 1), most of these rights have no underlying data to act on. The "Delete Local Data" action in the Parent Area achieves erasure of all locally stored content. To exercise any other right, contact butyoux@163.com; we will respond within 30 days.
Legal basis for any processing: contractual necessity (Art. 6(1)(b)) — operation of the App and verification of subscription state via Apple App Store as described in Section 4. No automated decision-making with legal or similarly significant effects is performed.
10. California Residents (CCPA / CPRA)
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, grants you the following:
• Right to know what personal information is collected, used, shared, or sold • Right to delete personal information held about you • Right to correct inaccurate personal information • Right to opt-out of the sale or sharing of personal information • Right to limit use of sensitive personal information • Right to non-discrimination for exercising these rights
The App does not sell or share personal information with anyone for any purpose, and does not collect personal information about California residents beyond the subscription state described in Section 4 — which is processed solely by Apple App Store to verify your active entitlement. There is therefore no opt-out to exercise. To submit any other request, contact butyoux@163.com.
11. Data Retention
Locally stored information remains on the device until you delete the App or use the Delete Local Data action in the Parent Area. Subscription state held by Apple is governed by Apple's retention policies and is tied to your Apple ID, not to the App.
12. Where the App Is Available
The App is distributed through Apple App Store storefronts worldwide, with the exception of mainland China. The live list of supported regions is the App Store storefront on your device. Because no personal information leaves your device, this Privacy Policy applies uniformly across all supported regions, supplemented by the EU/UK and California sections above for those residents.
13. Changes to This Policy
The Developer may update this Privacy Policy from time to time. When that happens, the "Effective" date above is updated and, for material changes, the updated policy is presented on next launch so you can review it before continuing to use the App.
14. Data Controller and Contact
Data controller: the independent individual developer of Pumlo ("the Developer").
Contact: butyoux@163.com — questions, GDPR/CCPA requests, or other privacy concerns. The Developer aims to reply within 7 days for general questions and within 30 days for formal data-rights requests.