📅 Effective: 4 November 2025✓ COPPA Compliant✓ GDPR-K Compliant✓ Google Families Policy
01
Introduction
TORTUGA APPS (SMC-PRIVATE) LIMITED ("we," "us," or "our") is committed to protecting the privacy and safety of children using our mobile application, Kids 123 Learning ("the App"). This Privacy Policy outlines how the App manages data in compliance with applicable regulations, including COPPA, GDPR-K, and Google Play's Families Policy.
The App is designed for young children and offers two primary features: number learning (1–20) and a simple number quiz. The App includes advertising to support its development.
02
Information We Collect
User-Provided Data
The App does not require or collect any user-entered personal data.
Automatically Collected Data
To provide functionality and monetize the App, we use third-party SDKs that may automatically collect certain data. This data is not directly collected or stored by us, but by the third-party providers.
Device Identifiers: We have taken steps to ensure that personal identifiers — such as the Android Advertising ID (AAID) — are not collected or transmitted by our third-party SDKs. The App is configured to prevent collection of this data.
Crash and Usage Data: The App uses Firebase Crashlytics to collect crash reports and Firebase Analytics to understand how users interact with the App. This data is anonymized and helps improve stability and features. Data collected includes device model, OS version, app usage, and crash events.
03
Permissions Used in the App
The App requests and uses the following Android permissions:
GRANTED
android.permission.INTERNET
Required for third-party SDKs to function, including serving ads and sending crash/analytics data.
GRANTED
android.permission.ACCESS_NETWORK_STATE
Allows the App to check network status (Wi-Fi or mobile data) to optimize data usage for SDKs.
REMOVED
com.google.android.gms.permission.AD_ID
This permission is explicitly removed from the App's manifest. The App cannot access the Android Advertising ID, preventing personalized or targeted advertising and strengthening user privacy.
🛡️By removing the AD_ID permission, we ensure no user-specific identifiers can be used for ad targeting — a key safeguard for child-directed apps.
04
Third-Party SDKs & Families Policy Compliance
The App uses the following third-party SDKs, selected to ensure compliance with Google Play's Families Policy and applicable regulations:
SDK Name
Purpose
Families Policy
Privacy Policy
Google Mobile Ads (AdMob)
Serves contextual, non-personalized ads. Configured as child-directed; AAID use is disabled.
ℹ️Disclaimer: TORTUGA APPS (SMC-PRIVATE) LIMITED does not control these SDKs individually. Each SDK is governed by its own privacy policy. We have configured these SDKs to comply with child privacy laws, but we are not responsible for their direct data collection and use.
05
Children's Privacy
This App is intended for children under the age of 13. We are fully committed to complying with COPPA, GDPR-K, and the Google Play Families Policy.
🚫
No Personal Data Collection
We do not knowingly collect, store, or transmit any personally identifiable information from children. By removing the AD_ID permission, we prevent the collection of the Android Advertising ID, ensuring no user-specific identifiers are used for ad targeting.
📢
Advertising
All ads served through Google AdMob are contextual and non-personalized. We ensure all ad requests are tagged as "child-directed," which disables interest-based advertising and remarketing for all users.
📊
Analytics
Firebase Analytics is configured to collect only anonymized data in a manner compliant with COPPA and GDPR. It does not collect any personally identifiable information from children.
06
Changes to This Privacy Policy
We may update this policy to reflect changes in legal requirements or app functionality. When we do, the "Effective Date" at the top of this page will be updated.
🔔We recommend reviewing this policy periodically for any updates.
07
Contact Us
For any questions about this Privacy Policy or our data practices, please contact us: