Kids Privacy Policy

This policy applies to children-directed apps (including apps primarily targeted at users under age 13) published by NAGI STUDIO.

For the data processing described in this policy, NAGI STUDIO acts as the data controller.

1. COPPA Notice (Under 13)

Our apps include services directed at children under 13 and are designed to be anonymous. We do not collect personal information directly from children (such as name, email address, or account credentials).

We do not require children to create accounts or provide personal information directly. Some limited technical information may be automatically processed by our service providers for app functionality, analytics, security, crash diagnostics, and purchase support, and never for advertising or profiling.

2. GDPR Transparency and Legal Basis

We process only the minimum anonymous technical data necessary for app operation and safety, and we do not profile children.

Primary legal bases under GDPR Article 6:

  • Legitimate interests: App stability, security monitoring, fraud prevention
  • Contract necessity: Purchase verification and restoration support
  • Legal obligations: Accounting, tax, and legal compliance where applicable

We adhere to purpose limitation and data minimization principles and do not process data beyond what is necessary.

3. Data We Collect

Data categories processed through our third-party service providers:

  • Anonymous usage analytics (Firebase Analytics): Aggregate statistics such as session counts and feature page views. We do not collect advertising identifiers (such as IDFA) or use data for advertising.
  • Crash reports (Firebase Crashlytics): App crash stack traces and device type information.
  • In-app purchase data (RevenueCat + Apple / Google): IAP identifiers and receipt verification data. Parent/guardian names or card numbers are not stored on our servers.

Data we do not collect: name, email address, phone number, postal address, photos, precise location, advertising IDs, login credentials.

4. How We Use Data

  • Stable app operation and bug fixes
  • Security monitoring and fraud prevention
  • Verifying in-app purchases and supporting purchase restoration
  • Anonymous aggregate analysis for app quality improvement

We do not use data for advertising, behavioral targeting, or profiling of children.

5. Third-Party Sharing

We do not sell or share data with third parties other than the following service providers:

  • Google LLC (Firebase Analytics / Crashlytics)
  • RevenueCat, Inc. (purchase management)
  • Apple Inc. / Google LLC (store payment processing)

These providers process data on our behalf for analytics, crash diagnostics, and purchase verification.

6. Provider Privacy Policies

7. Data Retention

  • Analytics event-level data is retained for up to 14 months.
  • Crash data is retained according to periods defined by the relevant service provider.
  • Aggregated anonymous statistics may be retained longer for long-term product improvement and quality analysis.

8. International Transfers

Due to service provider infrastructure, data may be processed outside the user's country (including the United States). Where required, we rely on Standard Contractual Clauses (SCCs) or other lawful transfer mechanisms.

9. Parental Rights

  • Ask what categories of data are processed
  • Request access or deletion support

Our apps are anonymous-by-design and do not require user accounts, so requests are handled within the limits of anonymous technical and purchase-verification data.

10. Contact

Operator: NAGI STUDIO
Contact: nagilit.dev@gmail.com

Last updated: March 5, 2026