Privacy policy

Lulla Kids, the Android app, and the Lulla Kids section of the getlulla.app website (getlulla.app/kids) are published by Lulla App, based in Romania, which also publishes Lulla, the baby sleep app. For the little data we process, described below, the data controller (“we”) is:

• Controller: Lulla App, Romania
• Email: contact@getlulla.app

We have not appointed a data protection officer (DPO). For any question about your data or your child's, write to us directly at the address above.

This policy applies to the Lulla Kids app on Google Play (package com.toddlerdreams.lullakids) and to the Lulla Kids section of getlulla.app (getlulla.app/kids, “the site”). The Lulla app has its own privacy policy, published on getlulla.app.

Lulla Kids is designed to work without sending us data: without an account or a purchase, the app sends us nothing, and the games work offline. The app has no ads, uses no usage-analytics, crash-reporting or tracking tools and does not use the advertising ID; the only statistics come from the purchase records RevenueCat keeps on a phone on which Premium was bought or restored (see Payments). We do not sell personal data or give it to anyone for advertising.

Only two things, both optional, send data off the phone: the parent account, if you choose to create one (see The parent account), and the record of a Premium purchase, only on a phone on which Premium was bought or restored (see Payments).

You are not required by law or by contract to give us personal data. The account is optional, and the app works the same without it. The app asks you for a name, so that the friends can greet your child, but it can be a nickname.

To prepare the right games, the app keeps two separate files on the phone, in its own storage:

• your child's profile, which you fill in at first launch: the first name, what your child loves, your goals and the chosen friend. If you interrupt the first-launch set-up, the answers given so far are also kept here, so that you can continue;
• progress and settings: your child's age, the daily limit and time played, the answers to the two optional questions (“Gets scared by loud sounds?” and “Plays in the evening too?”), your notification choices, completed lessons, stars, the friends album, progress in each skill, the language and the app's other settings, whether you have Premium and, if you started a free trial in the app, the date on which it ends. Your child's name does not appear here.

The app uses this data on the phone: it picks the first games based on your goals, puts the favourite worlds first on the screen, matches the difficulty to the age and keeps to the daily limit. If you answered “yes” to the optional questions, it plays sudden sounds more softly or, from 7 pm, shows bedtime games first. The narrator may say your child's first name (see The narrator's voice).

Legal basis: the legitimate interest, yours and ours, in the app suiting your child's age and preferences (Article 6(1)(f) GDPR). We have taken into account that a child is involved: there is little data, without an account we do not receive it, and you can change or delete it at any time.

Without an account, this data does not reach us: the app does not send the profile off the phone, and progress and settings can only end up in the Android backup in your Google account, if backup is turned on (see Android backup). If you create an account, a copy is also kept in it (see The parent account). You control the data on the phone directly:

• in the grown-ups' area you change the age, the daily limit and the other settings, and you can edit the profile or delete it, after a confirmation: the first name, what your child loves, the goals and the chosen friend are deleted, while progress and settings remain (if you are signed in, the deletion also reaches the account's copy at the next save);
• if you clear the app's data in the Android settings or uninstall the app, all its data is deleted from the phone; the account's copy, if you have one, stays until you delete the account.

The account is optional: every game works without it. You, the parent, create it at the end of the first-launch set-up or in the grown-ups' area, with an email address and a password or with your Google account. You use it to bring the progress, settings and your child's plan to another phone or after a reinstall, and to have them on both parents' phones.

What we keep in the account:

• your email address and password. The password is handled by Supabase Auth and kept only in encrypted form (a hash): no one, including us, can read it;
• if you sign in with Google: after you pick the account in Google's window, Google gives us the email address, name, profile picture (a link) and your Google account's identifier. We use them only to recognise you when you sign in;
• an account identifier, generated at random;
• your choice about emails with ideas, news and offers, when you made it and the account's language;
• a copy of the app's data: progress (lessons, stars, friends, progress in each skill), settings (including your child's age and the daily limit) and the plan (your child's first name, if you typed one, what your child loves, your goals, the daily time, the chosen friend);
• for each phone connected to the account, a code generated at random by the app and the app's version, so that saves from different phones do not overwrite each other, plus the time of each save.

Not in the account: Premium (it belongs to your Google Play account), the notification permission and history, the app's language and today's play time.

Where. The account and its copy are kept by Supabase (Supabase, Inc.), on servers in the European Union (Frankfurt, Germany). Supabase processes them only on our behalf, as a processor, under its data processing agreement. Each account sees only its own data. On the phone, the app keeps the account's session, so that you do not have to sign in at every launch; the session is excluded from Android backup and from the transfer to a new phone. Google processes your Google account's data under the Google Privacy Policy.

Why and on what legal basis. To provide the account you asked for: signing in, keeping the copy and bringing it back on another phone (performance of a contract, Article 6(1)(b) GDPR). Your child's data in the copy is entered by you, the parent, and we use it only for this service. We send you emails with ideas, news and offers only if you ticked the box, which is not ticked by default (consent, Article 6(1)(a) GDPR). You can withdraw your consent at any time, through the unsubscribe link in any such email or by writing to us; withdrawing does not affect the emails sent before. Without separate consent, we write to you only about the account (for example to confirm the address or change the password).

Signing out and deletion. “Sign out” leaves everything on the phone and does not delete the account. “Delete account” (For grown-ups › Your account › Delete account) immediately deletes the account, its copy and your choice about emails. You can also ask for deletion without the app: see Deleting the account.

Many Android phones automatically back up apps to the user's Google account. For Lulla Kids:

• your child's profile (first name, what your child loves, your goals, the chosen friend) is excluded from Android cloud backup and from device-to-device transfer, so it reaches neither your Google account nor a new phone;
• progress and settings, which do not contain your child's name but do contain their age and the daily limit, may be included in Android's automatic backup, if backup is turned on on the phone, and in the data transfer when you move to a new phone. The cloud copy is kept by Google, in your Google account, under the Google Privacy Policy. We have no access to it.

You turn backup on or off in the Android settings, and you manage existing backups from your Google account.

The instructions in the games are read aloud by the phone's text-to-speech engine, the one chosen in the Android settings. The engine is a separate component of the phone, provided by Google, by the phone's manufacturer or by another provider, and it works under that provider's rules.

The app gives the engine the text to read. If the voice chosen on the phone uses the internet, the engine may send this text to its provider. When the default voice needs the internet, the app picks a voice installed on the phone, in the same language, if there is one.

The app gives your child's first name only to a voice that, as the engine declares, works on the phone, without the internet. If the active voice needs the internet, the app says a general phrase instead of the first name, so it does not give the first name to a voice that uses the internet. What the voice engine does with the text it receives is a matter for its provider.

Lulla Kids can send notifications only to the parent and only if you turn them on; until then, they are off. On Android 13 or newer, Android asks you for permission only when you choose to turn them on: at the end of the first-launch set-up, on the Premium offer screen (for the free trial reminder) or in the grown-ups' area. In the grown-ups' area you turn them on or off with a single switch, and Android also lets you turn them off in the phone's settings.

There are three kinds of notification:

• an idea for carrying the day's play on at home, after play;
• a summary of the week's play, on Sundays;
• a reminder before the free trial of a subscription started in the app ends. After the 7 free days, the subscription costs 25.99 lei per month and renews automatically until you cancel it in Google Play. The final price is the one Google Play shows in your currency.

Notifications are scheduled locally, with Android alarms, without any server of ours and without a push notification service. None of them is addressed to the child, and the child's name does not appear on the lock screen.

Lulla Kids uses only these Android system permissions:

In addition, an Android library (AndroidX) automatically adds an internal permission of the app (DYNAMIC_RECEIVER_NOT_EXPORTED_PERMISSION). It belongs to the app itself and gives access to nothing outside it.

The app does not ask for access to the camera, microphone, location, contacts, photos or files. It does not use the advertising ID: its permission (AD_ID) and Android's advertising interfaces are explicitly removed from the app, and the Google library that could read it is not included.

18 games are free forever. Premium is bought through Google Play, as a monthly subscription or as a one-time lifetime payment; prices and conditions are in the Terms. Google Play decides, based on your Google account's history, whether you are a new subscriber who can get the first 7 days free; after them, the subscription costs 25.99 lei a month and renews automatically until you cancel it in Google Play. The final price is the one Google Play shows, in your currency.

Payment is processed by Google, as an independent data controller, under the Google Privacy Policy and the Google Play terms. Card or other payment details are seen only by Google: neither the app nor we see them.

To know whether you have Premium, at every launch the app asks the Google Play app on the phone which purchases the Google account has. The Google Play Billing library in the app may also talk to Google's servers, under Google's rules. Premium does not go through your Lulla Kids account and is never restored from it: Google Play always confirms it.

Purchase records: RevenueCat

To know how many subscriptions, free trials, renewals and cancellations we have, we use RevenueCat (RevenueCat, Inc., US) as a processor, on our behalf. RevenueCat does not process payments and unlocks nothing: it only records the purchases Google Play has already made.

RevenueCat is turned on only on a phone on which Premium was bought or restored; on a phone without purchases, the app never contacts it. Once on, the app sends it, at the purchase and then at every launch: the product bought, its price and currency, the Google Play purchase code, a customer code (random or, if you are signed in, your Lulla Kids account's identifier), the phone model, the Android and app versions, the language and the Google Play store country; as with any connection, RevenueCat also sees the IP address. It does not receive the advertising ID, your name or email, or any data about your child. When no Lulla Kids account is signed in, RevenueCat may also keep its random customer code in Block Store, a Google Play service, which can be backed up to your Google account, so that the purchase is recognised after a reinstall or on a new phone; nothing else is kept there.

Legal basis: our legitimate interest in keeping accurate records of subscriptions and revenue (Article 6(1)(f) GDPR) and our accounting obligations (Article 6(1)(c) GDPR). On the transfer to the US, see Transfers outside the EU.

In the grown-ups' area, “Manage subscription” opens the subscriptions page in Google Play, and “Restore purchases” checks again, also through Google Play, which purchases the account has.

As the app's developer, we receive from Google, in Google Play Console, order information: the order number, the product, the date, the price, taxes and the order status (for example, whether it was refunded), plus sales reports that show, for each order, the buyer's country and phone model and, for some countries, the region, city and postcode. We do not receive card details. If you write to us about an order, we can look it up by its number or by the Google account email address you give us, in order to help you, for example with a refund.

We use this information for accounting and tax obligations (Article 6(1)(c) GDPR, legal obligation) and to answer your requests about purchases (Article 6(1)(f) GDPR, legitimate interests). For accounting purposes, order information may be passed to our accountant, who processes it on our behalf, and, where the law requires, to the tax authorities.

Google Play also shows us aggregate statistics, for example the number of installs per country, and technical reports about app crashes (for example, the phone model and Android version), which Google receives from users who have agreed to send it diagnostic data. Reviews on Google Play are public, under Google's rules, and we may reply to them there. We use the error reports to fix the app, and we reply to reviews to help users (legitimate interests, Article 6(1)(f) GDPR).

Lulla Kids is made for children aged 1–6 (children aged 1–2 play alongside a parent), but it is set up and controlled by the parent: you answer the first-launch questions, and the grown-ups' area is protected by a question for adults (a multiplication). Notifications are for you only.

Your child has no account and sends us nothing. The app has no ads, no chat or other feature through which a child could publish anything, and it uses no advertising, usage-analytics or tracking libraries: the only statistics are the subscription counts from RevenueCat, on a phone on which a parent bought Premium, and they contain no data about your child. Data about your child (the first name, if you typed one, age, what they love, progress) reaches us only if you, the parent, create the optional account: it is then part of your account's copy, and we use it only to bring it to your other phone. The account is for adults: before signing in with Google, the app asks for the year of birth, and an answer under 18 blocks, on that phone and for one day, both Google sign-in and a new account.

In the European Union. Article 8 GDPR requires a parent's consent when an online service processes, on the basis of consent, the data of a child below the age set by each country (16 in Romania). Lulla Kids does not rely on the child's consent: the profile on the phone is based on the legitimate interest described under What stays on the phone, and the account's copy on the contract with you, the parent who creates the account and enters the data. You can see and change it at any time in the app, and it is deleted with the account.

In the United States. We do not knowingly collect personal information directly from children under 13, within the meaning of the Children's Online Privacy Protection Act (COPPA), and a child cannot make information public through the app. The information about a child in the optional account is provided by the parent, who can see and change it at any time in the app, delete it by deleting the account, and stop it being kept further by signing out. We do not disclose it to anyone except the providers that host our service on our behalf.

If you find out that a child has created an account or sent us data, for example by email, write to us at contact@getlulla.app and we will delete it.

Purchases are made through the Google account on the phone. We recommend turning on authentication for every purchase in the Google Play settings, so that a child cannot buy anything alone.

You can delete the account and everything in it at any time:

• in the app: For grown-ups › Your account › Delete account. The deletion is immediate;
• without the app: write to us at contact@getlulla.app, from the account's email address, saying that you want it deleted. We delete it within 30 days at most, usually much sooner, and confirm by email.

Deleted: the account (email, password, the data received from Google), the account's copy (progress, settings, your child's plan), the phones' codes and your choice about emails. Kept: the data on the phone (until you delete it in the app or uninstall it), Google Play orders (Google keeps them, and we keep those required for accounting), the purchase records at RevenueCat (we delete them on request, unless the law requires us to keep them) and emails exchanged with us (at most 2 years). Deleting the account does not cancel the subscription: cancel it in Google Play. The steps, in short, are also on the account deletion page.

The site presents the app. It has no accounts, forms, newsletter or mailing list and does not ask you for personal data. Fonts are served from the same domain, so your browser makes no requests to Google Fonts or other font services.

Visit data is processed only by the company that hosts the site, for hosting and for visit statistics, as described below.

The site links to other websites and pages, for example Google Play, the rest of getlulla.app or the website of the World Health Organization. When you open them, their own privacy policies apply.

The site is hosted by Vercel Inc. (USA). To deliver the pages and protect the site from abuse, Vercel processes the technical data of each request: the IP address, browser and system information (user agent), the page requested and the time. Vercel acts as a processor, on our behalf, under its data processing agreement.

Legal basis: our legitimate interest in having a secure, working website (Article 6(1)(f) GDPR).

We use Vercel Web Analytics, in its cookieless form, to know how many visits the pages get and where visitors come from. For each page visited, the following is recorded: the page, the time, the site you came from (referrer), the approximate location derived from the IP address (country, region, city), the operating system, the browser and the device type.

Visits on the same day are recognised by a temporary code, calculated from the browser's request and automatically deleted after 24 hours. No cookies are used, nothing is saved on your device and there is no tracking from one site to another. We see only aggregate statistics, from which we cannot identify visitors. We do not use any other measurement tools.

Legal basis: our legitimate interest in understanding, in aggregate, which pages are useful (Article 6(1)(f) GDPR).

The Lulla Kids section of getlulla.app (getlulla.app/kids) does not set cookies and does not save anything in your browser (not even in localStorage).

Visit statistics use a Vercel script that, on each page, sends the data described in Visit statistics. The script saves nothing on your device and does not track you on other sites.

The other pages of getlulla.app, about the Lulla app, set one functional cookie, LULLA_LOCALE, which remembers the chosen language, and keep consent and analytics opt-out preferences in your browser's localStorage. Those pages are covered by the getlulla.app privacy policy. Because the cookie is set for the whole getlulla.app domain, a browser that already has it also sends it when you open the Lulla Kids pages; these pages do not read or use it.

If you write to us at contact@getlulla.app, we use your email address and your message to reply to you and, where relevant, to help you with an order. Legal basis: our legitimate interest in replying to messages (Article 6(1)(f) GDPR).

We keep messages for as long as necessary to reply to you and for no more than 2 years, then we delete them. Emails are hosted by our email service provider, which processes them on our behalf, as a processor.

Please do not send us data about your child, such as their name or photos: we do not need it to help you.

Under the GDPR, you have the right:

• to find out what data we hold about you and to receive a copy (right of access);
• to ask for inaccurate data to be corrected (rectification);
• to ask for your data to be deleted (erasure);
• to ask us to use it only in a limited way (restriction of processing);
• to object to processing based on our legitimate interest (objection);
• to receive the data you gave us in an easy-to-use format and to pass it on to someone else (data portability);
• to lodge a complaint with the data protection authority.

Right to object. You can object at any time, on grounds relating to your particular situation, to processing based on legitimate interest: website hosting, visit statistics, replies to emails, requests about purchases, purchase records at RevenueCat, error reports and Google Play reviews. Write to us at contact@getlulla.app. For the data in the app, you exercise this right directly: you delete the profile or the account in the grown-ups' area, or uninstall the app. You can withdraw your consent to news emails at any time, through the unsubscribe link.

You control the data in the app directly. Without an account, we hold nothing of what you entered in Lulla Kids. With an account, data you change in the app is also saved in the account, you delete the account in the grown-ups' area, and you can ask us for a copy of the account's data in an easy-to-use format (JSON). You change the age, the limit and the other settings in the grown-ups' area, where you can also edit or delete the profile, and you delete all the app's data by uninstalling it. For data kept by Google (payments, backup), contact Google, from your Google account.

For the data we do hold (the account and its copy, your emails, the order information received from Google Play and the purchase records from RevenueCat), write to us at contact@getlulla.app. We reply within 30 days at most; if the request is complex, this period may be extended by up to two further months, and we will let you know. Visit statistics are aggregated, so we cannot identify you in them. We do not carry out profiling and do not take automated decisions that have legal effects on you.

If you believe we are infringing your rights, you can lodge a complaint with the Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP) (National Supervisory Authority for Personal Data Processing):
B-dul G-ral Gheorghe Magheru 28-30, sector 1, București, Romania
Tel.: +40.318.059.211 / +40.318.059.212
Email: anspdcp@dataprotection.ro
Web: www.dataprotection.ro

If you live in another EU country, you can also contact the authority in your country. If you live outside the European Union, you can also use the rights your country's data protection law gives you and contact its authority (in the United Kingdom, the Information Commissioner's Office, ico.org.uk). Please write to us first: in most cases we can resolve things quickly.

The account and its copy are kept on Supabase servers in the EU (Frankfurt, Germany). Supabase, Inc. is based in the US: if the data is accessed from outside the European Economic Area, for example for technical support, the European Commission's standard contractual clauses in Supabase's data processing agreement apply.

RevenueCat, Inc. is based in the US and processes the purchase records there. The transfer relies on the European Commission's standard contractual clauses, included in RevenueCat's data processing agreement.

Vercel Inc. is based in the US, so the technical data of visits to the website may also be processed there. The transfer relies on the European Commission's adequacy decision for the EU-U.S. Data Privacy Framework (10 July 2023), under which Vercel is certified.

Your emails are processed by our email service provider. If it processes messages outside the European Economic Area, the transfer takes place only with the safeguards required by the GDPR: an adequacy decision of the European Commission (for example the Data Privacy Framework, for a certified company) or the standard contractual clauses.

You can ask for a copy of the safeguards for these transfers by writing to us at contact@getlulla.app.

Google processes payment data, the backup and, if you sign in with Google, your Google account's data under its own rules, set out in the Google Privacy Policy.

The best protection is not to have the data: without an account or a purchase, the app sends us nothing, and your child's profile (first name, what they love) is not included in Android backup.

For the optional account: all connections are encrypted (HTTPS); Supabase Auth keeps the password only as a hash; each account can read and write only its own data (row-level security rules in the database); the links in the confirmation and password-change emails work only together with a code kept on the phone that asked for them (PKCE); the account's session is not included in Android backup.

Android keeps each app's data separate from other apps. We recommend keeping the screen lock turned on.

The question for adults in front of the grown-ups' area is designed to keep young children away from the settings; it is not a password.

The website is served only over an encrypted connection (HTTPS).

If we change this policy, we will publish the new version here, with the date of the last update. If a future version of the app uses data differently from what is described here, we will first update this policy and the information on Google Play, and only then publish that version of the app.

For any question about this policy or about your data, write to us at contact@getlulla.app. You will find more details on the contact page.

Lulla App, Romania