Privacy Policy

Effective Date: April 30, 2026

NubiKids (“the App”) is an educational application for children developed and operated by Funcode SRL, a company registered in Romania (“we”, “us”, “our”). We are committed to protecting the privacy of children and their parents. This Privacy Policy explains how we collect, use, and safeguard information in compliance with the Children’s Online Privacy Protection Act (COPPA), the General Data Protection Regulation (GDPR), and other applicable privacy laws.

1. Operator Information

• Operator: Funcode SRL
• Location: Romania, European Union
• Contact Email: admin@funcode.ro

2. Information We Collect

2.1 Information Provided by Parents

• Parent Account Information — collected via Google Sign-In: email address, display name, and (if the parent’s Google account has one) profile picture. These details are made available to the App through Google Sign-In and Firebase Authentication so that you can sign in and so the App can display your account. We use the email address as your account identifier, and we do not separately copy your display name or profile picture into our application database (Firestore).
• Child Profile Information — entered by the parent when creating a child profile: first name (or nickname), age range (6–8 or 9–12), gender, an avatar picked from a fixed set of cartoon characters bundled with the App, and reading level. Used only to personalize the learning experience. The App does not allow uploading photos of children; only one of the App’s bundled cartoon avatars can be selected.
• Earned Badges — record of badges the child has earned through learning activities, used to display progress and motivate continued learning.

2.2 Information Generated Through App Usage

• Learning Progress Data — records of completed puzzles, reading exercises, vocabulary activities, math exercises, best times, and completion counts. Stored to track educational progress and provide a personalized learning experience.
• Learning Streak Data — daily activity records used to motivate consistent learning.
• App Preferences — language settings, theme preferences, sound/notification toggles. Stored locally on the device.

2.3 Information Collected With Parental Consent

• Analytics Data (Optional) — if a parent opts in during the consent flow, we collect anonymous usage analytics via Firebase Analytics to improve the App. This is disabled by default and requires explicit parental opt-in. Analytics data includes device type, operating system version, screen views, and anonymous interaction events. No personally identifiable information is included in analytics.

2.4 Automatically Collected Technical Data

• Crash Reports — we use Firebase Crashlytics to collect anonymous crash reports (stack traces, device model, OS version). This data contains no personally identifiable information and is collected under legitimate interest to maintain App stability and fix bugs. Parents may disable this via device settings.

2.5 Information We Do NOT Collect

• We do not collect photos or videos of children. The App does not provide any way to upload images from the device gallery; child profile pictures can only be picked from a fixed set of cartoon avatars bundled with the App.
• We do not upload audio recordings to our own servers. Some App features use speech recognition for pronunciation practice. Where an offline, on-device model is available (Vosk, currently for English, German, French, Spanish, Italian and Dutch), audio is processed entirely on the device and never leaves it. For languages without an offline model (currently Greek and Romanian), the App falls back to the Android speech recognition service provided by Google, in which case audio may be sent to Google for processing under Google’s Privacy Policy. We do not store recordings ourselves in either case.
• We do not collect precise geolocation from children.
• We do not use advertising identifiers or serve any advertisements.
• We do not enable social features, chat, or public profiles.
• We do not collect more information than is reasonably necessary for the child to participate in the educational activities.

3. How We Use Information

• Providing the educational service — personalizing learning content, tracking progress, and maintaining user accounts.
• Improving the App — analyzing anonymous usage patterns (only with parental consent for analytics) and crash reports to fix bugs and enhance features.
• Managing subscriptions — processing subscription purchases through Google Play Billing. Payment information is handled entirely by Google and is never accessible to us.
• Communication — responding to parent inquiries or account-related requests sent to our contact email.

4. Third-Party Services

We use the following third-party services:

• Google Firebase (Authentication, Firestore, Crashlytics, and optionally Analytics) — for user authentication, data storage, crash reporting, and analytics. Firebase Privacy Policy
• Google Play Billing — for processing subscription payments. Payment details are managed entirely by Google. Google Privacy Policy

We do not share children’s personal information with any third party for marketing, advertising, or any purpose unrelated to the App’s educational service.

5. Data Storage and Security

• Account information, child profile records, and learning progress are stored on Firebase servers (Authentication and Firestore) located in the European Union or the United States, protected by Google’s security infrastructure.
• To support offline use and reduce data usage, learning progress (puzzles, vocabulary, reading, math, learning streak, and pending sync operations) is also cached locally on the device in the App’s private application database. The local progress cache is automatically cleared on sign-out and on account deletion.
• All data is transmitted using TLS/SSL encryption.
• App preferences (language, theme, sound) are stored locally on the device.
• We implement reasonable security measures to protect personal information from unauthorized access, alteration, or destruction.

6. Parental Consent

Before a child can use NubiKids, we require verifiable parental consent. During the consent flow:

• The parent must confirm they are the parent or legal guardian of the child.
• The parent must attest they are at least 18 years old.
• The parent may optionally opt in to analytics data collection (disabled by default).

Consent records (timestamp, method, and choices) are stored securely in association with the parent’s account.

7. Parental Rights

Parents have the following rights regarding their child’s data:

• Review — Parents can view their child’s learning progress and profile information within the App at any time.
• Delete — Parents can delete all data associated with their account (including all child profiles and progress) using the “Delete Account” option in the App’s Settings. This permanently removes all data from our servers.
• Withdraw Consent — Parents can disable analytics collection at any time via the Settings screen. Parents can also delete their account entirely to withdraw all consent.
• Refuse Further Collection — Parents may request that we stop collecting data from their child by contacting us at admin@funcode.ro or by deleting their account in the App.

To exercise any of these rights, parents may use the in-app controls or contact us at admin@funcode.ro. We will respond to verified requests within 30 days.

8. Data Retention

• Account data and learning progress are retained for as long as the account is active.
• When an account is deleted, all associated data (user profile, child profiles, learning progress, consent records) is permanently removed from our servers.
• Anonymous crash reports are retained for up to 90 days.
• Anonymous analytics data (if opted in) is retained according to Firebase Analytics’ default retention policy.

9. Children’s Privacy (COPPA Compliance)

• NubiKids is designed for children aged 6 to 12, used under parental supervision.
• We obtain verifiable parental consent before collecting any information.
• We collect only the minimum information necessary for the educational service.
• We do not condition a child’s participation on disclosing more information than is reasonably necessary.
• We do not serve behavioral advertising or share children’s data with advertisers.
• Parents can review, delete, or refuse further collection at any time.

10. GDPR Rights (European Users)

In addition to the parental rights above, EU users have the following rights under GDPR:

• Right of access to personal data
• Right to rectification of inaccurate data
• Right to erasure (“right to be forgotten”)
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to lodge a complaint with a supervisory authority

To exercise these rights, contact us at admin@funcode.ro.

11. Voice Content Disclaimer

Voice content and pronunciations in the App are generated using AI or Text-to-Speech (TTS) technology for educational purposes. These do not represent human speakers and may occasionally contain inaccuracies.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the App and will require renewed parental consent where applicable. The “Effective Date” at the top will be updated accordingly.