Privacy Policy

Parlini Land

Privacy Policy

Effective date: August 2026

1. Introduction

Parlini Land is an educational app for children aged 3–6, providing a library of language-learning games across 11 languages. It is operated by Venturevate Limited, a company registered in Malta (registration number C 74415), with registered office at No. 8, Regent House, Office 25, Bisazza Street, Sliema, Malta (“Parlini Land”, “we”, “us”, or “our”).

We take your privacy and the privacy of your child seriously. This Privacy Policy explains what information we collect, why we collect it, how we use it, and your rights under applicable law — including the EU General Data Protection Regulation (GDPR).

By creating an account and using Parlini Land, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the app.

This Privacy Policy applies to the Parlini Land mobile app and any related services. It does not apply to third-party services linked from the app.

2. Information We Collect

2.1 Account Information (Parent)

When you create an account, we collect:

  • Email address
  • Authentication method (email/password, Sign in with Apple, or Sign in with Google)
  • Firebase user ID and Parlini Land internal account ID
  • Email verification status
  • Account creation date, last login, and last activity timestamps
  • App version, platform (iOS or Android), and device country/region
  • Marketing opt-in status and the date and method of consent
  • If you sign in via Google or Apple: the display name or profile photo URL returned by that provider (we will remove these fields from the app build if they are not needed)

These are used to authenticate your account, keep it secure, sync your child profiles across devices, restore access, and provide account support.

2.2 Child Profile Information

A parent may create one or more child profiles within their account. We collect:

  • Child’s first name or nickname
  • Avatar selection
  • Age
  • Birth month and birth year
  • Preferred interface language and learning languages
  • Profile progress and settings

Birth month and birth year are used to automatically update the child’s age group year on year, so the app can filter and surface games appropriate for their age. This data is held on the parent’s account and is not shared with third parties for any advertising or profiling purpose.

Children are never asked to create their own account or to provide contact information directly. All child profiles are created and managed by the parent.

2.3 Guest Account (Pre-Registration)

Before you register, the app may automatically create a temporary Firebase guest identifier. This identifier may be used to:

  • Associate a purchase with your device before you sign in
  • Maintain subscription entitlement during the registration flow
  • Link a guest session to your full account when you register or log in
  • Prevent duplicate purchase claims or fraud

This identifier is a pseudonymous device-level ID. It is not truly anonymous if it is linked to a purchase or later merged into a registered account.

2.4 Purchase and Subscription Information

When you purchase a subscription, we receive from Apple or Google:

  • Product purchased (e.g. monthly, annual or lifetime subscription)
  • Store used (Apple App Store or Google Play)
  • Transaction ID or original transaction ID
  • Purchase token and receipt-verification data
  • Subscription status and expiry date
  • Account entitlement status (whether you currently have premium access)

Parlini Land does not receive or store your payment card, bank account, or billing address details. Payments are handled entirely by Apple or Google.

Purchase records are used to verify your payment, prevent fraud, restore purchases after reinstalling, and provide premium access to content.

2.5 Analytics and Technical Data

We use Firebase Analytics and AppsFlyer to understand how the app is used and to improve it. These services may process:

  • App launches and session information
  • Screens, features, or games opened
  • Taps and in-app interactions
  • Subscription or conversion events
  • App version, operating system, and general device information
  • Firebase Installation ID or AppsFlyer ID (pseudonymous device identifiers)
  • Installation source and campaign attribution information
  • Country or region (derived from the device or app store, not GPS)
  • Technical event timestamps

These identifiers are pseudonymous — they identify a device or install instance rather than a named individual. We configure both services with child-privacy safeguards:

    • No personalised advertising or remarketing
    • No advertising identifiers (IDFA or GAID) collected
    • No sharing of analytics data with ad networks
    • Analytics events are not linked to parent email addresses, child names, or birth information
    • Restricted partner data sharing

Despite these safeguards, we describe these identifiers as pseudonymous rather than anonymous because a device ID, in combination with other data, could theoretically be used to identify a person.

3. How We Use Your Information and Our Legal Bases

Purpose

GDPR legal basis

Creating accounts and authenticating users

Performance of a contract (Article 6(1)(b))

Providing, syncing and restoring subscriptions

Performance of a contract (Article 6(1)(b))

Personalising educational content by age group

Performance of a contract (Article 6(1)(b))

Automatically updating the child’s age group using birth month and year

Performance of a contract (Article 6(1)(b))

Security, fraud prevention and abuse detection

Legitimate interests (Article 6(1)(f))

App performance and product analytics

Legitimate interests (Article 6(1)(f))

Sending marketing emails (only if you opt in)

Consent (Article 6(1)(a))

Retaining records required by law

Legal obligation (Article 6(1)(c))

Marketing emails are optional. You must actively opt in to receive them, and you can withdraw your consent at any time free of charge by clicking “Unsubscribe” in any email or by contacting us at [email protected]. Withdrawal does not affect the lawfulness of processing before withdrawal.

4. Children’s Privacy

Parlini Land is designed for children aged 3–6 but accounts are created and controlled by parents or guardians. We do not knowingly collect any of the following directly from a child:

  • Email address or other contact information
  • Phone number
  • Precise location
  • Photographs or videos
  • Voice recordings
  • Contacts or social connections

A parent may provide a child’s first name or nickname, avatar, age, birth month, and birth year as part of setting up a child profile. This data is attached to the parent’s account, managed by the parent, and used only to provide and personalise the educational experience. It is not used for behavioural advertising or profiling.

We comply with GDPR requirements for child data, Google Play Families Policy, and COPPA principles (even though Venturevate Limited is not a US company). If we become aware that a child has independently created an account or submitted personal data without parental involvement, we will delete that data promptly.

Parents can access, correct, or delete their child’s profile at any time through the app or by contacting us.

5. How We Share Information

We do not sell personal information. We share data only as described below.

5.1 Service Providers (Processors)

We use the following third-party service providers who process data on our behalf under appropriate data processing agreements:

Provider

What data

Why

Google Firebase

Account data, device IDs, analytics events, child profile data

Authentication, database, cloud functions, analytics

AppsFlyer

Device ID, install data, country, attribution events

Install attribution, fraud prevention, analytics

Apple

Authentication token, purchase and transaction data

Sign in with Apple, App Store purchases

Google

Authentication token, purchase and transaction data

Sign in with Google, Google Play purchases

5.2 International Transfers

Google Firebase and AppsFlyer are US-based services. Data transferred to these providers outside the European Economic Area is protected by Standard Contractual Clauses (SCCs) approved by the European Commission, or by applicable adequacy decisions. You can request details of the applicable safeguards by contacting us.

5.3 Legal Requirements

We may disclose information if required by law, court order, or to protect the rights, property, or safety of Venturevate, our users, or others.

5.4 Business Transfers

If Venturevate Limited is involved in a merger, acquisition, or sale of assets, personal data may be transferred as part of that transaction, subject to confidentiality obligations and applicable law.

6. Data Retention

Data category

Retention period

Account and child profile data

Retained while the account is active. Deleted within 30 days of an account-deletion request.

Deleted-account data

Promptly deleted from active systems. May remain in encrypted backups for up to 30 days, after which it is overwritten.

Analytics data (Firebase)

Up to 14 months (Firebase default). Adjusted in project settings where required.

Analytics data (AppsFlyer)

Up to 24 months per AppsFlyer’s default; may be reduced in dashboard settings.

Marketing consent records

Retained for 5 years from the date of consent or withdrawal, to demonstrate compliance.

Purchase and subscription records

Retained for 7 years to satisfy accounting and tax obligations.

Security and fraud logs

Up to 12 months.

Customer support communications

Up to 3 years from last contact.

7. Your Rights Under GDPR

If you are located in the EEA, UK, or a jurisdiction with equivalent data protection law, you have the following rights:

  • Right of access — to obtain a copy of the personal data we hold about you
  • Right to rectification — to correct inaccurate or incomplete data
  • Right to erasure — to request deletion of your data (subject to legal retention obligations)
  • Right to restriction — to restrict processing in certain circumstances
  • Right to data portability — to receive your data in a structured, machine-readable format
  • Right to object — to object to processing based on legitimate interests
  • Right to withdraw consent — to withdraw marketing consent at any time, without affecting prior lawful processing
  • Right to lodge a complaint — with the Maltese Information and Data Protection Commissioner (idpc.org.mt) or the supervisory authority in your country of residence

To exercise any of these rights, contact us at [email protected]. We may ask you to verify your identity before processing your request. We will respond within 30 days.

8. Account and Data Deletion

You can delete your account directly within the Parlini Land app:

  • Go to Settings →Parents Area → Account → Delete Account

If you no longer have access to the app, you can request deletion by emailing [email protected] with the subject line “Account Deletion Request.”

Upon deletion:

  • Your account, parent profile, and all child profiles are deleted from active systems within 30 days
  • Your email address, child names, birth month/year, and profile data are removed
  • Pseudonymous analytics identifiers may be anonymised rather than deleted, where this is technically required for aggregate product reporting
  • Purchase records may be retained for up to 7 years for accounting and legal compliance purposes

Deleting your Parlini Land account does not automatically cancel your Apple or Google subscription. You must cancel separately through the App Store or Google Play to avoid further charges.

How to cancel:

  • Apple: Settings → your name → Subscriptions → Parlini Land → Cancel
  • Google Play: Play Store → Subscriptions → Parlini Land → Cancel

9. Security

We implement appropriate technical and organisational measures to protect your personal data, including encrypted transmission (TLS), access controls, and secure credential storage. No internet transmission is completely secure. If you become aware of any security concern relating to your account, please contact us immediately at [email protected].

10. Marketing Communications

We will only send you promotional emails if you explicitly opt in during registration or within the app. Each marketing email contains an unsubscribe link. You may also withdraw consent at any time by emailing [email protected].

We do not send marketing to children. Marketing is directed only to the parent account holder who has opted in.

11. Advertising

Parlini Land does not display advertising within the app. We do not use data collected from children for any advertising purpose. We do not share personal data from the app with advertising networks.

12. Changes to This Policy

We may update this Privacy Policy from time to time. If we make a material change, we will notify you by email (if you have an account) or by a prominent notice within the app before the change takes effect. The effective date at the top of this document will always reflect the most recent version.

Continued use of the app after notification of a material change constitutes acceptance of the updated policy. If you do not agree, you should delete your account before the change takes effect.

13. Contact Us

For any questions, requests, or concerns about this Privacy Policy or how we handle your data:

Venturevate Limited

No. 8, Regent House, Office 25, Bisazza Street, Sliema, Malta

Company registration number: C 74415

Email: [email protected]

If you have appointed a Data Protection Officer, their contact details should be added here.