Privacy Policy

Last updated: 30 April 2026

We take privacy seriously — especially children’s privacy. This Privacy Policy explains, in plain language, what information we collect when you and your child use FoxieLearn, why we collect it, and what your rights are.

The Service is operated by Byte Spiral Single Member PC (“we”, “us”, “our”), a company registered in Greece at Monumental Plaza, Building C, Leof. Kifisias 44, Marousi 151 25, Greece. We are the data controller for the personal information described below.

1. Who This Applies To

FoxieLearn is designed for children, but accounts are created and managed by parents or legal guardians. Children do not directly provide us with personal information — parents do, on their behalf.

This policy applies to the FoxieLearn mobile app on iOS and Android, and to any related online services.

2. The Data We Collect

We collect the minimum we need to run the Service. FoxieLearn does not ask for a username, email address, or password — sign-in is handled automatically by Google Play Games Services (Android) or Game Center (iOS).

Provided by the parent

• The child’s first name (no last name) — used to greet the child in the app.
• The child’s age or age range — used to show age-appropriate content.

Received from the platform sign-in

• A platform-issued player ID from Google Play Games Services or Game Center. We use this opaque identifier to save the child’s progress on their device. We do not receive the parent’s or child’s real name, email, or password from the platform.

Collected automatically

• Anonymous usage analytics — for example, which games are played, levels completed, time spent. This data is not tied to a real-world identity.
• Crash and error reports — technical information about problems so we can fix bugs.

What we do not collect

• We do not ask for or store usernames, email addresses, or passwords.
• We do not collect last names, addresses, phone numbers, or photos of children.
• We do not collect precise location data.
• We do not display third-party advertising and we do not use advertising trackers.
• We do not sell or rent personal information.

Payments

If you make a purchase or subscribe, payment is handled entirely by Apple App Store or Google Play Store. They send us a transaction confirmation, but we never see or store your card details.

3. Why We Use This Data (Legal Bases under GDPR)

Purpose	Data	Legal basis
Provide the Service (greet the child, show age-appropriate games, save progress)	First name, age range, platform player ID	Performance of a contract / parental consent
Improve the Service (which features work best)	Anonymous usage analytics	Legitimate interests / consent where required
Fix bugs and keep the app secure	Crash reports	Legitimate interests
Process subscriptions and purchases	Transaction confirmations from Apple/Google	Performance of a contract
Comply with legal obligations	All of the above, as needed	Legal obligation

4. Children’s Privacy (COPPA + GDPR-K)

We comply with the U.S. Children’s Online Privacy Protection Act (COPPA) and the EU GDPR rules for children.

• A parent or legal guardian must create the account and provide verifiable consent before any data about a child is collected.
• The data we collect about children (first name + age range) is the minimum needed to personalise the learning experience.
• We do not show behavioural advertising to children. We do not allow third-party trackers in the kids’ experience.
• A parent can review, change, or delete their child’s data at any time (see Section 8).

If you believe a child has provided us with information without parental consent, please contact us at info@bytespiral.com and we will delete it.

5. Who We Share Data With

We share data only with the small number of service providers we need to run the app:

• Apple and Google — for app distribution, sign-in, and payments.
• Unity Cloud — for parts of the app’s infrastructure (game delivery, asset hosting, anonymous diagnostics).

These providers act as our data processors. They are bound by contracts that require them to protect your data and only use it for us. We do not sell personal information and we do not share it with advertisers.

We may disclose data if required by law (for example, in response to a valid court order), or to protect the rights, safety, or property of FoxieLearn, our users, or the public.

6. Where Data Is Stored and International Transfers

Data may be stored or processed in the European Union and in countries where our service providers operate (including the United States). When data leaves the EU/EEA, we rely on safeguards approved under GDPR — typically the European Commission’s Standard Contractual Clauses — to protect it.

7. How Long We Keep Data

• Account data (child’s first name, age range, and platform player ID) — kept while the account is active.
• After account deletion — all personal data is deleted within 30 days, except data we must keep for legal reasons (such as transaction records for tax purposes, normally up to 10 years under Greek law).
• Anonymous analytics — kept in aggregated form indefinitely, because it can no longer be linked to an individual.
• Crash reports — kept for up to 90 days.

8. Your Rights

Depending on where you live, you may have some or all of the following rights:

• Access — get a copy of the data we hold about your child or you.
• Correction — fix anything that is wrong.
• Deletion — ask us to erase the data (“right to be forgotten”).
• Restriction — ask us to pause processing while you check something.
• Portability — receive your data in a portable format.
• Objection — object to processing based on legitimate interests.
• Withdraw consent — at any time, without affecting prior lawful processing.
• Lodge a complaint — with your local data-protection authority. In Greece, this is the Hellenic Data Protection Authority.

California residents (CCPA / CPRA): You also have the right to know what categories of personal information we collect, to request deletion, to correct inaccurate information, and to not be discriminated against for exercising your rights. We do not sell or share personal information for cross-context behavioural advertising.

To exercise any of these rights, email us at info@bytespiral.com. We will respond within the timeframe required by law (typically 30 days).

9. Security

We use industry-standard technical and organisational measures to protect your data — including encryption in transit (HTTPS/TLS), access controls, and regular security reviews. No system is perfect, but we work hard to keep data safe and we will notify you and the relevant authorities if a breach affects your personal data.

10. Cookies and Similar Technologies

The FoxieLearn mobile app does not use cookies. The companion website may use a small number of strictly necessary cookies for things like remembering your language preference. We do not use advertising cookies on pages directed at children.

11. Changes to This Policy

We may update this Privacy Policy as the Service evolves. If we make material changes, we will notify you in the app or by email at least 14 days before they take effect. The “Last updated” date at the top always shows the current version.

12. Contact Us

For privacy questions, requests, or complaints:

Byte Spiral Single Member PC Monumental Plaza, Building C Leof. Kifisias 44 Marousi 151 25, Greece Email: info@bytespiral.com