PRIVACY POLICY

Introduction

As UPILY Arastırma ve Teknoloji Gelistirme Anonim Sirketi, developing products and services under the name of Wonjo Kids (We, Wonjo Kids), we are firmly committed to protecting the privacy of our users. We are committed to minimizing the processing of personal data to the greatest extent feasible and refrain from collecting personal information beyond what is essential. Ensuring that you, as a parent and/or legal guardian (hereinafter collectively referred to as "Parent(s)"), have complete trust and confidence in how we manage your personal information across our mobile application ("App"), websites, and any other services, or during your interactions with us (hereinafter collectively referred to as our "Services") is our utmost priority. This Privacy Policy is here to explain how and why we collect personal information, and your rights as it pertains to data collection. You are encouraged to read this Privacy Policy carefully and ask any question that may arise by contacting us from the channels listed in the “Contact Us” section below.

Wonjo Kids App is tailored primarily for young children and their parents. However, please note that our websites, “wonjo.kids”, “wonjokids.com”, “upily.com” (collectively referred to as the "Site" or "Sites"), are designed for use by adults only. This Privacy Policy applies to the sites as well as Wonjo Kids App.

It is essential to underscore that all processing of personal data by Wonjo Kids, including collection, registration, storage, and any form of handling, is conducted in strict compliance with relevant privacy laws. Wonjo Kids is committed to ensuring that the processing of personal data is performed in accordance with established legal standards.

As a service oriented toward children, Wonjo Kids App adheres to the Children's Online Privacy Protection Rule ("COPPA"). Where COPPA is applicable, the terminology used in this privacy policy shall be interpreted as follows: the term "personal data" will include "personally identifiable information, and the term "processor" will encompass "service provider", consistent with the definitions provided under COPPA.

Information We Collect

There are three different types of collection methods that we utilize for user information: direct user provided information collection, automatic collection based on app and website usage and data collection from third party and other sources.

2.1 Information Directly Provided by Users

We may collect your personal information from you directly if you sign up or use our services:

• E-mail address
• Name

Note that the above information only pertains to the data belonging to an adult user (parent) of our services.

Player Information:

In order to create a kid profile in the App and customize the content accordingly, we collect the following information:

• Child’s name or nickname
• Child’s year of birth

This information is used to customize the content for the profile of the kid.

Payment Information:

Accessing premium features of Wonjo Kids requires a subscription payment after trial period. We do not store sensitive payment information on our servers. All payment transactions are processed through Google Play Store, Apple App Store or Paddle, which employ robust security measures to protect data privacy. The information that we receive from respective payment providers include:

• Google or Apple Account Information
• Device Type and Operating System Information
• Payment Status
• Time of payment
• Method of payment

Privacy of your payment information stored in Google Play Store, Apple App Store and Paddle is governed by their respective privacy policies.

Voice, Camera and Gallery Access:

In order to provide the best play experience for kids, some of our games contain access to Microphone, Camera, and Gallery. As per our strict policy on kids' privacy, no data from these leave the user's device, and they are never shared with third parties as well.

• Microphone: is required to allow kids to provide their choices or interact with the games using their own voice. Voice processing is done on the device and the audio is not stored for further use. This data is never used to identify the owner of the voice or any other fingerprinting.
• Camera and Gallery: access is there to provide some interactive features inside the games. We provide a Parent Gate to receive parent consent before enabling these features, and the data received or produced from these never leave the user's device. They are only utilized for the specific games they are to be used in, and never used for any other purpose.

If any of the aforementioned features are disabled for the app in the operating system settings, respective functions or games may not work as intended.

Information shared by you in third party social media platforms:

We have a presence in various social media platforms including but not limited to Facebook, Instagram, YouTube, and LinkedIn. Anything that is posted on these platforms, including our pages, are governed by each platform's respective privacy policies. Any information or post shared on these platforms using public sharing features will be considered “public” unless otherwise required by relevant law and is not subject to privacy protections referenced in this Privacy Policy.

Voluntary Feedback and Research Activities:

In order to provide the best service to our users, we sometimes ask you to provide feedback and/or participate in product surveys. Providing this data is completely optional, and we may collect additional information in these activities.

Your communications with us:

You can always contact us from the contact information provided in the “Contact Us” section of this document. Whenever we receive a support request, your personal information may be collected to provide you the best experience possible.

2.2 Automatically Collected Information

Certain information about you is collected automatically when you access our apps or websites.

When you use the app:

• App session start, stop times and durations
• App screens that you visited
• Contents that you interacted with, your choices, duration of interaction, play patterns, actions
• Badges / Achievements
• Behavior on push notifications
• Device information like model, OS and identifiers
• Non-granular location data
• IP Address
• ISP, Connection Information
• Settings

When you use the website:

• Pages that you visited, content you interacted with
• Device information like model, OS and identifiers
• Location data
• IP Address
• ISP, Connection Information
• Information provided by third party tracking (Will be detailed below)

2.3 Data Collected from Third Parties

In order to provide you with the best service possible, we work with third parties to receive information about you and your interaction on different platforms.

When you login to our app and/or website using third party authentication like Google/Apple login, we collect personal information about you from these platforms. You can control what to share from respective platforms’ privacy settings.

We use Third Party Analytics services on both apps and websites. These are to support our marketing and user acquisition channels. Our paid marketing and social presence on social media are directed at parents and we only use these services to track and understand their behaviors on our websites, apps, third party social networks and platforms. We may also receive data from third parties to better target adult audiences.

Purposes for Processing Your Data

We use and process your data for the following purposes:

3.1 Providing our Services

We collect and use your information such as the following to provide the best service in our apps and websites.

• Managing your login information, providing you with access to your account across different devices such as phones, tablets and web
• Allowing access to different parts of our services
• Processing your purchases using your Apple App Store and Google Play Store accounts
• Creating reports, dashboards and screens to evaluate and provide progress on your child’s progress for you
• Providing customer or technical support
• Contacting you in case of updates on your account, activities, policy changes and required communication
• Authenticating and verifying individuals
• Troubleshooting and fixing any issues that may happen in our services

3.2 Administrative Purposes

We collect and use your information such as the following for administrative purposes:

• Measuring interest, engagement, and quality of our services
• Improving our services with continuous feedback on app usage
• Developing new products and services
• To satisfy our quality and safety requirements
• Marketing similar products or services, requesting feedback
• Fraud prevention, security
• Customization of ads

3.3 Compliance & Legal Obligations

We work with respective legal authorities to comply with law & regulations:

• Auditing transactions, interactions as required
• Enforcing agreements & policies
• Activities to comply with our legal obligations

3.4 Marketing & Advertising

We may use your personal information to provide tailored advertising. This would include custom audience advertising, interest-based, personalized advertising and email marketing. Some of the features listed here might require cross device tracking to enable these scenarios. Our line is clear on children’s data though - we never use personalized or behavioral advertising based on information collected from children or activities designed for children.

Privacy of Children

Keeping children safe is at the core of our business and we strongly believe that children’s privacy deserves special attention. In our apps and services, you as parents are, by design, in control. Our apps require an adult to download them from the app stores, register profiles for their children with the limited information we require to create profiles for kids. Any action that requires adult supervision such as purchase, subscription operations, or creation of new child profiles are always guarded by parent gates inside the apps. On profile creation, child name (or nickname) and year of birth are collected to provide customized app experience and to distinguish between different profiles.

After profile creation, we know that children will be the main users of the app, that’s why any information collected from activities is strictly handled to only be used to improve the services and to provide a better user experience for children. Some of the examples would be:

• Customizing content to children’s age, preferences
• Generate education progress reports for parents and kids
• Analyze usage, determine quality and performance of our content, improve content for better user experience

We do not share, sell, rent or transfer children’s personal information with third parties, except:

• We use cloud providers and third party service providers to store information and run online and analytics services on. They are also contractually obligated to store our data safely and treat it as our confidential information.
• We are bound by laws and regulations to comply with legal requests from authorities.
• Aggregated information - which doesn’t identify any of our users as individuals.

Wonjo Kids app is certified and audited by kidSafe seal program, details of which can be accessed from the following link: Wonjo Kids kidSafe Seal.

You can always contact privacy@wonjo.kids to get additional information on how and why we process data of your children.

How we Disclose Data We Collect

5.1 Suppliers and subcontractors

This category contains companies that only have the right to process the data they receive from us on behalf of Wonjo Kids, i.e. data processors. Examples are cloud providers, data storage providers and business consultants.

Examples of the services we use:

• Google Cloud for storage and services
• Firebase, BigQuery, Amplitude for analytics
• Adjust as attribution provider - Adjust doesn’t collect any Personally Identifiable information from Wonjo Kids App

5.2 Advertising Partners

We reserve the right to potentially disclose your personal data to our third-party advertising partners in accordance with applicable legal frameworks, as applicable. Furthermore, these advertising partners may employ the use of technologies and various tracking tools on our services, which may accumulate information regarding your activities and your device, such as your IP address, cookie identifiers, browsed pages, geographical location, and time of day. This is contingent upon compliance with relevant legal frameworks, where applicable.

Such collected information, along with similar data derived from other services, may be utilized by our advertising partners for the purpose of serving you tailored advertisements upon your visit to digital platforms within their network, pursuant to applicable legal bases. This approach is typically branded as "interest-based advertising" or "personalized advertising".

To emphasize it again, we do not use behavioral advertising based on information collected from children or from child-directed parts of our services.

5.3 Legal Disclosure Requirements

We reserve the right, under certain circumstances, to access, retain, and share any information that we have collected in connection with your account. These circumstances include times where we earnestly believe that such actions are necessary or appropriate in order to: adhere to requests from law enforcement or national security bodies and to abide by legal procedures like subpoenas or court orders; safeguard the rights, property, or safety of yourself, our organization, or other parties; implement our policies or contracts; recover debts payable to us; or to facilitate the investigation or prosecution of potential or verified unlawful activities, all within the bounds of applicable laws.

Retention of Your Data

We are committed to preserving your information for the duration necessary to offer you our services. Beyond this, we may hold your data to meet our own legal requirements, address disagreements, and uphold our contractual obligations. Furthermore, we may retain your information for a period that corresponds to the legal timeframe for potential litigations.

Keeping your Information Safe

We have established relevant safeguards aimed at securing your personal information, avoiding its modification, loss, or unauthorized access or use. Nonetheless, it's important to understand that no website or internet transmission can be entirely immune to security breaches. Despite our rigorous commitment to data safety, we cannot provide an absolute guarantee against unauthorized access, hacking, data loss, or other such disruptions. In accordance with existing laws, we do not assume liability for any unauthorized access, use, disclosure, or loss of personal information.

Changes to this Privacy Policy

This privacy policy may be periodically updated to reflect new technological advancements, industry standards, compliance mandates, or other necessary purposes. In event of substantial changes, We assure You will be duly notified, and when demanded by relevant laws, We will secure Your consent prior. You may receive this notification through the latest email address You have shared with Us, by posting updates on our websites and applications, or via other channels, as per legal guidelines. The most recent modification date is clearly indicated at the beginning of this document.

Contact Us

If you have any questions, concerns regarding this privacy policy, you should contact us via email at privacy@wonjo.kids.

Mailing Address:
UPILY Arastırma ve Teknoloji Gelistirme Anonim Sirketi
Universiteler Mh. Ihsan Dogramacı Bul. No:31 Ic Kapi No:2 Cankaya / Ankara, Turkiye