Kobi Kids – Puzzles for Kids & Toddlers
Last Updated: 1st June 2026
1. Introduction
This Privacy Policy describes the information practices of Intudev Ltd. (“the Company”), a limited liability company incorporated in Hong Kong SAR (“we,” “us,” or “our”), which operates the mobile application Kobi Kids – Puzzles for Kids & Toddlers (“the App”). The Company is the operator of the App for the purposes of this Privacy Policy and all applicable data protection laws. References to “Kobi Kids” are references to the App, which is owned and operated by the Company. The App is an educational puzzle game designed for children aged 2–5 and is available on iOS and Android platforms worldwide.
We are committed to protecting the privacy of children who use our App. We comply with all applicable privacy and data protection laws in the jurisdictions in which the App is made available, including but not limited to:
- United States: The Children’s Online Privacy Protection Act (“COPPA”) and the COPPA Rule (16 C.F.R. Part 312), as amended, together with applicable state-level privacy and children’s data protection laws;
- European Economic Area: The General Data Protection Regulation (EU) 2016/679 (“GDPR”);
- United Kingdom: The UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, including the Age Appropriate Design Code (“Children’s Code”);
- Canada: The Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial privacy legislation;
- Australia: The Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”);
- Hong Kong SAR: The Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”);
- People’s Republic of China: The Personal Information Protection Law (“PIPL”) and the Provisions on the Cyber Protection of Minors;
- Japan: The Act on the Protection of Personal Information (“APPI”);
- South Korea: The Personal Information Protection Act (“PIPA”); and
- Brazil: The General Data Protection Law (“LGPD”), Lei Nº 13.709/2018, and the Digital Statute of the Child and Adolescent (“Digital ECA”);
- India: The Digital Personal Data Protection Act 2023 (“DPDP Act”).
We do not collect, use, or disclose personal information from children or any other users of this App.
2. Operator Information
The operator of this App for the purposes of COPPA and all other applicable data protection laws is:
Intudev Ltd. (trading as Kobi Kids), of Room F, Floor 21, 1 Larch Street, Tai Kok Tsui, Kowloon, Hong Kong SAR | Email: privacy@kobikids.app | Website: https://kobikids.app
3. Information We Collect
We do not knowingly collect any personal information from children or adults who use this App. Specifically:
- We do not require users to create an account or register to use the App.
- We do not collect names, email addresses, physical addresses, phone numbers, or any other contact information.
- We do not collect photographs, video, or audio recordings, including any audio file containing a child’s voice.
- We do not collect precise or general geolocation data.
- We do not collect biometric identifiers, such as fingerprints, facial recognition data, retina scans, or voiceprints.
- We do not collect government-issued identifiers of any kind.
- We do not collect persistent identifiers such as device IDs, advertising IDs, cookies, or IP addresses for the purpose of identifying individual users.
- We do not use cookies or similar tracking technologies.
- We do not engage in behavioural profiling or targeted advertising of any kind.
The App is designed to function entirely offline and does not require an internet connection for gameplay.
4. Third-Party Services
Advertising: The App contains no advertisements. We do not use any third-party advertising networks or services, and no advertising SDKs are integrated into the App.
Analytics: We do not use any third-party analytics services. No analytics SDKs are integrated into the App. We do not collect usage data, session information, or behavioural metrics of any kind.
In-App Purchases: The App offers optional in-app purchases for additional puzzle themes. All transactions are processed entirely by the Apple App Store or Google Play Store, depending on your device. We do not process, collect, or have access to any payment information, billing details, or financial data. The respective platform’s own privacy policy governs the handling of transaction data:
Other Third-Party SDKs: No other third-party SDKs, plug-ins, or services that collect personal information are integrated into the App.
5. Data Retention Policy
We do not collect personal information from users of the App. Accordingly, we do not retain, store, or maintain any personal data on our servers or in any system under our control, and we hold no children’s personal information that would be subject to a retention period.
All gameplay progress and settings are stored locally on the user’s device, are under the control of the user, and are not transmitted to us or to any third party. We do not have access to any data stored on the user’s device. Such locally stored data is removed if the user deletes the App.
Should we modify the App in the future to collect any personal information, we will establish, implement, and maintain a written data retention policy that states the specific purposes for which any children’s personal information is collected, the business need for retaining it, and a defined timeframe for its deletion. We will not retain any children’s personal information for longer than is reasonably necessary to fulfil the purpose for which it was collected, and we will not retain such information indefinitely.
6. Data Security
Although we do not collect personal information, we have designed the App with child safety as a core principle:
- The App does not contain any external links accessible to children.
- In-app purchase areas and settings are protected by a parental gate to prevent accidental purchases or navigation outside the App.
- The App does not include social features, chat functionality, user-generated content, or any means for users to communicate with one another.
- The App functions offline and does not require or maintain a persistent connection to the internet.
Age-Appropriate Design. Consistent with the United Kingdom’s Age Appropriate Design Code and equivalent age-appropriate design standards in other jurisdictions, the App is designed with the best interests of the child as a primary consideration. In particular: the App applies the most privacy-protective approach by default, in that it collects no personal information at all; it contains no profiling or behavioural tracking; it employs no “nudge” techniques or design features intended to encourage children to provide personal information, to share more data, or to extend their use of the App; and access to in-app purchases, settings, and any navigation outside the App is governed by a parental gate.
7. Children’s Privacy
This App is designed exclusively for use by children. We treat all users of the App as children falling below the relevant age threshold for the protection of children’s data in each applicable jurisdiction. We do not:
- Condition a child’s participation in any activity on the disclosure of more personal information than is reasonably necessary for the child to participate in that activity;
- Collect personal information from children for the purpose of behavioural advertising, profiling, or creating user profiles;
- Disclose children’s personal information to third parties;
- Use children’s personal data for commercial purposes unrelated to the provision of the App; or
- Encourage children to disclose personal information.
We process no personal data from children. In the event that we modify the App in the future to collect any personal data, we will obtain verifiable parental or guardian consent in accordance with all applicable laws before any such collection takes place.
8. Parental Rights
We respect the rights that parents and guardians hold under the privacy laws of their jurisdiction. Because we do not collect any personal information, there is no personal data to access, review, correct, delete, port, or restrict. However, for your reference, the following is a summary of the key parental rights available under applicable laws:
United States (COPPA and state laws): Parents have the right to review personal information collected from their child, request its deletion, refuse further collection, and consent to collection without consenting to third-party disclosure. Various US states, including California, provide additional rights such as the right to opt out of the sale or sharing of personal information.
European Economic Area (GDPR) and United Kingdom (UK GDPR): Data subjects have rights of access, rectification, erasure, restriction of processing, data portability, and objection. Where a child is below the applicable age of digital consent (16 in most EU member states; 13 in the United Kingdom), a parent or guardian may exercise these rights on the child’s behalf. The UK’s Age Appropriate Design Code requires online services likely to be accessed by children to provide high privacy protections by default.
Canada (PIPEDA): Individuals have the right to access and challenge the accuracy of personal information held about them. Parental consent is required before collecting personal information from children under 13.
Australia (Privacy Act 1988): Individuals have the right to access and correct personal information held about them. A parent or guardian may exercise these rights on behalf of a child.
Hong Kong SAR (PDPO): Data subjects, including parents acting on behalf of their children, have the right to request access to and correction of personal data held by a data user.
People’s Republic of China (PIPL): The PIPL classifies personal information of children under 14 as sensitive personal information, requiring separate parental consent and a personal information impact assessment before processing. Parents and guardians have the right to access, correct, and request deletion of their child’s personal information.
Japan (APPI): Where a minor lacks the capacity to understand the consequences of consenting to data processing, consent must be obtained from a parent or legal representative. Data subjects have rights of access, correction, and deletion.
South Korea (PIPA): Parental consent is required before collecting personal information from children under 14. Data subjects have rights of access, correction, suspension of processing, and deletion.
Brazil (LGPD and Digital ECA): The LGPD requires that children’s personal data (under 12 years of age) be processed only with specific parental consent and in the child’s best interests. The Digital ECA establishes additional protections for minors in digital environments, including prohibitions on behavioural advertising directed at children. Parents and guardians have the right to access, correct, and request deletion of their child’s personal data.
India (DPDP Act): The DPDP Act requires verifiable parental consent before processing any personal data of children (defined as individuals under 18). Parents and guardians have rights of access, correction, and erasure.
All Jurisdictions: If you believe we have inadvertently collected personal information from your child, please contact us immediately using the details provided in Section 11 below. We will take prompt steps to investigate and, where personal information is found to have been collected, to delete it.
9. International Data Transfers
Because we do not collect personal data, no personal data is transferred across borders. All App data (gameplay progress and settings) is stored locally on the user’s device.
In the event that we modify our practices in the future to collect any personal data, we will update this Privacy Policy and ensure that any cross-border transfer of personal data complies with the requirements of the PDPO, GDPR, PIPL, LGPD, PIPA, APPI, and all other applicable data protection laws, including by implementing appropriate safeguards such as standard contractual clauses or other lawful transfer mechanisms.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to the App, our practices, or applicable law. If we make material changes — particularly any change involving the collection, use, or disclosure of personal information — we will provide notice by updating the “Last Updated” date at the top of this policy and, where required by law, seek any necessary consents. We encourage you to review this Privacy Policy periodically.
11. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy, our information practices, or your child’s privacy, please contact us at:
Kobi Kids | Email: privacy@kobikids.app | Website: https://kobikids.app
This Privacy Policy is effective as of 1st June 2026.