Ilugon Privacy Policy

This policy applies to our apps distributed through Google Play, which use Firebase Analytics. Our apps distributed through the App Store do not use it and are covered by their own policy.

🏢 Data controller

Ilugon Educational Games, S.L. Calle Padornelo 24, 2.º B — 28050 Madrid, Spain Privacy contact: info@ilugon.com

⚖️ Legal basis

At ILUGON, we respect the privacy rights and data protection of our users and recognise the importance of protecting the information collected. We comply with Art. 13/14 of Regulation (EU) 2016/679 (GDPR) and strive to adhere to best global practices, including the Children’s Online Privacy Protection Act (COPPA) in the U.S. and Google Play’s Families Policy.

We process the technical data described below on the basis of our legitimate interest (Art. 6(1)(f) GDPR): we need to know whether the app installs and works correctly in order to maintain it. That interest is limited to non-personal data, is never used to build profiles or personalise advertising, and therefore does not override children’s rights. If you would rather object to this processing, you can do so by writing to us.

👧 Child protection and data security

Child protection is our main priority.

• Target audience. This application is exclusively directed at children under the age of 13.
• Collection of personal information (PII). We do not knowingly collect Personally Identifiable Information (PII) from children through our apps (such as names, emails, addresses, etc.).
• Persistent identifiers. To comply with COPPA, we have configured all our analytics tools to deny the use of persistent device identifiers for advertising personalisation purposes.

📊 Limited data collection (Firebase Analytics)

Although we do not collect PII, we do collect limited technical data for app functionality and measurement.

• Service provider. We use Firebase Google Analytics, a service provided by Google, exclusively to measure app performance and the success of our Google Ads campaigns (specifically the first_open event). Google acts as our service provider and processes data strictly according to our instructions.
• Technical data collected. We collect the following non-personal data, strictly for analytics purposes:
  • Device identifiers: a unique App Instance ID (generated by Firebase).
  • Usage data: the first-open event (first_open) and the aggregated usage metrics that Firebase produces.
• Purpose. This data is used exclusively for analytics (measuring the initial app conversion) and app functionality. These are the only two purposes we declare in Google Play’s Data Safety form.
• No advertising. Our apps contain no advertising of any kind. The technical identifiers collected are never used to create profiles or to personalise ads.

🗓️ How long we keep the data

These are the retention periods we have configured in Google Analytics:

• Event data: 2 months. This is the shortest period Google allows.
• Data tied to the device identifier: 14 months from the last activity. The clock restarts every time the app is used, so the identifier is deleted 14 months after the child stops playing.

Once those periods elapse, Google deletes the data automatically. Aggregated reports, which cannot identify any device, are kept for as long as the app remains published.

If you write to us to exercise your rights, we keep your email for as long as we need to handle the request and to show that we handled it, and then delete it.

🌍 International transfers

Firebase and Google Analytics are services provided by Google LLC, based in the United States, so the technical data described above is processed outside the European Economic Area. Google covers those transfers under the EU-U.S. Data Privacy Framework and, additionally, under the standard contractual clauses approved by the European Commission, incorporated into the Google data processing terms we have signed.

📝 Right of access and data deletion (COPPA)

Any parent or legal guardian may exercise their rights regarding data collected from their child’s device.

• Your rights. You can exercise your rights of access, rectification, erasure, restriction of processing, portability and objection by sending a request via email to info@ilugon.com.
• Complaint to a supervisory authority. If you believe we have not handled your request properly, you can lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) or with the data protection authority of the country where you live.
• Minor data deletion process. If you wish to request the deletion of all technical data associated with your child’s device:
  1. Contact us via email at info@ilugon.com.
  2. We will ask you to first access the privacy section of the app to obtain and provide us with the App Instance ID (a 32-digit identifier).
  3. We will use this unique identifier to locate and delete all analytics data from our Firebase/Google Analytics system.

📢 Advertising, third-party sites and cookies

Our apps contain no advertising of any kind — neither third-party nor our own — and no links to third-party websites, products, or services.

This website does not use cookies and does not run any analytics or third-party scripts. Every resource it loads is served from ilugon.com. The Firebase Analytics described above applies to our mobile apps, not to this website.

🤝 Acceptance of the policy

By accessing our website and installing our mobile apps, the user agrees to the practices set out in this privacy policy. We advise reading this privacy policy, as by allowing your children to use our services you are agreeing to this privacy policy on their behalf. If you disagree, please do not allow your child to use our apps.

ILUGON may change its Privacy Policy. If these changes affect user rights, users will be notified. The updated Privacy Policy is permanently accessible on the website.