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Kid Doodle — Children's Privacy Policy

Last updated: June 20, 2026

This Children's Privacy Policy (the "Policy") explains how Nevzat Atilla Ozder ("Developer", "we", "us", or "our") handles information in connection with the mobile application Kid Doodle — Color, Draw & Paint for Kids (Apple App Store ID 1500785406) (the "App"). The App is designed for young children (ages 2–6) and the parents and guardians who provide it to them.

This Policy applies only to the App. It does not apply to any other app, website, or service, including any operated by us under a different name or at a different address. This Policy forms part of, and should be read together with, our Terms of Use. If there is a conflict between this Policy and the Terms of Use on a matter of privacy, this Policy controls.

This version is effective as of the "Last updated" date shown above and replaces any earlier version for the App.

1) Who operates the App (Data Controller)

  • Data Controller / Operator: Nevzat Atilla Ozder
  • Address: Cavus Mah. Muhtesem Sk. 6B/16 Sile / Istanbul, Turkiye
  • Email: support@atillaozder.com
  • Data Protection Officer: Not required; none appointed. Privacy enquiries go to the email above.

We are the "operator" of the App for the purposes of the U.S. Children's Online Privacy Protection Act ("COPPA") and the "controller" for the purposes of the EU/UK General Data Protection Regulation ("GDPR") and Turkiye's Personal Data Protection Law No. 6698 ("KVKK").

2) Our privacy-by-design approach

We designed the App to collect as little information as possible from children. The App is built to run on the device and does not require an account, a login, or an internet connection to function. We apply a high standard of protection appropriate to children, by design and by default, consistent with applicable children's privacy frameworks (including COPPA, as amended, and the UK Age Appropriate Design Code).

A) Information the App does NOT collect

  • No advertising and no advertising identifiers (IDFA).
  • No analytics, attribution, or measurement SDKs.
  • No third-party tracking, profiling, or behavioral advertising.
  • No push-notification token collection.
  • No user accounts, login, email capture, or registration.
  • No user-generated content shared with us (no chat, no profile, no uploads).
  • No precise location (GPS), contacts, photos, camera, microphone, or health data.
  • No biometric identifiers (such as fingerprints, faceprints, or voiceprints).
  • No government-issued identifiers.
  • No persistent identifiers used to recognize a user across apps, services, or over time.

No third-party data-collection SDKs. The App does not integrate any third-party advertising, analytics, attribution, social, or tracking software development kits (SDKs) that collect personal information from children.

B) Information processed by Apple (App Store, In-App Purchases, diagnostics)

The App uses Apple's App Store and, where offered, Apple's In-App Purchase system (StoreKit). We do not receive your payment card information. Apple may process personal data when you download the App or make a purchase (for example, account and purchase information) under Apple's own policies, as an independent controller.

Apple diagnostics (optional): If the device owner has opted in to share technical diagnostics with app developers in iOS settings, Apple may provide us with anonymized or aggregated crash and performance information to help us fix bugs. This information is provided through Apple's developer tools and is not used to track users.

Apple policies:

C) Information you choose to send us (optional)

If a parent or guardian contacts us for support by email, we receive the information contained in that email (for example, the sender's email address and the message content). We do not ask children to submit personal information in the App, and we do not require any personal information as a condition of using the App's features.

Unsolicited information: If we learn that we have received personal information from a child without a parent's or guardian's involvement (for example, an unsolicited email), we will delete it as soon as reasonably possible and will not use or disclose it except as necessary to respond or to comply with law.

3) How we use information, and our legal bases

Because the App does not use analytics or advertising SDKs, our use of personal information is limited to:

  • responding to parent/guardian support requests sent to support@atillaozder.com;
  • maintaining, securing, and improving the App based on our own testing and on feedback you choose to send us (without in-app analytics or tracking); and
  • complying with our legal obligations and exercising or defending legal claims.

We do not use information for behavioral advertising, profiling, or tracking, and we do not sell or rent personal information.

Legal bases (GDPR/UK GDPR): where the GDPR applies, we rely on our legitimate interests in operating, securing, and improving the App and in responding to your enquiries (balanced against your rights), on compliance with a legal obligation, and, where required, on your consent, which you may withdraw at any time. Because we direct the App to children, we minimize processing and rely on parent/guardian-initiated contact rather than on collecting information from children.

Automated decision-making: we do not carry out automated decision-making, including profiling, that produces legal or similarly significant effects on children or parents.

4) How we share information

We do not sell or rent personal information. We share information only in these limited situations:

  • With Apple: to process downloads and any in-app purchases via the App Store.
  • Service providers: if we ever engage a processor to act strictly on our instructions (for example, email handling for support), they are bound by confidentiality and data-protection obligations and may not use the information for their own purposes.
  • Legal and safety reasons: where required to comply with applicable law, lawful requests, or to establish, exercise, or defend legal claims, or to protect the rights, safety, and integrity of users, the public, or our services.
  • Business transfer: in connection with a merger, acquisition, or sale of assets, subject to this Policy and applicable law.

5) Data retention

Consistent with the amended COPPA Rule, we keep personal information only for as long as is reasonably necessary to fulfill the specific purpose for which it was collected; we do not retain it for any secondary purpose and we do not retain it indefinitely. When it is no longer needed, we delete or anonymize it.

  • In-app data: we do not maintain a user-account database for the App.
  • Support emails: if you email us, we retain the correspondence only as long as reasonably necessary to respond and for legitimate recordkeeping, dispute-resolution, and legal-compliance purposes, after which we delete or anonymize it. You can request deletion at any time (see Section 8).

6) International transfers

We are located in Turkiye. Apple and its service providers may process App Store, purchase, and optional diagnostics data in the United States and other countries under Apple's policies. Where we transfer personal information across borders and the GDPR/UK GDPR or KVKK applies, we rely on a lawful transfer mechanism — such as an adequacy decision or appropriate safeguards (including standard contractual clauses, binding corporate rules, or, under the KVKK as amended in 2024, a written undertaking authorized by the Turkish Data Protection Board) — to protect that information.

7) Security

We use reasonable administrative, technical, and organizational measures appropriate to the limited information we control (such as support emails) to protect it against unauthorized access, loss, misuse, or alteration. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8) Your rights (parents/guardians) and how to contact us

A) United States — COPPA

The App is directed to children, so COPPA applies. Consistent with COPPA, we do not knowingly collect personal information from children in the App, and we do not condition a child's participation on disclosing more personal information than is reasonably necessary. Where a parent or guardian voluntarily emails us, we rely on COPPA's limited exceptions that permit collecting online contact information solely to respond to a specific request, after which we delete it.

As a parent or guardian, you may review any personal information we have received from or about your child, direct us to delete it, and refuse to permit its further use or collection, by contacting us at the email below. We will take reasonable steps to verify that you are the child's parent or guardian before acting on a request.

No third-party disclosure for advertising: consistent with the amended COPPA Rule, we do not disclose children's personal information to third parties for targeted advertising or other unrelated purposes. We would obtain separate verifiable parental consent before making any such disclosure, which we do not currently make.

California & other U.S. state laws (incl. CPRA): we do not "sell" or "share" (for cross-context behavioral advertising) the personal information of children or of consumers of any age, we do not use sensitive personal information to infer characteristics, and we do not offer financial incentives in exchange for personal information.

To learn more about COPPA and children's privacy, you can visit the U.S. Federal Trade Commission's website.

B) GDPR / UK GDPR (EEA/UK)

If you are in the EEA or UK, you may have rights to access, rectify, erase, restrict, or object to processing of personal information, to data portability, and to withdraw consent where processing is based on consent.

If you are in the UK, we also take into account the heightened protections for children under the UK GDPR (as updated by the Data (Use and Access) Act 2025) and the ICO's Age Appropriate Design Code (the Children's Code).

Right to complain: you also have the right to lodge a complaint with your local data protection supervisory authority. We would, however, appreciate the chance to address your concerns first.

C) Turkiye KVKK (Law No. 6698)

For users in Turkiye, you have rights under Article 11 of the KVKK, including (among others) the right to:

  • learn whether your personal data is processed;
  • request information if it is processed;
  • learn the purpose of processing and whether it is used in accordance with that purpose;
  • know the third parties to whom personal data is transferred (domestically or abroad);
  • request correction of incomplete or inaccurate data;
  • request deletion or destruction under the applicable conditions;
  • request that correction, deletion, or destruction be notified to third parties to whom data was transferred;
  • object to a result against you arising exclusively from automated analysis; and
  • request compensation for damages arising from unlawful processing.

How to exercise your rights (email)

Email: support@atillaozder.com
Please include the App name (Kid Doodle), the type of request (access, deletion, etc.), and enough detail for us to locate the relevant communication. We will respond within the timeframe required by applicable law. We do not charge for exercising your rights except where permitted by law for manifestly unfounded or excessive requests.

9) Third-party links and Parental Gates

The App is designed to provide a safe environment for children.

Parental Gates: where the App includes any link that leads outside the App (such as a link to our support email, website, this Policy, or other apps), that link is intended to be protected by a "parental gate" — a challenge designed to help ensure the user is an adult — to prevent children from accessing external content without supervision.

Third parties: if a parent or guardian chooses to navigate to a third-party website or service, that third party's privacy practices apply, and we are not responsible for them.

10) Apple Kids Category and child-directed requirements

To the extent the App is offered in Apple's Kids Category or is otherwise treated as directed to children, we design it to comply with the additional requirements that apply, including not including behavioral advertising and not transmitting personally identifiable information or device information to third parties for tracking.

11) Changes to this Policy

We may update this Policy from time to time. We will post the updated version with a new "Last updated" date, and, where a change is material, we will take additional reasonable steps to notify you (for example, in the App or on the store listing) where feasible. Your continued use of the App after an update takes effect indicates your awareness of the updated Policy.

12) Contact