1. Introduction
This Privacy Policy explains how VERBUM EDUCA LTDA ("Verbum Apps", "we"), Brazilian company registration (CNPJ) 59.508.559/0001-70, handles information in the apps, games and websites it publishes (the "Services"), in accordance with Brazil's General Data Protection Law (Law No. 13,709/2018 — LGPD), the Children's Online Privacy Protection Act (COPPA, US), the EU General Data Protection Regulation (GDPR), and Apple App Store and Google Play policies.
Our Services are designed for children and families. We therefore follow a data-minimization principle: we only process what is strictly necessary for the app to work.
2. Information we collect
Children's data: we do not ask for a child's name, email, phone number, address, photos, precise location or any identifying information. There are no accounts, open chats or user-to-user content sharing.
Non-identifying technical data: information such as device model, OS version, language and crash logs may be collected in aggregate to fix bugs and improve performance.
In-app progress: completed levels, preferences and settings are stored locally on the device and are not sent to our servers unless stated in the app.
Adults' data: when a parent or guardian emails us or makes a purchase, we use the email and information provided only to reply and provide support. Payments are fully processed by Apple or Google; we never access card details.
3. How we use information
We use information solely to: (a) operate the app; (b) diagnose crashes and improve stability; (c) answer support requests; (d) comply with legal obligations.
We do not use children's data for behavioral advertising, profiling, remarketing, or sale to third parties.
4. Legal bases
Processing relies on Articles 7 and 14 of the LGPD (and Article 6 of the GDPR where applicable): performance of the requested service, legitimate interest in app security and stability, compliance with legal obligations and, where required, specific and prominent consent from at least one parent or legal guardian.
5. Children's privacy
We comply with Article 14 of the LGPD, which requires children's data to be processed in their best interest, and with COPPA. We do not knowingly collect personal information from children under 13 without verifiable parental consent.
External links, purchases and store ratings are protected by a parental gate that requires adult action.
If you are a parent and believe we have improperly collected data from your child, contact us and we will delete it promptly.
6. Advertising and third-party services
If any app displays ads, they will be non-personalized (contextual) only and served by networks certified under Google Play's Families program, with no advertising identifiers (IDFA/AAID) collected from children.
We may use third-party tools for crash reporting and app distribution (such as Apple's and Google's own store services), configured not to collect identifiable personal data from children. These companies have their own privacy policies.
8. Retention and security
We keep data only as long as needed for its purpose or legal obligations. Crash logs are kept in aggregate for up to 90 days. Support messages are kept for up to 2 years.
We apply reasonable technical and organizational measures, such as encryption in transit (HTTPS/TLS) and access control, to protect information.
9. Your rights
Under Article 18 of the LGPD (and the GDPR/COPPA where applicable), you may request: confirmation of processing; access; correction; anonymization, blocking or deletion; portability; information about sharing; and withdrawal of consent. You may also file a complaint with Brazil's National Data Protection Authority (ANPD) or your local authority.
To exercise your rights, write to suporte-br@verbum-apps.com. We will respond within 15 days.
10. Changes to this policy
We may update this policy from time to time. The current version will always be on this page with its last-updated date. Material changes will be announced in the apps or on their store pages.
11. Contact and DPO
VERBUM EDUCA LTDA — CNPJ 59.508.559/0001-70
R. José Teófilo da Cruz, 158, Apto 101 — Parque Jaraguá, Taubaté/SP — CEP 12062-640, Brasil
Email: suporte-br@verbum-apps.com
Data Protection Officer: suporte-br@verbum-apps.com