Privacy Policy

Our Privacy Policy was last updated on June 30, 2026.

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Age Gate means the neutral age-screening mechanism presented when the Application is first opened, used to determine whether a user is a child, a teenager, or an adult, in order to apply the appropriate privacy and advertising settings.
• Application means the software program provided by the Company downloaded by You on any electronic device, named Grammar Plus
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to DL Technologies
• Country refers to Mozambique
• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Usage Data means data collected automatically, generated by the use of the Service, which includes non-identifiable information about app performance and functionality.
• You means the individual accessing or using the Service, or the parent or legal guardian of the child using the Service, as applicable.

Age Gate and Children's Privacy

Our Service is intended for a general audience that may include children under 13. Because children may use the App, We are fully committed to complying with the U.S. Children's Online Privacy Protection Act (COPPA), the EU General Data Protection Regulation (GDPR), and the Google Play Families Policy whenever applicable.

How the Age Gate Works

When the App is first opened, users are asked to enter their age (or, where applicable, a parent/guardian enters it on the child's behalf) through a neutral, non-biased Age Gate. This age input is used only to determine which experience to apply and is not stored, linked to any other data, or used for any other purpose:

• Under 13 (or local age of digital consent): The App applies the strict child-directed protections described in this Policy, including no personalized advertising, no collection of persistent identifiers, and the use of certified, child-safe ad networks only.
• 13 and older: The App applies our standard privacy and advertising practices for teens and adults, which may include analytics and, where legally permitted and consented to, personalized advertising.

If a user does not enter an age, or if the entered age cannot be verified, the App treats that user under the stricter child-directed protections by default, out of an abundance of caution.

Data Collection and Use

The data described below reflects what we collect from users identified by the Age Gate as children under 13. Users identified as 13 or older may be subject to additional standard data practices described in the "Users Aged 13 and Older" section below.

What We Do NOT Collect From Children

We do NOT collect any of the following from users identified as children:

• Names, email addresses, or phone numbers
• Photos, audio, or video recordings
• Precise geolocation data
• Advertising IDs (AAID) for ad personalization
• Any other personally identifiable information

What We DO Collect From Children

We collect only the minimum data necessary to operate the app for users identified as children:

• App Performance Data: Basic information about app functionality, such as crashes and errors, to help us improve the app experience.
• Anonymous Usage Statistics: Non-identifiable information about which features and grammar lessons are used, to help us understand how to make the app better.
• Device Information: Basic device type and operating system version for compatibility purposes only (not for advertising).
• Age Gate Response: The age range selected at the Age Gate, used only to apply the correct experience and not linked to any other identifying information.

Users Aged 13 and Older

For users who indicate at the Age Gate that they are 13 or older, We may additionally collect standard, non-sensitive Usage Data (such as in-app interaction and performance analytics) to improve the Service, and We may display personalized advertising where permitted by law and, where required, with appropriate consent. Such users may also have additional rights described in Our general privacy practices, including the ability to opt out of personalized advertising through their device settings.

Advertising

Age-Appropriate Advertising

We display advertisements within the app to support its free availability. The type of advertisement shown depends on the age range selected at the Age Gate:

• Users Identified as Children (Under 13): Ads are strictly non-personalized, context-based, and do not use any personal information or browsing history. All such ads comply with Google Play's content policies for child-directed treatment and involve no tracking or profiling.
• Users Identified as 13 or Older: Ads may be personalized based on standard advertising identifiers, where permitted by applicable law and, where required, subject to user consent and the ability to opt out via device settings.

Our Advertising Provider

We use Google AdMob for serving advertisements. For users identified as children, AdMob is configured to serve only non-personalized ads and is certified under the Google Play Families Self-Certified Ads SDK Program in compliance with COPPA requirements for child-directed content. For users identified as 13 or older, AdMob may serve standard advertising, including personalized ads where permitted.

Data Shared with AdMob for Users Identified as Children (non-personalized ads only):

• General device information (device type, OS version) - NOT for ad targeting
• IP address (used only for fraud prevention and approximate geographic location for regional ad content, not for tracking)
• App interaction data (e.g., when an ad is displayed or clicked) - NOT linked to any user identity

What is NOT shared with AdMob for Users Identified as Children:

• Advertising ID (AAID)
• Any persistent identifiers
• Browsing history or user profiles
• Any personally identifiable information

Third-Party Services

We use the following third-party services, all of which comply with COPPA and Google Play Families requirements:

• Google AdMob: For serving advertisements
• Google Play Billing: For processing in-app purchases (premium upgrade to remove ads and unlock advanced lessons)

We do not use any analytics services, social media integrations, or other third-party SDKs that would collect personal information from children.

Parental Rights and Controls

The rights below apply where the Age Gate has identified a user as a child. Parents and guardians can also use the Age Gate, or contact Us directly, to correct an inaccurately entered age.

What Parents Should Know

As a parent or legal guardian, you have the following rights:

• Review: Request to review any information we have collected from your child (note: we collect minimal to no personal information)
• Delete: Request deletion of any data associated with your child's use of the app
• Refuse Collection: Refuse to permit further collection or use of your child's information
• Premium Option: Purchase the premium version to remove all advertisements

Remove Ads Completely

Parents can purchase the premium version of the app through Google Play's in-app purchase system to completely remove all advertisements and unlock the full set of grammar lessons and games.

Data Security

We implement appropriate technical and organizational security measures to protect the limited data we collect. However, no method of transmission over the Internet or electronic storage is 100% secure. The minimal data we collect reduces potential security risks.

Data Retention

We retain data only for as long as necessary to provide the app's functionality:

• App Performance Data: Retained for up to 30 days for debugging purposes
• Age Gate Response: Retained only locally on the device for the duration of the app session/installation, to apply the correct experience
• Purchase Records: Retained as required by Google Play and tax regulations
• No User Profiles: We do not maintain any user accounts or profiles

International Users

Our app is available worldwide. We comply with applicable privacy laws including COPPA (United States), GDPR (European Union), and other regional children's privacy regulations.

EU Representative (Article 27 GDPR)

FGND Core GmbH
Hauptstrasse 151, 10827 Berlin, Germany
Email: dl-technologies@core-privacy.eu

This contact is for GDPR-related privacy matters and requests from EU supervisory authorities and individuals in the EU.

Links to Other Websites

This app does not contain links to external websites except for:

• This Privacy Policy
• Google Play Store (for app updates)

We do not link to any third-party websites or services that could collect additional information from children.

Changes to This Privacy Policy

We may update Our Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will notify users of any material changes by:

• Posting the new Privacy Policy on this page
• Updating the "Last Updated" date at the top of this policy
• Providing an in-app notification for significant changes

We encourage parents to review this Privacy Policy periodically. Changes become effective when posted on this page.

Compliance Certifications

Our app complies with:

• COPPA (Children's Online Privacy Protection Act) - United States
• GDPR (General Data Protection Regulation) - European Union
• Google Play Families Policy - Child-directed content requirements
• Google Play Families Self-Certified Ads SDK Program - AdMob certification

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your child's privacy, please contact us: