Effective Date: 4 November 2025
Introduction
TORTUGA APPS (SMC-PRIVATE) LIMITED (“we,” “us,” or “our”) is committed to protecting the privacy and safety of children using our mobile application, Kids 123 Learning (“the App”). This Privacy Policy outlines how the App manages data in compliance with applicable regulations, including COPPA (Children’s Online Privacy Protection Act), GDPR-K (General Data Protection Regulation for Kids), and Google Play’s Families Policy.
The App is designed for young children and offers two primary features: number learning (1–20) and a simple number quiz. The App includes advertising to support its development.
Information We Collect
a. User-Provided Data
The App does not require or collect any user-entered personal data.
b. Automatically Collected Data
To provide its functionality and monetize the App, we use third-party SDKs that automatically collect certain data. This data is not directly collected or stored by us, but by the third-party providers.
The App may collect the following types of data:
- Device Identifiers: We have taken steps to ensure that personal identifiers, such as the Android Advertising ID (AAID), are not collected or transmitted by our third-party SDKs. The app is configured to prevent the collection of this data.
- Crash and Usage Data: The App uses Firebase Crashlytics to collect crash reports and Firebase Analytics to understand how users interact with the App. This data is anonymized and helps us improve the App’s stability and features. The data collected includes information about your device (e.g., model, OS version), app usage, and crash events.
Permissions Used in the App
To support its new features, the App requests and uses the following Android permissions:
android.permission.INTERNET: Required for third-party SDKs to function, including serving ads and sending crash/analytics data.android.permission.ACCESS_NETWORK_STATE: Allows the App to check the network status (e.g., whether a Wi-Fi or mobile data connection is available) to optimize data usage for SDKs.
Note on the AD_ID Permission: The App explicitly removes the com.google.android.gms.permission.AD_ID permission from its manifest. This ensures that the App cannot access the Android Advertising ID, further strengthening our commitment to preventing personalized or targeted advertising and protecting user privacy.
Third-Party SDKs & Families Policy Compliance
The App uses the following third-party SDKs, which are selected to ensure compliance with Google Play’s Families Policy and other applicable regulations.
| SDK Name | Purpose | Families Policy Compliant | Privacy Policy Link |
| Google Mobile Ads SDK (AdMob) | To serve contextual, non-personalized ads. We have configured AdMob to comply with COPPA and the Google Play Families Policy by treating all ad requests as child-directed. The App’s manifest is also configured to prevent the use of the Android Advertising ID. | Yes | Google Privacy Policy |
| Firebase Crashlytics | To collect crash reports to monitor and improve app stability. | Yes | Firebase Privacy & Security |
| Firebase Analytics | To provide anonymized usage statistics to help us improve the user experience. | Yes | Firebase Privacy & Security |
| androidx.core.ktx | Kotlin extensions | Yes | AndroidX Privacy |
| androidx.appcompat | Backward compatibility | Yes | AndroidX Privacy |
| com.google.android.material | Material UI Components | Yes | Google Privacy Policy |
| androidx.activity | Activity lifecycle support | Yes | AndroidX Privacy |
| androidx.constraintlayout | Layout and UI design | Yes | AndroidX Privacy |
| androidx.emoji2:emoji2 | To ensure a wide range of emojis are displayed correctly and are up-to-date across different Android versions. | Yes (As a core Android library for UI rendering) | AndroidX Privacy |
| androidx.emoji2:emoji2-bundled | Includes the necessary font files to display the latest emojis, ensuring compatibility on older devices. | Yes (As a core Android library for UI rendering) | AndroidX Privacy |
Disclaimer: TORTUGA APPS (SMC-PRIVATE) LIMITED does not control these SDKs individually. Each SDK is governed by its own privacy policy. We have configured these SDKs to be compliant with child privacy laws, but we are not responsible for their direct data collection and use.
Children’s Privacy
This App is intended for children under the age of 13. We are committed to complying with COPPA, GDPR-K, and the Google Play Families Policy.
- No Personal Data Collection: We do not knowingly collect, store, or transmit any personally identifiable information from children. By removing the AD_ID permission, we prevent the collection of the Android Advertising ID, ensuring no user-specific identifiers are used for ad targeting.
- Advertising: All ads served through Google AdMob are contextual and non-personalized. We ensure that ad requests are tagged as “child-directed,” which disables interest-based advertising and remarketing for all users.
- Analytics: Firebase Analytics is configured to collect anonymized data in a way that is compliant with COPPA and GDPR. It does not collect any personally identifiable information from children.
Changes to This Privacy Policy
We may update this policy to reflect changes in legal requirements or app functionality. When we do, the “Effective Date” at the top will be updated. We recommend reviewing this policy periodically for updates.
Contact Us
For any questions about this Privacy Policy or our data practices, please contact:
Email: support@tortugaapps.site
Company: TORTUGA APPS (SMC-PRIVATE) LIMITED