Privacy Policy

Last updated: August 2026

1. About this Privacy Policy

This Privacy Policy explains how TOREYNOS LIMITED (“JNH Developers”, “we”, “us” or “our”) collects and uses personal data when people use our mobile applications, visit jnhdevelopers.com, contact us or otherwise interact with our services (together, the “Services”).

Our portfolio includes applications designed for children and applications intended for a general audience. The rules that apply depend on the relevant application and its intended and actual audience. Section 3 explains these categories. Where an app-specific notice shown in an app or on an official store listing provides more specific information, that notice supplements this Policy.

This Policy is a notice about our data practices. It is not a request for a child to provide personal data, and accepting our Terms of Use does not by itself constitute consent to processing that requires separate consent under applicable law.

2. Who is responsible for your data

The controller responsible for the processing described in this Policy is:

TOREYNOS LIMITED
Company number: 16748176
Office 14921, 182-184 High Street North, East Ham, London, United Kingdom, E6 2JA
Email: toreynos@jnhdevelopers.com
Telephone: +44 7700 161582

3. Which application category applies

Kids Apps are applications that are listed in the Apple App Store Kids Category, include children in the Google Play target audience, are otherwise marketed or designed primarily for children, or must be treated as child-directed under applicable law. Kids Apps use the child-protective practices in Section 4.

General-Audience Apps are applications that are not directed to children and are not marketed as being for children. They use the practices in Section 5. A low store age rating alone does not make an application a Kids App.

Mixed-audience treatment. If an application is directed to both children and adults, we either apply the Kids App protections to all users or use a neutral age-screening method before enabling any adult-only data practices. We do not encourage users to misstate their age, and we do not enable adult tracking by default before we know that the user is an adult.

4. Kids Apps

4.1 Child-protective defaults

Kids Apps are designed to work without a child creating an account or directly submitting a name, email address, precise location, photograph, voice recording, free-form message or other personal content to us. They do not use personal data for cross-app tracking, behavioural advertising, profiling for advertising, data brokerage or sale.

Kids Apps do not request access to the advertising identifiers IDFA or AAID and do not transmit advertising identifiers from children or users whose age is unknown. We configure or remove third-party software development kits so that they do not use prohibited identifiers or child data.

4.2 Microphone access in Kids Stories – Fairy Tales app

The Kids Stories – Fairy Tales App allows users to record their own narration for stories. A recording may include the voice of a child.

The App accesses the device microphone only when the user chooses to start a recording and grants microphone permission through the device settings. Voice recordings are stored exclusively on the user’s device and are used solely to play the recorded narration within the App.

JNH Developers does not collect, receive, access, upload, transmit or share voice recordings. The recordings are not used for analytics, advertising, profiling, voice identification or artificial intelligence training. Users can delete their recordings within the App. Recordings are also removed when the App and its locally stored data are deleted.

4.3 Limited technical data

A Kids App may process the minimum technical information reasonably necessary to provide the game, maintain security, remember settings or purchases, diagnose crashes and measure the reliability of the app. Depending on the app and platform, this may include:

• app name and version, operating system version, device type or model class and language settings;
• coarse country or region derived from store settings or an IP address, without collecting precise GPS location;
• IP address and network information processed to deliver a request, prevent abuse and maintain security;
• crash reports, error logs, launch and performance events and diagnostic information;
• limited gameplay or feature events that do not contain a child’s name, contact details or advertising identifier; and
• purchase or subscription entitlement status supplied by the relevant app store, without full payment-card details.

Where an app-specific identifier is strictly necessary for internal operations, it is scoped to the app or service, is not used for advertising or cross-app profiling, and is retained only for the relevant operational purpose. We do not ask a child to provide more information than is reasonably necessary to participate in an activity.

4.4 No Advertising in Kids Apps

Our Kids Apps do not display third-party advertising, including targeted, personalised or contextual advertising.

4.5 Parental gates, purchases and external links

Purchasing opportunities, external links and adult-facing settings in Kids Apps are placed in a designated parent area or behind a parental gate where required by the applicable platform. A parental gate is a product-safety control. It is not a method of obtaining verifiable parental consent to collect a child’s personal data.

Purchases are processed by Apple and Google. We receive purchase status and transaction references needed to provide or restore purchased content, but we do not receive full payment-card details.

4.6 Support and parental consent

Support channels are intended for parents and other adults. We ask adults not to send personal information about a child unless it is necessary for a support request. If we learn that a child has sent personal information directly to us without the required authorisation, we will use it only to protect the child or respond as permitted by law and will delete it as soon as reasonably practicable.

Our current Kids Apps are not intended to offer a feature that requires a child to submit personal data subject to prior verifiable parental consent. If we introduce such a feature, we will provide the required direct notice to the parent and keep the feature unavailable until we obtain verifiable parental consent by a method permitted by applicable law. Where consent is required for disclosure to third parties, we will obtain any required separate consent.

5. General-Audience Apps

General-Audience Apps may process more information than Kids Apps, depending on their features and the choices available to the user. They are not intended for children. If we learn that a user of a General-Audience App is a child and the app must be treated as child-directed in relation to that user, we will disable adult-only data practices, seek any legally required parental authorisation or delete the affected personal data.

5.1 Information you provide

• contact information and the content of communications when you contact support;
• account details, if a particular app offers an adult account;
• feedback, survey responses or other information you choose to send; and
• purchase information supplied by an app store or payment provider, excluding full payment-card details.
• billing and transaction information when you make a purchase or start a subscription through our website, such as the product or subscription selected, amount, currency, billing country, transaction status and payment-related identifiers supplied by Stripe. Full payment-card details are collected and processed directly by Stripe and are not stored by JNH Developers, although we may receive limited payment-method information, such as the card type and last four digits, where made available by Stripe.

Unless an app-specific notice says otherwise, our Apps do not provide public profiles, chat or a facility for users to upload and publish user-generated content.

5.2 Information collected automatically

• device and app information, such as device type, operating system, app version, language, time zone and general region;
• online identifiers, such as IP address, an app installation identifier, IDFV and, only where law and platform rules permit, IDFA or AAID;
• usage information, such as app launches, sessions, screens or features used, interactions and progression events;
• diagnostic and performance information, including crash logs and error data; and
• attribution information in General-Audience Apps, but only after any required consent or platform permission.

We do not collect precise geolocation, contacts, photographs, microphone recordings or other sensitive device data unless a specific feature needs it and the app provides a just-in-time notice and obtains any permission required by the device or applicable law.

5.3 Analytics, attribution and tracking; no in-app advertising

We use analytics and attribution services in General-Audience Apps to understand app performance, measure user acquisition, evaluate the effectiveness of external marketing campaigns and improve features. General-Audience Apps do not display third-party advertising, including contextual, targeted or personalised advertising.

With the user’s prior permission through Apple’s AppTrackingTransparency framework, and where permitted by applicable law, we and our attribution partners may access the device’s advertising identifier (IDFA) and link information collected from the App or device with information from apps, websites or services operated by other companies. This constitutes tracking and is used to attribute installations and measure the effectiveness of external advertising campaigns. We do not use this information to display advertising within our Apps.

Users may refuse permission or subsequently withdraw it through their device settings under Settings → Privacy & Security → Tracking. If permission is refused or withdrawn, we do not access the IDFA or conduct tracking that requires AppTrackingTransparency permission. Refusing or withdrawing permission does not prevent access to App features that do not require this processing.

In General-Audience Apps distributed through Google Play, and only where permitted by applicable law, we and our attribution partners may process the Android Advertising ID (AAID) and other permitted attribution signals to attribute installations and measure external marketing campaigns. Where consent is required, this processing is not enabled before consent is obtained. We do not use this information to display advertising within our Apps.

The practices described in this section apply only to General-Audience Apps. We do not access IDFA/AAID or conduct cross-app or cross-website tracking in Kids Apps.

6. Website and communications

When you visit jnhdevelopers.com, our servers or service providers may process IP address, browser and device information, requested pages, timestamps, referring page and security logs. We use essential cookies needed to operate and secure the website.

With any consent required in your location, we may also use analytics or similar technologies to understand website use. Non-essential tags are not activated before consent where prior consent is required. You can change your choices through toreynos@jnhdevelopers.com.

When you email us or submit a support request, we process your email address, message, attachments and related technical information to respond, investigate problems, protect our rights and keep an appropriate record of the communication.

7. Purposes and legal bases

Where the EU GDPR, UK GDPR or similar law applies, we rely on the following legal bases:

Where we rely on legitimate interests, we consider the nature of the data, reasonable expectations, potential effects on users and additional protections. The best interests of the child are a primary consideration for Kids Apps. We do not rely on legitimate interests to override consent requirements or platform restrictions.

8. Service providers and other disclosures

We disclose personal data only as needed for the purposes described in this Policy and subject to appropriate contractual and technical safeguards. Recipients may include:

• hosting, cloud infrastructure, crash reporting, security and technical-service providers;
• analytics and attribution providers used only in the App categories and configurations described below and, where applicable, in the relevant app-specific notice;
• Apple App Store and Google Play for distribution, purchases, subscriptions and fraud prevention;
• customer-support providers where an adult contacts us;
• professional advisers, auditors, insurers, regulators and public authorities where legally necessary; and
• a purchaser or successor in a corporate transaction, subject to applicable notice and protection requirements.

Our current technical providers include:

Adjust (Adjust GmbH): we use Adjust for mobile attribution and conversion analytics in both Kids Apps and General-Audience Apps, subject to different configurations and safeguards depending on the App category.

In Kids Apps, the Adjust SDK is integrated into the configurations for children’s apps: third-party data transfer is disabled until the first session, access to advertising and device identifiers (IDFA, AAID, Android ID) is blocked at the assembly level, the AD_ID permission is not requested, and the AppTrackingTransparency and AdSupport frameworks are not included in children’s builds. Attribution in iOS apps is performed via SKAdNetwork/AdAttributionKit, using aggregated data provided by Apple. We do not use Adjust in Kids Apps for behavioural profiling, retargeting, personalised advertising, cross-app or cross-website tracking, or the creation of advertising profiles.

In General-Audience Apps, Adjust may process installation and acquisition-source information, campaign data, app-interaction and conversion events, purchase and subscription events, device and App information, and app-scoped identifiers. Where permitted by applicable law and platform rules, and only after any required consent or platform permission has been obtained, Adjust may also process IDFA or AAID for attribution and campaign measurement. Adjust data is not used to display third-party advertising within our Apps.

AppsFlyer (AppsFlyer Ltd.): we use AppsFlyer for mobile attribution and purchase and conversion analytics in both Kids Apps and General-Audience Apps, subject to different SDK versions, configurations and safeguards depending on the App category. We do not use AppsFlyer data to make decisions that determine an individual user’s access to an App, content, purchases or other rights.

In Kids Apps, we use the AppsFlyer Strict Mode SDK and child-protective configuration. The Strict Mode SDK removes IDFA collection functionality and the AdSupport framework from the relevant builds. Access to IDFA, AAID and other advertising identifiers is disabled, and the Android AD_ID permission is not requested or is removed, as applicable. AppsFlyer may process limited installation, attribution, app-interaction, purchase or subscription events without advertising identifiers, solely to measure acquisition sources, conversions and campaign performance. We do not use AppsFlyer in Kids Apps for behavioural profiling, retargeting, personalised advertising, cross-app or cross-website tracking, or the creation of advertising profiles.

In General-Audience Apps, we use the standard AppsFlyer SDK. AppsFlyer may process installation and acquisition-source information, campaign data, app-interaction and conversion events, purchase and subscription events, device and App information, and app-scoped identifiers. Where permitted by applicable law and platform rules, and only after any required consent or platform permission has been obtained, AppsFlyer may also process IDFA or AAID for attribution and campaign measurement. We use the resulting analytics to compare traffic sources and adjust marketing expenditure at campaign or source level. AppsFlyer data is not used to display third-party advertising within our Apps.

AppMetrica (Air Smart Advertising Solutions FZ-LLC): we use AppMetrica in both Kids Apps and General-Audience Apps, with different data-collection configurations depending on the App category.

In Kids Apps, AppMetrica is limited to predefined app-interaction events, such as screens or features used and buttons selected, together with error reports, crash information and high-level installation and conversion statistics. We use this information solely to understand how the App functions, diagnose technical problems, measure reliability and improve its features.

In Kids Apps, AppMetrica is configured not to collect or transmit IDFA, AAID or other information capable of identifying a child or their device. Behavioural profiling, retargeting, personalised advertising and cross-app or cross-website tracking are disabled. AppMetrica data from Kids Apps is not used to create advertising profiles or target advertising.

In General-Audience Apps, AppMetrica may additionally be used for acquisition attribution and conversion measurement. Advertising identifiers are processed only where permitted by applicable law and platform rules and after any required consent or platform permission has been obtained.

Google Analytics for Firebase (Google LLC): analytics, acquisition attribution and purchase analysis in General-Audience Apps. Depending on the App and platform, the service may process app-interaction events, installation and acquisition-source information, campaign data, purchase and subscription events, device and app information, and app-scoped identifiers. Kids Apps uses only Firebase Crashlytics for crash reporting and stability diagnostics. Google Analytics for Firebase is not included in the children’s builds. Advertising identifiers are not transmitted to Firebase from children’s apps; user analytics collection and attribution are not performed by Firebase in Kids Apps.

Stripe and its relevant affiliates: payment processing for purchases and subscriptions made through our website, subscription administration, payment authentication, fraud prevention, refunds and transaction reporting. Stripe may process payment-method details, billing and contact information, transaction information, device and network information, and other data required to complete and secure a payment. JNH Developers does not receive or store full payment-card details.

Opt-Out & Store Controls:

• Apple iOS: Settings → Privacy & Security → Tracking — disable tracking per app.
• Google Android: Settings → Privacy → Ads — reset/delete Advertising ID.

We do not sell children’s personal data or disclose it for targeted advertising, cross-context behavioural advertising or data brokerage. We may disclose limited Kids App technical data to service providers acting on our behalf where necessary for permitted internal operations, subject to contractual and technical safeguards. We do not permit providers to use Kids App data for their own advertising profiles.

9. International transfers

We are established in the United Kingdom. Some providers may process data in countries outside the European Economic Area or the United Kingdom. Where required, we use an adequacy decision, the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum or another lawful transfer mechanism, together with supplementary measures where appropriate. You may contact us for information about the relevant safeguards.

10. Retention

We retain personal data only for as long as needed for the stated purpose, to comply with law or to establish, exercise or defend legal claims. We maintain a written retention schedule and periodically delete or irreversibly anonymise data that is no longer required.

Backups are protected and deleted or overwritten on a defined cycle. If deletion from a backup is not immediately practicable, the data remains isolated from ordinary use until the backup is overwritten, unless restoration is required for security or disaster recovery.

11. Security

We use administrative, technical and organisational measures appropriate to the nature of the data and the risks, including access controls, data minimisation, secure development and vendor review. We use encryption in transit where supported and appropriate protection for stored data. No system is completely secure, and we cannot guarantee that unauthorised access or loss will never occur.

12. Your choices and controls

• Device permissions can be changed in the operating-system settings.
• Tracking permission for a General-Audience iOS App can be changed in iOS Privacy & Security settings.
• Website cookie choices can be changed at toreynos@jnhdevelopers.com.
• You may withdraw consent at any time, without affecting processing that occurred lawfully before withdrawal.

12.1 Automated decision-making

We do not make decisions about users based solely on automated processing, including profiling, that produce legal effects concerning them or similarly significantly affect them within the meaning of Article 22 of the GDPR. Analytics and attribution data may be used to evaluate Apps, campaigns, audience groups or traffic sources and to inform general product and marketing decisions, such as the allocation of advertising budgets. These activities do not determine an individual user’s legal rights, access to the Services, eligibility for a purchase or subscription, or other similarly significant matters.

If we introduce automated decision-making of this kind in the future, we will provide the information and safeguards required by applicable law, including information about the logic involved, the significance and expected consequences of the processing, and any applicable right to obtain human intervention, express a point of view and contest the decision.

13. Privacy rights

Depending on where you live, you may have rights to request access to personal data, correction, deletion, restriction, portability, objection to processing, withdrawal of consent and information about data disclosures. You may also have the right not to be discriminated against for exercising a privacy right.

Send a request to toreynos@jnhdevelopers.com with enough information for us to identify the relevant App, device or support interaction. We may ask for information reasonably necessary to verify the request. An authorised agent may submit a request where permitted by law, subject to proof of authority. We will not ask for more verification data than reasonably necessary.

Parents and legal guardians may request access to or deletion of personal data collected from their child and may refuse further collection or use. Because Kids Apps do not use child accounts, we may need the app name, platform, device-side identifier or purchase reference to locate a record, and in some cases we may hold no data that allows us to identify a particular child.

You may complain to the UK Information Commissioner’s Office at https://ico.org.uk. We encourage you to contact us first so that we can try to resolve the issue.

13.1 Addendum for UK residents (UK GDPR representative)

If you are a resident of the United Kingdom, the UK General Data Protection Regulation (UK GDPR) applies to the processing of your personal data.

TOREYNOS LIMITED is a company organized and existing under the laws of England and Wales and acts as the Data Controller.

If you have any questions about how we handle your personal data, or if you wish to exercise your data subject rights (such as the right to access, delete, or restrict your data), you can contact our UK Representative directly:

UK Representative Name: BRAINYTRAINEE LTD
Postal Address: Office 34a, Business Centre, 9 Lydden Road, London, United Kingdom, SW18 4LT
Dedicated Email Address: business@brainytrainee.com

Our UK Representative is authorized to act on our behalf and serve as a direct point of contact for UK users and the Information Commissioner’s Office (ICO) regarding all matters related to UK GDPR compliance.

14. United States children’s privacy

For child-directed Services covered by the U.S. Children’s Online Privacy Protection Act, we provide notice and obtain verifiable parental consent before collecting, using or disclosing a child’s personal information unless a specific legal exception applies. Information collected under an internal-operations exception is used only for the permitted operational purpose and is not used for behavioural advertising or unnecessary profiling.

Where consent to disclosure is required, a parent may consent to collection and use without consenting to disclosure to third parties, except where disclosure is integral to the requested service. We maintain a written data-retention policy for children’s personal information and delete such information when it is no longer reasonably necessary for the purpose for which it was collected.

15. California and other U.S. state disclosures

If a U.S. state privacy law applies to JNH Developers and to the relevant processing, residents may exercise the rights provided by that law. In the preceding 12 months, the categories of personal information we may have collected are identifiers, internet or electronic-network activity, commercial information relating to purchases, approximate location, and inferences limited to app use in General-Audience Apps. We collect these categories from users, devices, app stores and the service providers described above for the purposes in Section 7.

We do not sell or share personal information. We do not knowingly sell or share personal information of consumers under 16.

Where applicable, we honour legally recognised opt-out preference signals for browser-based activity. To exercise a right to know, correct, delete, opt out of sale or sharing, limit use of sensitive information, or appeal a decision where provided by law, contact us using Section 18 or use toreynos@jnhdevelopers.com.

16. Children outside the United States

We apply child-protective defaults in Kids Apps regardless of location. Where local law requires parental authorisation for an information-society service offered directly to a child, we do not use consent as the legal basis for optional processing until the required authorisation has been obtained. We also take account of applicable age-appropriate-design requirements, including high-privacy defaults, data minimisation and restrictions on profiling and geolocation.

17. Changes to this Policy

We may update this Policy to reflect changes in our Services, data practices or law. We will update the date at the top. If a change materially affects how we use personal data, we will provide appropriate advance notice through the App, website, store listing or other reasonable means and obtain consent where required. We will not treat a child’s continued use as parental consent.

18. Contact us

Questions, privacy requests and parental enquiries may be sent to toreynos@jnhdevelopers.com or by post to TOREYNOS LIMITED, Office 14921, 182-184 High Street North, East Ham, London, United Kingdom, E6 2JA. Telephone: +44 7700 161582.