MindMatch Lingo Privacy Policy

1. Scope and operator

This Privacy Policy applies to the MindMatch Lingo mobile application offered by LOKUP, including the iOS and iPadOS versions distributed through the Apple App Store and the Android version distributed through Google Play. In this Policy, “application,” “LOKUP,” “we,” “us,” and “our” are used within this scope.

LOKUP is the operator responsible for the data practices described in this Policy. You may contact us about privacy matters at info@lokup.io. Our official website is https://lokup.io.

This Policy does not replace the separate privacy practices of Apple, Google (including Google AdMob), the device manufacturer, the mobile operating system provider, or the text-to-speech provider selected on the device.

2. Children’s privacy

MindMatch Lingo is an educational application for children and families, and it may also be used by older players. The product is designed around data minimization and a high level of protection for children. The current version:

• does not require a child or parent to create an account;
• does not ask for a child’s name, date of birth, email address, or another direct identifier; it asks only for an age range once, as described in section 3;
• shows children and players of unknown age only child-directed, non-personalized ads, and only when the player chooses to watch an optional video;
• does not offer chat, messaging, public profiles, social networking, purchases, or another feature through which a child can publish content;
• does not send gameplay or profile information to a server operated by LOKUP.

LOKUP does not knowingly collect a child’s personal information through the application. If a parent or legal guardian believes that information relating to a child has been sent to us, the parent or guardian may contact us at info@lokup.io. After the request is verified, we will review the information and delete it where required by applicable law.

3. Age question and kids mode

Before the first game, the application asks the player’s age once, using neutral age ranges (4–5, 6–8, 9–12, 13–15, 16–17, and 18+). Nothing is preselected and the screen does not say what each answer unlocks. Only the resulting group, under 13 or 13 and older, is stored on the device. The age is not sent to LOKUP.

Kids mode applies to players under 13, to players whose age is unknown, and whenever a parent turns it on in the Parent Panel. A parent can turn kids mode off only after confirming that the device is used by someone aged 13 or older.

4. Advertising (Google AdMob)

When the bomb runs out in a timed round (the Speed Series and Endless Mastery), the application may offer an optional video ad. The video gives 10 more seconds on the same board, or 15 seconds on the largest boards (11 or 12 pairs of cards). In Turbo Streak, when all three lives are lost, the application may offer an optional video that gives one more life on the same board. A player can watch at most one video per round. The reward is given if the video has been on screen for at least 5 seconds, even if the player closes it early. There are no other ads: no banners, no ads at launch, and no ads in quizzes or stories. A video is offered only when the device is online and an ad has loaded.

• In kids mode, ad requests are tagged as child-directed and as under the age of consent, and are limited to content rated for general audiences (G). These ads are not personalized, neither the consent form nor Apple’s tracking permission prompt is shown, and the application does not send the Android advertising ID or Apple’s IDFA for these requests.
• For players 13 and older, general ads may be shown. On Android, Google may personalize these ads if the player agrees through Google’s consent form, which is shown where the law requires it (for example in the European Economic Area, the United Kingdom, and Switzerland). Where the form is shown, the player can change that choice at any time in Settings under “Ad privacy choices”. On iOS and iPadOS, the same consent form is shown where the law requires it, and the application then asks once for Apple’s permission to track (App Tracking Transparency). Ads there are personalized only if the player allows tracking; otherwise only non-personalized ads are requested. The player can change this answer at any time in the iOS Settings app under Privacy & Security > Tracking.
• To deliver ads, prevent fraud, and measure ad performance, Google may process device and connection information such as the IP address, device model, operating-system version, the application identifier, and interactions with the ad. For players 13 and older on Android, this may include the advertising ID. Google processes this information under its own policies: Google Privacy Policy and How Google uses information from sites or apps that use its services.
• In the PIN-protected Parent Panel, a parent can switch rewarded videos off entirely, in which case the application shows no ads at all, and can keep kids mode on for the device.

LOKUP does not receive the information Google processes to deliver ads, and does not use ads data to build profiles of players.

5. Information processed and stored only on the device

The application may process the following information locally on the user’s device in order to operate and maintain the learning experience:

This information is not associated with a LOKUP account, is not transmitted to a LOKUP server, and cannot be viewed remotely by LOKUP. The six-digit parent PIN is not stored in plain text: it is derived on the device with a random salt and a one-way key derivation function (PBKDF2). The derived value is kept in the operating system’s secure storage (Keychain on iOS, Keystore-protected storage on Android), with a copy in the application’s private storage so that the parent is not locked out if secure storage becomes unavailable. LOKUP cannot view or remotely recover the PIN.

6. Information we do not collect through the application

The application does not transmit the following categories of information to LOKUP, and LOKUP does not collect them through the application:

• name, surname, username, date of birth, email address, telephone number, or postal address;
• precise location;
• contacts, address book entries, calendar entries, or message content;
• photos, videos, audio recordings, camera data, or microphone data;
• health, biometric, or sensitive personal information;
• school, class, teacher, or student identification information;
• payment, banking, or purchase information;
• chat messages, user-generated content, or social connection information;
• analytics or behavioral profile information operated by LOKUP.

The ad-related processing performed by Google is described in section 4. Apple, Google, the device manufacturer, or the operating system provider may also independently process certain technical information when providing store access, downloads, device security, or their own services.

7. Purposes and legal grounds for processing

Local processing on the device is necessary to provide the game and educational functions requested by the user, remember selections, maintain learning progress, apply accessibility preferences, decide which kind of optional video may be offered, and operate parental controls. Because this information is not transmitted to LOKUP, LOKUP does not create a server-side user profile.

Optional rewarded videos are offered to fund the free application. Where the law requires consent for personalized advertising, such ads are shown only to players 13 and older who agree through Google’s consent form (and, on iOS and iPadOS, allow tracking); otherwise only non-personalized ads are requested.

If you contact us by email, we process the communication to respond to the request, comply with legal obligations, and establish, exercise, or defend legal rights. Depending on the applicable law and circumstances, this processing may be based on steps necessary to address the request, legitimate interests balanced against individual rights, compliance with a legal obligation, or consent where consent is required.

8. Text-to-speech, recordings, and music

MindMatch Lingo pronounces words with recordings bundled with the application or with the text-to-speech service available on the device. Where possible, the application prefers a voice installed for offline use on the device.

If the selected operating system or text-to-speech provider uses an online voice, the limited word or phrase to be spoken may be processed by that provider’s service. This depends on the provider’s technical design, the device settings, and the provider’s own privacy terms. LOKUP does not receive, retain, or use that text for any other purpose.

Background music is bundled with the application and plays locally. It can be turned off with the speaker button on the home screen.

9. Apple App Store, Google Play, and operating system services

The store from which the application is downloaded and the device operating system may independently process account, download, store transaction, device, security, diagnostic, or crash information in order to provide their own services. This is not data collection performed by the MindMatch Lingo application and is governed by the relevant Apple or Google privacy policy.

Apart from the Google Mobile Ads SDK and Google’s User Messaging Platform for the consent form described in section 4, MindMatch Lingo does not integrate third-party analytics, tracking, or crash reporting software development kits.

10. Application permissions and technical access

Android

The Android version declares the following permissions. None of them shows a permission prompt, and the application does not request location, camera, microphone, contacts, or storage access.

• Internet and network state: to load the optional videos and Google’s consent form;
• Vibration: for game feedback;
• Advertising ID and Android’s privacy-preserving advertising APIs (AD_ID and ACCESS_ADSERVICES): declared by the Google Mobile Ads SDK; in kids mode the advertising ID is not sent with ad requests;
• Wake lock and foreground service: declared by the Google Mobile Ads libraries and the Android background-task library (WorkManager) they include;
• Biometric and fingerprint: declared by the secure storage library that keeps the parent PIN; the application does not use biometric authentication.

iOS and iPadOS

The iOS and iPadOS version does not request location, camera, microphone, or contacts permission. It asks for Apple’s tracking permission (App Tracking Transparency) only from players 13 and older outside kids mode, as described in section 4. The application and its frameworks may access file timestamp, user defaults, and system boot time interfaces locally for essential operation; these required-reason API categories are declared in the iOS privacy manifests, and the Google Mobile Ads SDK includes its own privacy manifest.

If permissions change in a future release together with application functionality, the relevant store disclosures and this Policy will be updated before the changes are made available.

11. Sharing, sale, and international transfers

LOKUP does not sell or rent user or child information, and does not share it for behavioral advertising or cross-application tracking. When an optional video is requested, the information described in section 4 is sent directly from the device to Google, which may process it in countries other than your own under its own safeguards. Because LOKUP does not operate a server for application data, there is no server-side international transfer of application data by LOKUP.

Apple, Google, the device manufacturer, a hosting provider, an email service, or the selected text-to-speech provider may independently process and transfer information in connection with its own services. Those providers’ activities are governed by their policies and applicable data protection laws.

12. Retention, deletion, and backups

Local learning and settings information remains on the device until a parent clears it within the application, uses the operating system’s option to clear application data, or uninstalls the application. The clear-learning-progress function preserves preferences and the parent PIN so that settings and parental controls continue to operate. To remove all local application information, use the operating system’s clear application data option where available or uninstall the application.

Cloud backup and device-to-device transfer of application data are disabled in the Android version. On iOS and iPadOS, local information may be included in a device or iCloud backup depending on the family’s Apple settings. Apple and the user manage those backups. LOKUP cannot access or remotely delete them. Information processed by Google for ads is retained under Google’s policies linked in section 4.

Communications sent to us by email are retained only for as long as reasonably necessary to respond to the request and meet applicable recordkeeping obligations. They are then deleted or anonymized unless a longer period is required by law.

13. Information security

LOKUP applies measures including data minimization, on-device storage, the mobile operating system’s application sandbox, one-way derivation of the parent PIN, attempt limits with temporary locks for the PIN, encrypted connections to the internet only (unencrypted HTTP traffic to the internet is disabled on Android and iOS), and disabling Android backups. Not transmitting application information to LOKUP servers materially reduces exposure to remote data breaches.

However, no device, software, or storage method can provide absolute security. The device passcode, operating system updates, backup settings, and physical access to the device remain under the control of the parent or device owner.

14. When you contact us

If a parent or another user sends us an email, we receive the sender’s email address, the message content, the date, and necessary technical email headers. We use this information only to respond, provide support, investigate security or legal matters, and retain records where required.

We recommend that children do not email us directly and that communications be handled by a parent or legal guardian. Please do not send a child’s name, photograph, voice recording, school information, or other personal information unless it is strictly necessary for the support request.

15. Policy webpage and cookies

The MindMatch Lingo application does not use browser cookies. This policy page does not contain advertising, analytics, social media trackers, external web fonts, or third-party tracking scripts, and the page does not set browser cookies.

The website’s hosting and security infrastructure may temporarily process standard server logs, such as IP address, access time, requested page, and browser type, to deliver the page and prevent abuse. Data practices in other areas of the LOKUP website may be governed by separate notices presented on those pages.

16. Privacy rights of parents and users

Depending on applicable law, users and a child’s parent or legal guardian may have the right to ask whether personal information is processed; request information and access; request correction of inaccurate information; request deletion or destruction; restrict or object to processing; withdraw consent; and lodge a complaint with a competent data protection authority.

Individuals in Türkiye may exercise the rights provided by Article 11 of Law No. 6698 on the Protection of Personal Data. Individuals in the European Economic Area or the United Kingdom may exercise rights available under the applicable GDPR or UK GDPR. Rights under local law apply in other regions.

Because application information is not sent to LOKUP, LOKUP cannot access local progress information, associate it with your identity, or delete it remotely. Choices concerning local information and ads can be made directly in the application (the Parent Panel’s kids mode and rewarded video switches) or in the device settings. For information processed by Google for ads, see the Google policies linked in section 4. For an email or another record previously sent to us, submit a request to info@lokup.io. We may request only the information reasonably necessary to verify identity and authority.

17. Changes to this Policy

We may update this Policy when application functionality, data practices, or legal requirements change. The current version will be published at https://lokup.io with a new effective date. Before introducing a feature that materially changes the processing of children’s personal information, we will complete the required store disclosures, parental notices, and applicable consent procedures.