Privacy policy

Two ways to play: a profile under the tutor's account, or the child's own account

Model A (default): the adult creates the account and, inside it, a child profile with a nickname and avatar from a fixed list; the child has no account or email of their own. Model B: if the child already has their own Google account, they can sign in themselves; in that case they do have an account and email, handled by Firebase Authentication just like the adult's account, though in Firestore we never store their email, name or photo. On the consent screen there is a checkbox "I confirm I am an adult": with email-and-password sign-up it is mandatory, because that account is always an adult's; with Google it decides the account type — ticked, an adult account; left unticked, the child's own account. It is a self-declaration, a reasonable-effort measure, not strong identity or age verification; in Model B the adult's involvement also relies on the child's Google account being supervised by an adult (ideally through Family Link). The adult challenge (a simple arithmetic question) is no longer part of sign-up: it is only asked to open the adult panel. In its place, in Model B, before the child's own account is created a notice is shown asking to show it to an adult who needs to agree; it is a reasonable-effort notice, not a verification. The child's progress (streak, stars, badges, preferences) is always stored on the device itself; the local-latch PIN (Model A only) never leaves the device. If there was already progress stored on the device before creating the account, it is automatically transferred to the cloud without loss when the first profile is created, with a warning beforehand. A profile can also be the adult's own, to try the app; it is stored like any other profile, with no identifying data.

What data we process

Only if there is an active account (Model A or B):

• The adult's email and password, or the email/name/photo of the adult's or child's Google account when signing in with Google. These are handled by Firebase Authentication (Google); we never see or store a password in clear text.
• The child profile's or child account's learning progress, and their nickname and avatar (chosen from a fixed list), to save and sync them in Cloud Firestore (European region). For the child's Google account, Firestore only stores a technical identifier, never their email, name or photo.
• Current status: all of this is already built in code; there is no effective processing of any real user's data until a real Firebase project exists.

What data we do NOT process

We never process the following:

• In Cloud Firestore, no identifying data: no real name, birth date, photo, voice or email — the adult's or the child's. The nickname comes from a fixed list.
• The child's PIN is never stored in the cloud in any form; it lives only on the device (Model A only).
• Neither the adult's email nor the child's (Model B) is copied into the progress database: both reside only in Firebase Authentication.
• The sign-in diagnostic log (what you see under "More details" when signing in fails) stays in the tab's own memory: it holds no email, account identifier or passwords, it is never sent to any server, and it is discarded when the tab closes.
• We use no analytics, third-party advertising, trackers, or third-party cookies for commercial purposes. One security exception: Google reCAPTCHA v3 protects accounts against automated abuse; it is not used for analytics or advertising purposes.

Legal basis and consent

Model A: consent and control rest with the responsible adult, not the child; the adult gives informed consent, and confirms being an adult, before anything is saved in the cloud. Model B: the child themselves signs in with their Google account and accepts the consent screen; inside the app there is no longer an adult challenge at sign-up, but before their account is created a notice addressed to the adult is shown (show the screen to the parent or guardian, who need to agree, with a Family Link recommendation and an option to go back and tick the checkbox), closed with a self-declaration button ("an adult has seen this"). That notice is a reasonable-effort measure, not a verification: it is pressed by whoever holds the device. So the adult's involvement additionally relies on that Google account being supervised by an adult (ideally through Family Link), something the app cannot verify on its own. Whether that reliance suffices as valid parental consent or authorisation for a minor's own account (GDPR Art. 8, Spain's LOPD-GDD Art. 7) is a point pending confirmation by a qualified legal professional, not automated review alone; for that reason Model B is not exposed to real users until that confirmation. The app targets children below the age of digital consent (14 in Spain, Art. 7 LOPD-GDD), so processing relies on the responsible adult's consent (Art. 6(1)(a) and 6(1)(b) GDPR). There is no profiling, automated decision-making or advertising directed at minors.

Where data is stored and international transfers

Progress and child profiles are stored in Cloud Firestore in a European region and do not leave the European Economic Area at rest. The adult's email and, in Model B, the child's Google account email/name/photo are handled by Firebase Authentication, which runs on Google's global infrastructure and cannot be pinned to an EU region: that may involve an international transfer of that data. Google acts as processor under its Data Processing Addendum, with the Standard Contractual Clauses (SCCs 2021) and, where applicable, the EU-US Data Privacy Framework. Firestore, in turn, never stores that identifying data: only a technical identifier.

Hosting of the web version

The app can be used installed on Android or straight from a browser, at repasosdeprimaria.mrgnlabs.com. The web version is served from Cloudflare, which acts as hosting processor: it handles technical connection data (IP address, browser type, date and time of the request) for a limited time, in order to deliver the page and protect it from abuse. We use no analytics or advertising cookies, and that technical data is never combined with the account or the progress. Information pages like this one are static HTML and run no code in the browser. Apart from hosting, the web version processes exactly the same data as the installed app.

Retention and deletion

Data is kept while the adult account exists. From Settings, the "Reset my progress" option sets stars, streak, badges and completed exercises in every grade back to zero, but keeps the character, the nickname and the language chosen per subject: it resets progress, it does not delete the account. To delete the account entirely you can use Settings → Account → "Close account": after an adult check and signing in again, all of the account's cloud data (profiles and progress), the sign-in user and then whatever the account left on this device are deleted immediately and irreversibly. Once deletion is ordered, the providers that process data on our behalf (Firebase Authentication and Cloud Firestore, by Google) may take some time to remove it from their systems and backups, in line with their timeframes and their data processing agreement. Deleting a specific child profile without closing the whole account is not yet available inside the app; in the meantime, to erase only that profile you can request it from the controller (see "Contact") and it will be handled as an exercise of the right to erasure.

Your rights

The responsible adult may exercise over their account data the rights of:

• Access, rectification and erasure (right to be forgotten).
• Restriction, objection and portability.
• Withdrawing consent at any time, without affecting processing carried out before; in practice, by closing the account.
• Lodging a complaint with the Spanish Data Protection Agency (AEPD), www.aepd.es.

Security

Each account can only access its own data (Firestore security rules). Writing to the cloud requires prior email verification (for email-and-password sign-up). Access to the adult panel is protected by a parental gate — an adult challenge, a simple arithmetic question that a primary-school child will not solve from memory; signing out no longer asks for it. Personal data is minimised: the email lives only in Firebase Authentication and the latch PIN (Model A) only on the device.

Advertising and funding the app

Repasos de Primaria is free. To help cover its costs (servers and store publishing), the app reserves a few spaces at the end of some screens. Today we show no third-party advertising: these spaces show only our own content —tips on using the app and, on adult-facing screens, messages about how the app is funded— and process no personal data (no ad networks, no trackers, no third-party code, no profiling). We never show advertising inside the exercises, nor on the celebration or results screens, nor during sign-up, consent, the account, the legal pages or the printable worksheets, nor in a child's own account or child profiles: if it ever exists, advertising will only be directed at adults, on adult-facing screens. If we activate third-party ads in the future, they will be non-personalized and contextual, from ad networks certified by Google for families' apps, and clearly labelled as "Ad"; beforehand we will update this policy, its date and version, inform you and, where legally required, ask for your consent.

Contact

You can raise any privacy question, or exercise your rights (access, rectification, erasure, objection, restriction and portability), by writing to info@mrgnlabs.com. If this policy changes, we will update its date and version and, when the change is substantial, we will ask for the adult's consent again.