Last updated: 10.10.2025
General information
ALPA Kids may collect personal data about users of the websites and other domains operated by ALPA Kids and about users of our iPhone and Android mobile applications (“ALPA Kids Platform”). The collection and use of personal data allows us to provide you with the services offered through the ALPA Kids Platform, including ALPA Kids digital learning games, for the purpose of providing ALPA Kids games and courses targeted at users, as well as to enable you to purchase products offered through the ALPA Kids online store, to subscribe to digital learning games and other services offered through the ALPA Kids Platform, and to provide you with a better user experience on the ALPA Kids Platform. ALPA Kids collects and uses personal data in accordance with this Privacy Policy (“Privacy Policy”), which describes, among other things, the types of personal data that ALPA Kids collects, the purposes for which we use that data, and who has access to the personal data.
The ALPA Kids Platform Privacy Policy has been prepared and personal data are processed in accordance with the General Data Protection Regulation (EU) 2016/679 and the Personal Data Protection Act of the Republic of Estonia.
Please read this Privacy Policy attentively as it contains, among other things, important information about your rights as a data subject.
Controller
The controller of your personal data is ALPA Kids OÜ, registry code 14547512, address: Kadaka 63 (Gamedev Estonia), Tallinn 12915, Estonia (“ALPA Kids” or “we” or “us”).
1. What data do we collect and how do we use it?
For the purposes of this Privacy Policy, “personal data” means any data relating to an identified or identifiable natural person.
1.1 ALPA Kids Platform usage data
We continue to develop and improve the ALPA Kids Platform, the digital learning games offered and strive to make them more user-friendly and enjoyable. To do this, we need to know which information and digital learning games are of the greatest interest to users of the ALPA Kids Platform, how often users visit and browse the ALPA Kids Platform, which web browsers and/or devices are used, etc.
When you visit the ALPA Kids Platform or use the digital learning games, certain data may be collected without your knowledge using various technologies such as cookies, web tags and web beacons, and navigation data (log files, server logs, clickstream data, website scripts). Some of this information is sent automatically by your web browser or mobile device – for example, the URL of the website you are browsing or have previously visited, the IP address of your computer or mobile device and the version of the web browser you are currently using – as well as the time you arrived at the ALPA Kids Platform and the websites you specifically visit on the ALPA Kids Platform.
We use tools and instruments provided by various partners to collect and analyse data on the use of the ALPA Kids Platform and the digital learning games we offer. For a list of our partners, see Section 2 of the Privacy Policy.
The legal basis for the collection of personal data is the performance of a contract or pre-contractual activity between us and you (or the company you represent) for the purpose of providing the services to you (or the company you represent) on the ALPA Kids Platform, or our legitimate interest where a contract has been or will be entered into between us and the company you represent, and/or our legitimate interest in further developing the ALPA Kids Platform and the services we provide.
1.2 Information related to creating a user account
To access and use certain services offered on the ALPA Kids Platform, we may ask you to create a personalised user account – either by using a chosen email address and password or by using authentication tools provided by third parties (such as Facebook, Google or Apple).
The legal basis for the collection of personal data is the performance of a contract between us and you as a natural person, or our legitimate interest where the contract is between us and a company you represent.
1.3 Information related to the learning path service
In order to access and use the personalised learning path service on the ALPA Kids Platform, you may be required to provide – in addition to the data necessary for creating a personalised user account as set out in Section 1.2 of the Privacy Policy (applicable if you do not already have a user account) – the nickname, age, gender and native language of the service user (primarily the child), for the purpose of creating a personalised avatar.
As part of the provision of the ALPA Kids Platform personalised learning path service, we will additionally collect digital learning game usage data from the service user’s interaction with the ALPA Kids Platform in order to enable ALPA Kids to conduct learning analytics to better understand, personalise and optimise the service user’s learning methods. In addition to the data set out in Section 1.1 of the Privacy Policy, the digital learning game usage data that we collect when providing the personalised learning path service includes information about the various choices you make both when choosing a particular digital learning game and within that particular game, the duration of the game, the results and other data related to the digital learning game.
We use tools and instruments provided by various partners to collect and analyse data related to the ALPA Kids Platform personalised learning path service, including usage data of the selected digital learning game. For a list of our partners, see Section 2 of the Privacy Policy.
The legal basis for the collection of personal data is the performance of a contract or pre-contractual activity between us and you (or the company you represent) for the purpose of providing the personalised learning path service to you (or the company you represent) on the ALPA Kids Platform, or our legitimate interest where a contract has been or will be entered into between us and the company you represent, and/or our legitimate interest in further developing the ALPA Kids Platform and the personalised learning path service we provide.
1.4. Audio recordings
Our digital learning games may include an audio recording feature. We may use audio recordings for various purposes. First, the purpose of the audio recording is to ensure the functionality of the interactive digital learning games on the ALPA Kids Platform. In such cases, we record the audio transmitted to your device, which means we also process the voice of the service user (primarily the child). Depending on the situation, we may also process the voices of individuals near you or the service user, which depends solely on who is physically close to the device while the game is being played. Audio recording only takes place within specific games; in all other cases, ALPA Kids does not record or store any audio transmitted to your device. The legal basis for audio recording is the performance of a contract concluded with you or, if you represent a company, our legitimate interest in enabling the functioning of digital learning games with audio recording on the ALPA Kids Platform and supporting the development of children’s speech skills through gameplay.
Second, if you, as the child’s legal representative, provide consent, we may also use the audio recorded by your child on the ALPA Kids Platform for further research and development related to children’s speech. Consent from the child’s legal representative for the use of audio recordings in research and development will be requested before the child plays any games that record audio for the first time. You can withdraw your consent at any time in accordance with Section 5 of the Privacy Policy. Your consent or refusal to grant consent will not affect the content or quality of the services provided on the ALPA Kids Platform. If you give or withhold consent, we may also process data that allows your device to be identified in order to ensure that you have the option to withdraw your consent.
1.5 Transaction data
When you place an order on and/or through the ALPA Kids Platform (for example, using the Google Play Store or App Store) for the purchase and use of a paid digital learning game, a personalised learning path service, or any other service or product offered on the ALPA Kids online store, we may collect data about your payments and transactions and other information related to the transaction, such as the first name and surname and the date of birth of the person placing the order, the name of the organisation being represented (if the order is placed on behalf of a legal entity), telephone number, email address and other contact details, payment method, bank account number and holder, bank name, delivery address and other relevant information relating to the order.
The legal basis for the collection of transaction data is the performance of a contract between us and you as a natural person, or our legitimate interest where the contract is between us and a company you represent.
We also process the personal data we collect to comply with our obligations under applicable accounting and tax laws. In this case, the processing of personal data is based on the legal provisions that require us to process personal data.
1.6 Queries and answers
If you send us a query via the ALPA Kids Platform, we will process your contact details and the content of the query in order to respond to it.
The legal basis for the collection of this data is our legitimate interest in responding to your queries about us and the services we provide.
1.7 Data relating to legal requirements
Where necessary, we may process personal data in order to pursue our legitimate interest in submitting, processing or defending legal claims arising out of any contract concluded between us and you (or the company you represent).
1.8 Direct marketing
If you consent to receive push notifications and/or emails from the ALPA Kids Platform mobile applications by entering your email address, we may use the push notifications of mobile applications and/or your email address to send you news, offers and other marketing communications.
The legal basis for sending you direct marketing content is your consent or our legitimate interest in promoting the ALPA Kids Platform and providing you with information about ALPA Kids and the services offered on the ALPA Kids Platform. You have the right to withdraw your consent to receiving direct marketing materials at any time by contacting us by email at info@alpakids.com and/or by opting out of receiving push notifications on the ALPA Kids Platform mobile application. You may also opt out of the use of your email for direct marketing by clicking the unsubscribe link in the message you have received from us.
1.9 Cookies
What are cookies?
Cookies are small text files that the ALPA Kids Platform may store on your device during your visit. Cookies can be used to remember your choices and preferences to make it easier for you to use the ALPA Kids Platform, so that you do not have to re-enter them on each visit or each website.
What kind of cookies do we use?
The ALPA Kids Platform uses cookies to store your IP address and browsing information, including information about the websites you visit and the time you spend on them, as well as information about the device you use and your preferences for using the ALPA Kids Platform.
We also use cookies to track web traffic, application and user activity on the ALPA Kids Platform – we use this information to analyse visitor behaviour and provide a better user experience.
Cookies help us:
provide you with a better user experience when visiting the ALPA Kids Platform;
- enable you to set personal preferences;
- collect statistics on the use of the ALPA Kids Platform; and
- measure the effectiveness of advertising.
- We use the following types of cookies on the ALPA Kids Platform:
Functionality cookies
Functionality cookies are necessary to enable you to navigate the ALPA Kids Platform and use its features. Functionality cookies are used in our applications, for example, to remember your user account login details.
Statistics cookies
Statistics cookies collect anonymous statistics about how users use the ALPA Kids Platform mobile applications. Statistics cookies can, for example, help us understand how users browse and use the ALPA Kids Platform mobile applications and which parts of it are most used. Statistics cookies are stored on your device and used only with your consent.
How long will cookies stay on my device?
Cookies fall into two categories, depending on how long they stay on your device.
Session cookies
Session cookies are only created for the duration of the session and are kept on your device until you close the browser or mobile application. Session cookies are not stored on your device’s hard drive.
Persistent cookies
Persistent cookies are stored on your hard drive until you delete them or they expire. We can retain data from persistent cookies for a maximum of 2 years.
Cookies will only be stored on your device with your consent, except for cookies that are only necessary for the technical functioning of the ALPA Kids Platform. Please note, however, that if you do not consent to the use of cookies, you may not be able to use certain features of the ALPA Kids Platform.
Please also be advised that third parties (such as advertising networks and web traffic analysers and other external service providers) may use cookies over which we have no control.
How do I manage cookies?
You can manage and/or delete cookies at your discretion – see www.youronlinechoices.com for more details. You have the option to delete all cookies on your device and most web browsers can be set to refuse cookies. However, if you do so, certain preferences may need to be manually re-entered each time you visit and some services and features may not function.
2. Transfer and disclosure of personal data
We will do everything in our power to keep your personal data safe and we demand strict security and confidentiality from our employees and partners.
We may disclose your personal data:
– to our trusted service providers who provide services to us or to you as processors under our instructions. We will always control and be responsible for the use of your personal data;
– to public authorities, where required to do so by law or where a lawful request for information is made to us by a public authority; and
– in relation to our merger, acquisition or sale of our business or a part thereof.
As of the “last updated” date indicated in the header of this Privacy Policy, we use the following processors for the relevant purposes:
– Google Analytics, which provides us with analytics services to track users’ navigation and usage data on the ALPA Kids Platform mobile applications;
– AWS SageMaker, which provides us with an analytics service to analyse the usage data of a personalised learning path service user regarding their use of a specific digital learning game selected in the ALPA Kids Platform mobile application for learning analytics purposes;
– Facebook SDK, which provides us with a service to analyse user downloads of the ALPA Kids Platform mobile applications;
– Google Play Store, App Store and Maksekeskus AS, which provide us with payment services to enable you to make payments on and/or through the ALPA Kids Platform to subscribe to and purchase digital learning games, any services and products available in our online store.
We may further disclose your personal data:
– to ALPA Kids employees responsible for customer care and supporting customer relationships, as well as to employees in accounting, IT maintenance, business analysis and planning functions;
– to suppliers of the IT systems and cloud service providers we use to manage our customer interactions, and to our auditors;
– to banks;
– to our processors and other persons involved in the performance of the contract;
– to parties helping us to exercise our rights under the contract (debt recovery service providers, legal advisers, courts, credit reference agencies, etc);
– to parties involved in any merger, acquisition or sale of all or part of our assets.
– to organisations with whom we process personal data in our research and development work.
We do not transfer your personal data outside the European Union or the European Economic Area.
3. How long do we retain your personal data?
We will only retain your personal data for as long as necessary to achieve the purposes described in the Privacy Policy or as required by law. Most of your personal data will be retained until the end of the customer relationship between you and ALPA Kids, i.e. for as long as your ALPA Kids Platform user account remains active (if you have a user account). We may retain this data for up to 2 years after your ALPA Kids Platform user account has been deactivated.
For games that record audio on the ALPA Kids Platform, the recordings are deleted immediately after the game is played. If we use audio recordings for research and development purposes based on your consent, we will retain the recordings only for as long as necessary to carry out the research or until you withdraw your consent.
Certain personal data may be retained after the end of the customer relationship if required or permitted by applicable law. For example, we will keep basic accounting documents (such as copies of contracts and invoices) for 7 years from the end of the relevant financial year, as required by applicable law. We will retain your personal data relating to the contract for 10 years from the date of termination of the contract, subject to a maximum limitation period in case of intentional breach.
When the retention of your personal data is no longer required by law or necessary for the exercise of the rights or obligations of either party, we will permanently delete your personal data, unless you have instructed us otherwise and we have entered into an agreement for longer-term data retention.
4. Updating the Privacy Policy
We may update this Privacy Policy from time to time. We will notify you on the ALPA Kids Platform when we update the Privacy Policy. This Privacy Policy was last updated on the “last updated” date above.
5. Your rights
You have the right to access the personal data we process by requesting access to it. To the extent permitted by law, you have the right of access to and the right to rectify, update, amend or erase your data.
If your personal data are deleted at your request, we will only retain copies of them if this is necessary to protect our legitimate interests and those of third parties, to comply with instructions from public authorities, to resolve disputes, to troubleshoot problems or to enforce contracts we have entered into with you. Please note, however, that certain personal data are strictly necessary or required by law in order to achieve the purposes described in this Privacy Policy. You cannot erase this data.
Where the processing of personal data is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of the processing of personal data that was carried out on the basis of consent prior to the withdrawal.
Subject to the conditions set out in the legislation on the protection of personal data, in certain cases you have the right to request the restriction of the processing of your personal data and also to object to the processing of certain personal data.
Subject to the conditions set out in the data protection legislation, you have the right to data portability, i.e. the right to receive your personal data in an organised form in a commonly used machine-readable format and to transfer it to another controller at your own discretion.
For requests to exercise any of the above rights, please contact us at info@alpakids.com.
If you feel that we are not processing your personal data properly, you have the right to lodge a complaint with your national data protection authority. In Estonia, this is the Data Protection Inspectorate. Contact details for the Data Protection Inspectorate can be found here: https://www.aki.ee/en.
6. Security
We use appropriate organisational, technical and administrative security measures (including physical, electronic and administrative) to protect personal data against loss, destruction, misuse and unauthorised access or disclosure. For example, we only give access to your personal data to authorised employees and contractors who need them to perform their duties.
Please note that while we strive to take reasonable measures to protect the security of your personal data, no system can completely eliminate all possible security risks.
7. ALPA Kids contacts
If you have any questions about this Privacy Policy or the personal data we process about you, please contact us at info@alpakids.com.