Legal

Privacy Policy — Their First Numbers

Last updated: September 22, 2026

Browser version — October 17, 2026: The mobile policy below describes the installed app. Browser play downloads code and media from our website, opens Settings directly, and saves progress and preferences only in this browser when storage is available. Browser data may be cleared and is not synchronized or backed up. No account or gameplay upload is added. See our Website Privacy Notice for hosting requests and browser storage.

Optional web tips: Only adults should leave a tip. The browser app links to a separate support page and Stripe checkout. Stripe processes the payment details an adult enters, and Their First Words LLC receives the payment record, including email and amount, to handle the tip and payment questions. No child name, settings or activity is sent to Stripe. A tip unlocks nothing and starts no subscription. The installed mobile app has no tip checkout.

Plain-language summary

Their First Numbers is a calm, offline-first app that helps parents build early number sense with children about 2–4 years old. The parent is the user; the child is the end-user.

What the App never does:

No data collection. Nothing about you or your child leaves your device. We receive nothing, and neither does anyone else.
No ads, no advertising ID, no tracking. There are no ads, no analytics, and no tracking tools of any kind. We never follow you across other apps or websites.
No data sales or sharing. We have no data to sell or share, and no third-party processors.
No account. You never sign in or give us an email.
No purchases. The App is completely free, with no in-app purchase, subscription, or paid unlock.
No sensitive permissions. The App never asks for location, contacts, camera, photos, or the microphone. On Android it does not even request internet access.

What stays on your device: which numbers your child has practiced and completed, plus your in-app preferences. There is no cloud copy and nothing to sync. To erase your child’s progress, use Grown-ups → Reset progress, or uninstall the App.

The full policy follows.

1. Who we are

This Privacy Policy describes how Their First Words LLC, a California limited liability company (“we,” “us,” “our”), handles information in connection with the Their First Numbers mobile application (the “App”), available on the Apple App Store and Google Play.

Contact:

Email: privacy@theirfirstwords.org
Support: support@theirfirstwords.org
Postal address: Their First Words LLC, 2108 N St, Ste N, Sacramento, CA 95816, United States

We are the data controller for purposes of GDPR. For users in the United Kingdom, we act as data controller under UK GDPR.

2. Scope

This policy applies to information handled through the App itself. It does not apply to the App Store listing pages (governed by Apple’s and Google’s policies), or to any third-party website you may navigate to from the App.

3. What we collect

Nothing. The App collects no personal information, from your child or from anyone. It works offline, has no accounts, and is fully free, so there are no accounts, analytics, or purchases to collect data through. Below is what stays on your device, and what we never gather.

3.1 Data stored only on your device (we never receive it)

The record of your child’s learning lives entirely on your device and is never transmitted to us:

Data	What it is
Number progress	For each number (1–10): whether it has been practiced or completed, and enough recent-activity information to resume where the child left off
App preferences	Settings you choose in-app — language, sound on/off, and the day/night appearance
Local app record	A non-identifying app-generated ID and creation timestamp used only to initialize the device-local experience

There is no child profile: we do not collect or store the child’s name, age, date of birth, gender, avatar, photo, or voice. The local records above are held only on the device, are not tied to any account, and are not visible to us.

Reset progress clears only the learning-progress row. Language, sound, appearance, and the local app record remain so the App keeps the parent’s settings. Uninstalling the App removes all of these local records. There is no server copy of any of them.

3.2 No account

Their First Numbers has no account system. You never create an account, sign in, or give us an email address or password. We therefore collect no name, email, password, or account identifier of any kind. The App uses no Firebase, no authentication service, and no sign-in of any provider (Apple, Google, or otherwise).

3.3 No purchase

The App is fully free. There is no in-app purchase, no subscription, and no paid unlock — every number and activity is open from the first launch. We use no purchase-management service (no RevenueCat) and process no payments, so no purchase, entitlement, transaction, or payment record is ever created or received. There is nothing to buy and nothing to restore.

3.4 What we explicitly do not collect

Any account or identity data — no name, email, password, or account; you never sign in
Any purchase or payment data — the App is free; there is no IAP and no payment
Analytics or tracking — this App contains no analytics SDK and sends us no usage events
Advertising ID (IDFA on iOS, AAID on Android) — not collected; there are no ads
Crash reports or diagnostics — not collected; the App has no crash-reporting service
Precise or coarse location — not requested
Contacts, photos, camera, or microphone — not requested
Audio recordings of you or your child — the App plays audio to your child; it never records
Push-notification tokens — the App sends no push notifications
Browsing history across other apps or websites — not collected
Social media identifiers — not collected

4. How we use information

4.1 To provide the App

Everything the child does runs on the device: presenting number activities, tracking on-device progress, and resuming where they left off. This needs no account, no purchase, and no network.

4.2 No selling, no purchase, no email

Because the App is free and accountless, there is nothing to sell, nothing to restore, and no address to email — we send you no email of any kind, operational or marketing.

4.3 Legal compliance and safety

We comply with legal obligations and lawful requests from public authorities. We hold no data about you or your child, so there is nothing to produce.

4.4 No advertising, no profiling

We run no ads, no analytics, and no profiling of any kind. We do not build audiences and export nothing to any advertising platform.

5. Who we share information with

We share information with no one. Because the App collects nothing, transmits nothing off your device, and involves no purchase, there are no third-party processors of any kind — no Firebase, no RevenueCat, no payment processor, no analytics or attribution service, no advertising network. Child data never leaves the device, so no processor ever receives any data.

We do not engage advertising networks, attribution SDKs (Branch, Adjust, AppsFlyer, etc.), third-party analytics services (Mixpanel, Amplitude, PostHog, etc.), session replay tools (FullStory, LogRocket), or any other data-broker-adjacent service.

6. Children’s privacy

Their First Numbers is parent-led: the App is intended for parents to use with their child. The child does not create an account, sign in, or make any choice that sends data to us. Every record of the child’s activity is stored only on the device and is never transmitted to us.

We design and operate as if the Children’s Online Privacy Protection Act (COPPA), the GDPR’s protections for children (Article 8 / GDPR-K), and the UK Children’s Code (Age Appropriate Design Code) all apply.

6.1 United States (COPPA)

We do not collect personal information from children — or, in fact, from anyone. The child’s activity is device-local and is never sent to us, and the App collects no child name, age, birthday, photo, voice, or location. There is no account, so we collect no parent email either, and the App is free, so no purchase data is created. Nothing leaves the device.

Because we collect no personal information from children online, the App does not trigger COPPA’s verifiable-parental-consent requirement. The parent remains in full control: all on-device child activity can be cleared at any time (Grown-ups → Reset progress, or by uninstalling).

6.2 European Union and United Kingdom (GDPR / UK GDPR / Children’s Code)

Legal basis. We process no personal data through the App — no account data, no child data, no purchase data — so no GDPR legal basis is engaged.

UK Children’s Code. Notable defaults:

Geolocation: not collected.
Profiling: none. We do not infer behaviour or build advertising profiles of children.
Nudge techniques: we explicitly avoid them. There are no streak guilt prompts, no manipulative reminders, and no purchase prompts anywhere (there is nothing to purchase).
Default privacy settings: we send no email of any kind. There is no account and no mailing list.
Connected toys / devices: not applicable.

Data Protection Officer. We have not appointed a Data Protection Officer because we do not meet the GDPR Article 37 thresholds. Privacy inquiries are handled by our privacy contact at privacy@theirfirstwords.org.

7. How long we keep information

Category	Retention
On-device learning progress	Held on your device until you Reset progress or uninstall the App. We never hold a copy.
App preferences	Held on your device until you change the setting or uninstall the App. Reset progress does not remove them. We never hold a copy.
Local app record	Held on your device until you uninstall the App. Reset progress does not remove it. We never hold a copy.
Anything on our servers	None — we operate no server that stores your or your child’s data, and we run no analytics.

We maintain no backups of your data because we never receive it.

8. Your rights and how to exercise them

8.1 Clearing on-device data (in your control at all times)

Your child’s activity is on your device. To erase it: Grown-ups → Reset progress (clears learning progress), or uninstall the App (removes all local data). Both are immediate and need no request to us — there is no server copy.

8.2 There is no account and no server record

We hold no account and no data about you or your child on any server — so there is nothing for us to access, export, or delete on your behalf. This is the strongest form of the “right to be forgotten”: the data only ever existed on your device, and clearing it (§8.1) is complete and final.

8.3 Other rights

Because we hold no account and no personal data, access/rectification/erasure requests have nothing for us to act on. You may still contact privacy@theirfirstwords.org with any question about our practices, and we will respond within 30 days.

8.4 Right to lodge a complaint

If you are in the EU/UK and believe we have mishandled your data, you may complain to your national data protection authority. The UK’s authority is the Information Commissioner’s Office (https://ico.org.uk). A list of EU authorities is at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

9. Purchases and billing

The App is completely free. There is no in-app purchase, no subscription, and no billing — nothing to cancel, no recurring charge, and no payment of any kind. We never receive payment information because there is no payment.

10. International data transfers

Because no data ever leaves your device, there are no international data transfers. We operate no servers that receive your or your child’s data, and we engage no processors abroad.

11. Security

The App’s privacy comes from its architecture: it keeps your child’s data on your device and sends nothing off it.

Child learning data never leaves the device, which removes an entire class of server-side exposure.
We hold no account credentials — there is nothing to breach, because there is no login and no server.
The App requires no network connection to function; it makes no network calls that carry your or your child’s data.

We hold no data about you or your child, so there is nothing on our side to breach. If that ever changes and we learn of a security incident affecting data we hold, we will notify you and any required regulator within the time the law requires (72 hours under GDPR; without unreasonable delay under COPPA and state laws).

12. Changes to this policy

We may update this policy from time to time. When we do, we will:

Update the “Last updated” date at the top.
If the change is material (for example: a new category of data, a new processor, or a new purpose of processing — such as introducing analytics, accounts, or a purchase), notify you in-App at least 30 days before the change takes effect.
Keep prior versions of this policy available on request at privacy@theirfirstwords.org.

Continued use of the App after a non-material change indicates acceptance of the updated policy.

13. Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your data:

Email: privacy@theirfirstwords.org
Support: support@theirfirstwords.org
Postal: Their First Words LLC, 2108 N St, Ste N, Sacramento, CA 95816, United States

For users in the EU/UK, you may also lodge a complaint with your national supervisory authority as described in §8.4.