Legal

Privacy Policy — Their First Numbers

Last updated: July 12, 2026

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.
Their First Numbers is completely free. There is no in-app purchase, no subscription, and no paid unlock — the whole program is open to every child.
Your child’s activity stays on your device. Which numbers have been practiced and completed, and your in-app preferences, are stored only on the device — they are never sent to us. There is no cloud copy, no account, and nothing to sync.
No account, ever. You do not sign in or give us an email — the app has no account system at all.
We collect nothing. No name, no email, no analytics, no advertising ID, no purchase — nothing about you or your child ever leaves the device or reaches us or anyone else.
We do not sell data. We do not share it with advertisers. There are no ads, and no analytics or tracking SDKs in this App. We do not track you across other apps or websites, and we engage no third-party processors.
To erase your child’s progress: Grown-ups → Reset progress, or uninstall the App. Because the data lives on your device, it is yours to clear at any time.

This summary is informational. 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 the child or from anyone. It is offline-first and accountless, and it is fully free — so the collection vectors that normally exist (accounts, analytics, purchase processing) simply do not exist here. The detail below explains what stays on your device and confirms what we do not 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 (device-local)

There is no child profile: we do not collect or store the child’s name, age, date of birth, gender, avatar, photo, or voice. This information is held only on the device, is not tied to any account, and is not visible to us. Clearing it (Grown-ups → Reset progress, or uninstalling the App) removes it — there is no server copy to delete.

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/diagnostics with personal data — not collected; 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 the 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

To comply with legal obligations and respond to lawful requests from public authorities, should any ever arise. (In practice we hold no data about you 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 child activity and preferences	Held on your device until you Reset progress or uninstall the App. 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.

No system is perfectly secure. If we ever become aware of a security incident that affects data we hold, we will notify you and any required regulator within the timeframes prescribed by applicable law (72 hours for GDPR; without unreasonable delay for COPPA / state laws). In practice we hold no such data.

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.