Skip to content
Their First Puzzles

Legal

Privacy Policy — Their First Puzzles

Last updated: August 17, 2026

Plain-language summary

  • Their First Puzzles is a calm, wordless, offline puzzle app for young children. The parent sets it up; the child plays.
  • Their First Puzzles is completely free. There is no in-app purchase, no subscription, and no paid unlock — all five worlds are open to every child.
  • Your child’s activity stays on your device. Which puzzles have been completed, each world’s progress, 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, and the app never asks you for an email address — it has no account system at all.
  • The App collects nothing. No name, no email, no analytics, no advertising ID, no purchase — nothing about you or your child ever leaves the device on its own, or reaches us, or reaches anyone else.
  • If you email support, you decide what is in the message. That is the only way anything ever reaches us, it is always an adult’s deliberate act, and the App attaches no child activity, identifier, or device record to it.
  • Every link out sits behind the grown-ups gate. Website, Contact support, Privacy Policy, and the listing for another of our own apps open only after a grown-up holds the corner capsule for two seconds. We add no tracking, referral, or affiliate code to any of them.
  • 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 no third-party processor ever receives your child’s activity.
  • 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 Puzzles mobile application (the “App”), available on the Apple App Store and Google Play. We publish the “Their First …” family of children’s apps.

Contact:

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, and to support communications you choose to send us about it. It does not apply to the App Store and Google Play listing pages (governed by Apple’s and Google’s policies), to your email app or email provider, or to any third-party website you may navigate to from the App.

3. What we collect

Nothing, on its own. The App collects no personal information — not from the child, not from anyone — and transmits none. 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 one thing that ever reaches us is not something the App does: if a grown-up chooses to email us from behind the parent gate, we receive what they chose to write (§3.4). The detail below explains what stays on your device, what an adult can deliberately send, and what we never gather.

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

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

Data What it is
Puzzle progress For each world: which puzzles have been completed and which creatures have been brought home, so play resumes where the child left off
App preferences Settings you choose in-app — 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. What the App does store — the puzzle progress and app preferences above — sits under app-specific keys on your device, is not tied to any account, and is not visible to us. Grown-ups → Reset progress clears play progress; uninstalling the App removes everything it stores locally. Either way, there is no server copy to delete.

3.2 No account

Their First Puzzles 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 world and puzzle 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 Support communications you choose to send

The grown-ups area carries a Contact support row that opens your own email app. Nothing is sent unless you write the message and send it yourself. If you do email us, we receive what you chose to put in it — typically your email address, the contents of your message, any attachment you deliberately added, and whatever device or app-version details you decide to describe.

The App attaches nothing on your behalf: no child activity, no progress, no identifier, no diagnostics, no device record. We use what you send only to answer you, troubleshoot the problem, and meet legal obligations — never for advertising, profiling, or a mailing list. Please leave your child’s personal information out of it; we do not need it to help you.

The Contact support row has been in the App since its first release. This section documents that long-standing practice more precisely; it is not a new category of data, a new processor, or a new use of information (§14.2).

3.5 Adult-only external links

Every link out of the App sits behind the grown-ups gate — a sustained two-second hold on the “Hold 2s for grown-ups” capsule, which a tap will not open. Behind it, the App may open our family website, your email app, or an official Apple App Store or Google Play listing for another of our own Their First apps. These are ordinary platform links. We add no advertising identifier, analytics parameter, referral code, or affiliate code to any of them, and we receive nothing back when one is opened — there is no ad network, no attribution SDK, and no measurement of any kind behind them. Once an external service opens, that service’s own terms apply (§2). A child does not activate an external link from play: no link out opens without the adult hold.

3.6 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 sound 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 the puzzles, 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 mailing list

Because the App is free and accountless, there is nothing to sell, nothing to restore, and no address for us to put on a list — we send no marketing email, no operational email, and no newsletter, ever. The only message we ever send is a reply to one an adult sent us first, and we use it for nothing but answering them.

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

The App shares information with no one. Because the App collects nothing, transmits nothing off your device, and involves no purchase, it engages no Firebase, RevenueCat, payment processor, analytics or attribution service, or advertising network. Child data never leaves the device, so no processor ever receives it.

A support email an adult chooses to send is outside the App’s data flow and is carried and stored by the ordinary email providers at both ends, like any email. Apple, Google, and your email app likewise act under their own terms when an adult deliberately opens one of them from behind the gate (§3.5). We do not disclose a support message to advertisers, data brokers, or analytics providers.

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. Aggregate store statistics

When an app is distributed through the Apple App Store or Google Play, Apple and Google provide developers with anonymous, aggregated statistics — such as total downloads and crash counts — as part of their platforms. These figures are produced by Apple and Google, contain no information that identifies you or your child, and are governed by Apple’s and Google’s own privacy policies. The App does not add any tracking of its own to generate them.

7. Device permissions

The App does not request access to the camera, microphone, location, contacts, photos, or any other sensitive device data. It plays sound through your device’s normal audio output and never records.

8. Children’s privacy

Their First Puzzles is designed for young children, with adult-only settings, data management, support, and external links. 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.

8.1 United States (COPPA)

We do not collect personal information from children. 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 the App asks for no parent email either, and the App is free, so no purchase data is created. Nothing leaves the device on its own.

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).

8.2 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, and no purchase data. If an adult voluntarily emails support, we process that communication to respond to the request, keep the service secure, and meet legal obligations where applicable. That limited support processing is separate from the child’s use of the App and remains subject to the rights described in §10.

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 marketing email of any kind — only a reply to one you sent us. 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.

9. How long we keep information

Category Retention
On-device child activity and preferences Held on your device until you clear them: Reset progress clears play progress, and uninstalling the App removes everything it stores locally, including preferences. We never hold a copy.
Support communications you send us Kept only as long as reasonably needed to answer you, keep a sensible support record, protect the App, or meet a legal requirement
Child play data on our servers None — the App sends us nothing, we operate no server that stores it, and we run no analytics.

We maintain no backup of your child’s play data because we never receive it.

10. Your rights and how to exercise them

10.1 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 all play progress), or uninstall the App (removes all local data). Both are immediate and need no request to us — there is no server copy.

10.2 No account, and no server record of your child’s play

We hold no account, and no data from the App about you or your child on any server — so, apart from a support message you may have chosen to send us (§10.3), there is nothing for us to access, export, or delete on your behalf. This is the strongest form of the “right to be forgotten”: your child’s data only ever existed on your device, and clearing it (§10.1) is complete and final.

10.3 Other rights

Because we hold no account and receive no data from the App, access/rectification/erasure requests have nothing for us to act on. The one thing we could ever hold about you is a support message you chose to send us, and you may ask us to access, correct, or delete that — we may need to check that the request concerns your own message. Contact privacy@theirfirstwords.org with that or with any question about our practices, and we will respond within 30 days.

10.4 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.

11. 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.

12. International data transfers

Because no data from the App leaves your device, the App makes no international data transfers. We operate no servers that receive your or your child’s play data. The App can be used the same way in any region. If you email support from outside the United States, that message — like any email you send — may be handled in the United States, where we are; we use it only for the limited purposes described in §3.4.

13. Security

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

  • Child play data never leaves the device, which removes an entire class of server-side exposure.
  • We hold no account credentials — there is no login, and no server holding your child’s play data.
  • The App requires no network connection to function; it makes no network calls that carry your or your child’s data.

We apply reasonable administrative and technical safeguards to the support messages we receive. No system is perfectly secure. If we ever become aware of a security incident that affects data we hold, we will notify affected people and regulators when and as required by applicable law. In practice the only thing we could hold is a support message an adult chose to send us.

14. Changes to this policy

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

  1. Update the “Last updated” date at the top.
  2. 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), provide appropriate notice and obtain parental consent before the change when required by law.
  3. Keep prior versions of this policy available on request at privacy@theirfirstwords.org.

15. Contact

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

For users in the EU/UK, you may also lodge a complaint with your national supervisory authority as described in §10.4.