Privacy Policy
GlowCub OU — Privacy Policy
Last updated: May 25, 2026
GlowCub OU (registration number 17514105), headquartered at Pae 25-47, Tallinn, 11414, Estonia ("GlowCub", "we", "us") operates mobile applications designed for children. This Privacy Policy explains what information we collect, how we use it, and what rights you and your child have. It applies to all GlowCub mobile applications and to our website at glowcubstudio.com (collectively, the "Services").
We comply with the EU General Data Protection Regulation (GDPR), the Estonian Personal Data Protection Act, and the U.S. Children's Online Privacy Protection Act (COPPA). We take children's privacy seriously: we collect as little data as possible and never use it for behavioural advertising.
1. What Data We Collect
Our apps are designed for children and we minimise data collection to what is strictly necessary for the apps to function. We do not ask children to create accounts or provide their name, address, or any other directly identifying information.
Automatically collected technical data
When you use our apps or website, we automatically collect:
Device information — device type, operating system version, language and region settings.
Approximate location — country or region derived from IP address only. We do not collect precise GPS location.
Usage data — which features are used, session duration, crash reports, and in-app purchase history.
Persistent identifier — a random device identifier used solely for the internal operation of the app (e.g. saving game progress).
Data you provide to us (parents / guardians only)
If you contact our support team, we collect your name and email address in order to respond to your inquiry. We do not collect this information from children directly.
Payment and billing data
If you purchase a subscription through an alternative payment provider (in regions where app store billing is unavailable), that provider may share with us limited billing information necessary to manage your subscription — such as your email address, subscription status, and a payment transaction identifier. We do not receive or store full payment card details. This data is processed solely for the purpose of fulfilling and managing your subscription.
Camera, microphone, and photos
Some apps may request access to the device camera, microphone, or photo library to provide a specific in-app feature (for example, taking a photo to personalise a character). Any such content is stored locally on the device only — we do not upload, store, or share photos, videos, or audio recordings.
2. How We Use the Data
We use the data we collect only for the following purposes:
Operating and improving our apps — fixing bugs, analysing performance, and enhancing features.
Customer support — responding to questions or requests from parents and guardians.
Fraud prevention and security — detecting misuse or technical attacks on our Services.
Subscription management — processing and maintaining your subscription status where purchases are made outside of app stores.
Legal compliance — meeting our obligations under applicable law.
We do not use children's data for behavioural advertising, profiling, or any purpose beyond what is listed above.
3. Lawful Basis for Processing (GDPR)
For users in the European Economic Area, our lawful bases for processing personal data are:
Legitimate interests — operating and securing the Services, provided your or your child's rights do not override those interests.
Legal obligation — where processing is required to comply with applicable law.
Consent — where we ask for it specifically (e.g. for optional features). You may withdraw consent at any time by contacting us.
For processing personal data of children under 16 based on consent, we will take appropriate steps to verify that consent is given or authorised by a parent or guardian.
4. Third-Party Service Providers
We work with third-party software providers to support the operation of our apps. These may include providers in the following categories:
Analytics and crash reporting providers — to measure app performance and diagnose technical issues.
Attribution providers — to understand how users discover our apps.
Advertising and mediation providers — to serve contextual advertisements.
We configure these integrations to minimise data collection and to operate in compliance with applicable children's privacy requirements, including COPPA and platform policies. We do not allow third-party providers to use data collected through our apps for behavioural advertising or user profiling.
We may share data with third parties only in the following limited circumstances:
Service providers — companies that perform services on our behalf (e.g. hosting, analytics) under strict contractual data protection obligations.
Legal requirements — when required by law, court order, or a competent authority.
Business transfer — in the event of a merger, acquisition, or sale of assets, subject to the same privacy commitments.
We do not sell personal data. We do not share children's data for advertising purposes.
5. Children's Privacy
Our apps are designed for children. We comply with COPPA and GDPR rules on children's data. We do not knowingly collect personal information directly from children beyond what is described in Section 1. Children cannot create accounts or submit personal information through our apps.
If you are a parent or guardian and believe we have collected personal data from your child that should be deleted, please contact us at contact@glowcubstudio.com. We will delete such information promptly.
You may also request that we stop collecting any further data related to your child's use of our apps. The simplest way to do this is to uninstall the application.
6. Data Storage and International Transfers
Our Services are operated from Estonia, within the European Economic Area. Personal data is stored on servers located in the EEA. If we transfer data outside the EEA (for example, to a service provider), we do so only under appropriate safeguards, such as the European Commission's Standard Contractual Clauses.
7. Data Retention
We retain personal data only for as long as necessary for the purposes described in this Policy. Support correspondence is retained for up to 2 years. Technical usage data is retained for up to 3 years. When data is no longer needed, we delete or anonymise it.
8. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) within 72 hours and, where required, affected individuals without undue delay.
9. Your Rights
Under GDPR, if you are located in the EEA, you have the following rights regarding your personal data:
Access — request a copy of the data we hold about you.
Rectification — request correction of inaccurate data.
Erasure — request deletion of your data ("right to be forgotten").
Restriction — request that we limit how we process your data.
Portability — receive your data in a structured, machine-readable format.
Objection — object to processing based on legitimate interests.
Withdrawal of consent — withdraw consent at any time, where processing is based on consent.
Parents and guardians may exercise these rights on behalf of their child. To make a request, contact us at contact@glowcubstudio.com. We will respond within 30 days.
If you believe we are processing your data unlawfully, you have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee) or the supervisory authority in your EU country of residence.
10. Cookies and Tracking Technologies
Our website may use essential cookies required for its operation. We do not use cookies for advertising or tracking. Our mobile apps may use SDKs that collect aggregated, non-personal usage statistics. You can disable cookies in your browser settings at any time; some website features may not function as a result.
11. Changes to This Policy
We may update this Policy from time to time. If we make material changes, we will notify you by posting a notice in our apps or on our website before the changes take effect. The date at the top of this Policy indicates when it was last updated.
12. Contact Us
For any questions, requests, or concerns about this Privacy Policy or our data practices, please contact us:
GlowCub OU
Pae 25-47, Tallinn, 11414, Estonia
Email: contact@glowcubstudio.com
Website: https://glowcubstudio.com