⚠️ DRAFT — Not legally reviewed
This is a working draft for a global, child-focused service. Bracketed placeholders such as [COMPANY] must be filled in, and the full text must be reviewed by qualified legal counsel before publication.
Privacy Policy
Last updated: [EFFECTIVE DATE]
1. Who we are
Babchess ("we", "us") is a character-based chess learning platform for players of all ages, including children. This service is operated by [COMPANY], [COMPANY ADDRESS]. For privacy questions, contact us at [PRIVACY CONTACT EMAIL].
2. Our commitment to children
Because Babchess is intended for children, we apply heightened protections in line with the U.S. Children's Online Privacy Protection Act (COPPA), the EU/UK GDPR (including children's provisions, "GDPR-K"), and applicable local laws such as Korea's PIPA. We collect the minimum information necessary, and we require verifiable parental consent before children under [CONSENT AGE] can use features that involve interacting with others.
3. Information we collect
- Account data: username, email address, password (stored hashed), date of birth.
- Guardian data (for children): a parent/guardian email address used solely to obtain and manage consent.
- Optional profile data: country, short bio, avatar selection.
- Gameplay data: games, puzzles, lessons, ratings, and progress.
- Technical data: device/browser information and cookies (see our Cookie Policy).
4. How we use information
We use information to provide and improve the service, personalize learning, maintain safety and moderation, communicate important account and consent notices, and comply with legal obligations. We do not sell personal information, and we do not show behavioral advertising to children.
5. Legal bases (EEA/UK)
Where GDPR applies, we rely on: performance of a contract (providing the service), legal obligation (child-safety and consent records), legitimate interests (security and abuse prevention), and consent (cookies/analytics and, for children, parental consent).
6. Parental rights and choices
Parents and guardians may review their child's information, request corrections or deletion, and withdraw consent at any time by contacting [PRIVACY CONTACT EMAIL]. Withdrawing consent may limit or end the child's ability to use the service.
7. Your rights
Depending on your location, you may have rights to access, correct, delete, export, or restrict processing of your personal data, and to lodge a complaint with a supervisory authority. To exercise these rights, contact us at the address above.
8. Data retention & international transfers
We retain personal data only as long as necessary for the purposes described or as required by law, then delete or anonymize it. As a global service, data may be processed in countries other than yours; where required, we use appropriate safeguards such as Standard Contractual Clauses. [DESCRIBE HOSTING REGION / TRANSFER MECHANISM]
9. Security
We use technical and organizational measures to protect personal data, including encryption in transit, hashed passwords, and access controls. No method of transmission or storage is perfectly secure.
10. Changes & contact
We will update this policy as needed and post the effective date above. Material changes affecting children will be notified to guardians where required. Questions: [PRIVACY CONTACT EMAIL].