PUKABU Child Privacy Statement

PUKABU Child Privacy Statement

INFORMATIONAL MACHINE TRANSLATION — This document is an informational machine translation of the binding authoritative Turkish master. In the event of any discrepancy, the Turkish master prevails.

Child privacy notice for a general audience aged 13+

FINAL TEXT: This document is issued in Türkiye by Kader Narin as operator and data controller and takes effect on its publication date. Contact: pukabupuzzle@gmail.com.

1. Scope and target audience

PUKABU is a general audience puzzle app. The minimum age for use is 13; the app does not specifically target children under 13. Store age rating is a content classification to be determined separately and does not replace this minimum age rule.

2. Local digital consent age

If the applicable digital consent age in the user's country is higher than 13, the user must meet this higher age requirement or have parental/guardian consent as required by law. this notice does not claim that PUKABU has an active parental consent system.

3. Not knowingly collecting data from children under 13 years of age

PUKABU does not knowingly intend to collect personal data from individuals under the age of 13. In the context of general mass services COPPA, it is important that the operator actually learns that personal data is being collected from an individual under the age of 13. The application is not offered as a service for children or as a mixed-audience service.

4. Local profile and gallery avatar

Username, score, progress, and avatar preference are stored locally on the device. The image selected from the gallery is converted into the profile avatar on the device; the upload path to the PUKABU server is not verified in the current architecture. Users should not use their own or others' directly identifying photos.

5. Analytics and advertising components

Firebase Analytics is active for anonymous usage measurement and Crashlytics for technical diagnostics. AdMob serves ads only in the free version after the UMP consent flow; the Premium version displays no ads. PUKABU does not target children under 13 or direct behavioral advertising to children. On iOS, ATT is requested separately only when the UMP choice permits trackable advertising; if ATT is denied, restricted, or not determined, PUKABU does not use IDFA or initiate cross-app tracking and requests only non-personalized/limited ads.

6. If data of children under 13 is detected

If PUKABU discovers that it is processing personal data belonging to a person under the age of 13, the relevant feature or process will be stopped, the data source and recipients will be identified, and data that is not required to be retained will be deleted without delay. If applicable, deletion instructions will be sent to the processor/provider, and the incident record will only be kept to the extent necessary to prove liability.

7. Parent/guardian and user applications

A parent, guardian, or user can apply via pukabupuzzle@gmail.com. The subject of the request is the relevant account/device information and the necessary and proportionate information to verify the connection of the personal data with the child; no unnecessary identification documents are collected. The scope of rights is assessed according to applicable KVKK, GDPR, COPPA or other law.

8. Correct limitation regarding COPPA

This policy does not mean that PUKABU is a child application subject to COPPA or operates a verifiable parental consent system. If the general mass service learns that a user is under 13 years of age and that personal data is being processed, COPPA liabilities may arise; in this case, data deletion or legally required parental consent will be considered.

9. EU/EEA child consent

Under GDPR, the age threshold for parental/guardian consent in consent-based information society services may vary between 13 and 16 depending on the Member State. Therefore, 13 years of age alone is not considered a sufficient age of consent in all countries. PUKABU should verify the applicable threshold and the specific legal basis according to the country where the service is offered.

10. Communication and changes

Child privacy questions and deletion notices: pukabupuzzle@gmail.com. The operator and data controller is Kader Narin. This notice is reassessed if the target audience, data flows, analytics/advertising activity, or store distribution changes.

Official references

FTC - COPPA FAQ: https://www.ftc.gov/business-guidance/resources/complying-coppa-frequently-asked-questions

European Commission - child data and age of consent: https://commission.europa.eu/law/law-topic/data-protection/information-business-and-organisations/legal-grounds-processing-data/are-there-any-specific-safeguards-data-about-children_en

GDPR full text: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0679