Draft, review by a lawyer before publishing. Text in [OWNER TO CONFIRM: …] brackets must be completed or checked before this policy goes live.
Tanakh World (עולם התנך, "the app") is a Tanakh quiz game for kids and adults, made by Mala ("we", "us"). We wrote this policy for parents, in plain language.
The short version: there is no sign-up, no account and no Mala server. The player's name and progress stay on the device. A few outside services (Google, RevenueCat and Expo) receive limited technical data so the app can work, show ads, handle the subscription and receive updates, as described below. Every player is treated as a child.
Who we are
Mala, operated by Yohai Agami, an individual trading as Mala, [OWNER TO CONFIRM: address], is responsible for the app. There is no registered company.
- Website: mala-lab.com
- Email: support@mala-lab.com
- Data protection officer: [OWNER TO CONFIRM: name and contact of a DPO, or state that none is appointed].
- EU/UK representative: [OWNER TO CONFIRM: GDPR Art. 27 representative in the EU and UK, if Mala isn't established there and one is required].
1. What stays on the device
The following is stored only on the device. We never receive it, and the app doesn't send it to any service:
- the name the player chose (a nickname is fine) and, in Hebrew, the chosen form of address;
- settings: language, sound, haptics, timer, nikud, dark mode, and the usage-data switch;
- progress: past answers, scores, stars, experience points, level and rank, badges, and daily challenge results;
- sets of books and chapters the player made;
- questions the player reported (so they are hidden for that player);
- whether a subscription is active (a saved copy, so the app also works offline).
To delete all of this, uninstall the app. We keep no copy, so we can't restore it either.
2. What we don't collect
We don't ask for or collect names, email addresses, phone numbers, postal addresses, dates of birth, photos, contacts or precise location. The app doesn't ask for camera, microphone, location, contacts or notification permission. There is no chat, no sign-in, no content shared between players, and no share button.
The name the player types is never sent to any service, written to crash reports or included in usage data.
3. Outside services and what they receive
All of these services receive data over encrypted connections (HTTPS). We don't sell data and don't use it to track anyone across other apps or websites.
Google Firebase Analytics (usage data)
- What the app sends: a fixed list of events whose details are only numbers, values from a fixed list and a question id. There is no free text and no name. The events are: a round started or finished (mode, difficulty, score), a hint used (hint type), a question reported (question id and a reason from a list), a set created, the subscription screen opened, and a subscription started.
- What Firebase adds on its own: a random app-instance id, device model, operating system, app version, language, engagement time and basic events such as the first launch. Google derives a general country and region from the IP address.
- What is switched off: the advertising id (IDFA on iOS, Advertising ID on Android), the Android id (SSAID), automatic screen reporting, linking to ad networks, and every ad-storage and ad-personalisation signal. The iOS app is built without Apple's advertising-id framework for analytics.
- In the EU, EEA, UK and Switzerland, usage data is off until a parent allows it. The app decides whether you're in this region from Google's consent tool (UMP, see "Google AdMob" below) and the region set on the device; until it knows, nothing is collected. In the region, the first time the home screen opens, the app asks once: "May we collect anonymous usage data to improve the game?" "Allow" opens the parental gate first; "Not now" keeps usage data off, and the app doesn't ask again.
- Elsewhere, usage data is on until you switch it off.
- You can change your choice at any time: Settings → Privacy → "Share anonymous usage data". In the region, switching it on goes through the parental gate. When it's off, the app stops Firebase Analytics collection and analytics storage and sends no usage events.
Google Firebase Crashlytics (crash reports)
- When the app crashes or hits an error, a report is sent: what went wrong in the code, the device model, operating system, app version, memory and storage state, and a random installation id. Reports may include short technical notes written by us in the code, never anything the player typed.
- Crash reports are still sent when the usage-data switch is off, because we need them to fix problems.
Google Firebase Performance Monitoring
- Speed data: how long the app takes to open, how smoothly screens draw, and how long network requests take, with the device model, operating system, app version, a random installation id and country (from the IP address). No personal information.
Google AdMob (ads)
- Players without a subscription see a banner ad that never covers the question or answers. There are no full-screen ads and no video ads.
- Every ad request is marked as directed to children (under the US COPPA rule) and from a user under the age of consent (under the GDPR), with a maximum content rating of G (general audiences), and asks for non-personalised ads only.
- The app doesn't use the advertising id: on Android the AD_ID permission is removed, and on iOS there is no tracking (ATT) prompt.
- In the EEA, UK and Switzerland the app runs Google's consent tool (UMP), as Google requires. Because every request is marked as coming from a user under the age of consent, ads stay non-personalised. If the tool says ads can't be requested, the app shows none.
- To show ads, cap how often they appear, measure them and prevent fraud, AdMob receives technical data: the IP address (used to estimate a general location such as the country), device type and operating system, app details, and which ads were shown and tapped. On Android, Google may also use the App Set ID for frequency capping and fraud prevention.
- Tapping an ad can open the browser or an app store. We don't control ad content or the pages ads lead to.
- Subscribers see no banner, and the app makes no ad requests for them.
- Google's privacy policy · How Google uses information from apps that use its services
RevenueCat (subscription)
- The subscription is bought through the App Store or Google Play. We never see card or bank details.
- RevenueCat manages the subscription for us: when the app opens it checks whether a subscription is active, and it processes purchases and restores. For that it receives a random anonymous id it creates itself, the purchase details from the store (product, dates, price, country, currency and status), the device type, operating system version and IP address. We don't give it a name or anything that identifies the player.
- RevenueCat's privacy policy
Expo (EAS Update: app updates)
- When the app opens, it asks Expo's update service whether a small fix or improvement is waiting for this version, and downloads it if there is one. This lets us correct mistakes (for example in a question) without a new store release.
- The request carries the IP address (as every internet request does), the platform (iOS or Android), the app's runtime version and update channel, the ids of the update installed now, and a random id that Expo's update library creates on the device (it isn't the advertising id and isn't linked to the player). Expo uses them to send the right update, to check that it was downloaded and installed, and to keep its service working and secure.
- The app sends Expo nothing about the player: no name, no progress, no answers.
- Expo's privacy policy
Apple and Google stores
Downloads, purchases, payments, refunds and the subscription itself are handled by Apple (App Store) or Google (Google Play) under their own terms and privacy policies. We receive no payment details. Apple privacy policy · Google privacy policy
4. Children
Tanakh World is made for kids too, so every player is treated as a child, whatever their age:
- We don't ask for a child's age, name or contact details, and we don't knowingly collect personal information from children.
- The only identifiers the outside services use are random installation ids and the IP address, for the app's internal operations: keeping it working, measuring and fixing it, contextual (non-personalised) ads, frequency capping and fraud prevention. Nothing is used to build a profile or for behavioural advertising [OWNER TO CONFIRM: lawyer review of the COPPA "support for internal operations" position for Firebase Analytics].
- Ads are child-directed, rated G and never personalised.
- A parental gate (a question a grown-up has to answer) comes before the subscription screen, before buying or restoring a purchase, and before every link in the app that leaves it (this policy, the terms of use, rating the app). Tapping an ad isn't behind the gate, because the ad's own code handles the tap.
- A parent who thinks we received information about their child can write to support@mala-lab.com and we'll deal with it.
5. Legal bases (EU, EEA, UK and Switzerland)
| Purpose | Legal basis |
|---|---|
| Running the game on the device | No personal data reaches us; the data stays on the device |
| The subscription (RevenueCat, the stores) | Performance of our contract with you (the Terms of Use) |
| Crash reports, performance data and app updates (Expo) | Our legitimate interest in an app that works and gets fixes |
| Usage data (Firebase Analytics) | Consent, given by a parent through the parental gate; off until then, and it can be withdrawn at any time in Settings |
| Non-personalised, child-directed ads | Our legitimate interest in funding the free game |
6. How long data is kept
- On the device: until the app is uninstalled.
- Firebase Analytics: usage events are kept for 2 months, then deleted.
- Crashlytics: up to 90 days.
- Performance Monitoring, AdMob, RevenueCat and Expo: according to each provider's own retention policy.
- Purchase records: kept by RevenueCat, Apple and Google under their policies and legal duties (for example tax records).
7. Your rights and deleting data
Depending on where you live, you may have the right to access, correct or delete information, to object to its use, and to complain to a data protection authority. Write to support@mala-lab.com and we'll answer within the time the law requires (usually one month).
Because there are no accounts and we never know who the player is, we usually can't find the data of a particular device in the outside services. What you can always do:
- Uninstall the app to delete everything stored on the device.
- Switch usage data on or off in Settings → Privacy.
- Cancel the subscription in your App Store or Google Play account settings (uninstalling doesn't cancel it).
- Reset the advertising id in your device settings (the app doesn't use it, but other apps may).
California and other US states: we don't sell personal information, we don't "share" it for cross-context behavioural advertising, and we don't use sensitive personal information.
8. International transfers
Google, RevenueCat and Expo may process data outside your country, including in the United States. Where the law requires it, these transfers rely on safeguards such as the European Commission's Standard Contractual Clauses or the EU–US Data Privacy Framework [OWNER TO CONFIRM: the safeguards in each provider's data processing terms].
9. Changes to this policy
When this policy changes, we update this page and its version and effective date at the top. Significant changes will also be mentioned in the app's release notes. Previous versions are available on request.
10. Contact
Mala, operated by Yohai Agami, an individual trading as Mala, [OWNER TO CONFIRM: address]
support@mala-lab.com · mala-lab.com
See also our Terms of Use.