NoMiLudo
Privacy

NoMiLudo Privacy Policy

Last updated: 31 August 2026

NoMiLudo is an educational game for young children. It is designed so that a family can play it without giving us anything at all.

This document is the hosted copy required by the App Store and Google Play, and it is the complete text. The app itself carries a summary of it under Parent Dashboard → Legal, in every language the app supports, along with who is responsible and how to reach them, so the essentials can be read with no internet connection at all. If the two ever disagree, that is a bug. Please report it.

The short version

  • We do not run ads or analytics anywhere, and the app and the game itself carry no third-party code at all. The one exception on either site is the newsletter sign-up form on two pages of nomiludo.com, and its spam protection, both described under Newsletter below.
  • The two links that leave the app are both behind the parental gate: signing in with Google, and this privacy policy. The one thing that can be bought is the full version, and it sits behind that gate too.
  • The microphone is off by default, is switched on only by a grown-up from behind a parental gate, and what it captures never leaves the device.
  • The game is fully playable with no account and no internet connection.
  • Cloud sync is optional. Only if a parent signs in with Google does anything at all leave the device.

Who is responsible

The controller for everything described here, within the meaning of Art. 4 (7) GDPR, is:

Jan Schätzle
Mezgerstr. 3
72820 Sonnenbühl
Germany

NoMiLudo is made by one person, so there is no data protection officer: neither Art. 37 GDPR nor § 38 BDSG requires one at this size. Write to the address above with any question about your family's data and a person will answer.

Microphone

Some levels let a child answer out loud instead of tapping.

  • Voice answers are off by default and are switched on only by a grown-up in the Parent Dashboard, behind the parental gate. That is the moment the operating system's microphone permission prompt appears. The app never asks for the microphone during gameplay.
  • Speech is converted to text by the device's own speech recognition (Apple's on iOS, Android's on Android, the browser's on the web). We do not record, store or transmit audio. Only the recognised text is compared against the expected answer, in memory, and then discarded.
  • Note that the device's built-in speech recognition may itself be a service of Apple or Google, governed by their platform privacy policies and the settings you control on your device.

Data stored on the device

The app saves the following in its own local storage on the device:

  • Child profile name, avatar emoji and colour theme
  • The child's birth month and year, only if a parent chooses to enter it. It is optional and can be skipped. We deliberately never ask for, and cannot store, a full date of birth. The month is all that is needed for the one thing it is used for: suggesting which game modes suit that age when the profile is created. It is never used to identify anyone and is never shared.
  • Levels unlocked, stars earned and high score
  • Settings: language, volume, music, hints, playback speed, which modes are visible, and whether voice answers are enabled
  • Whether microphone permission was granted on this device (deliberately kept out of anything that syncs)

None of this reaches us. It stays in the app's own storage on your device, for as long as you keep it there, and we have no way to read it. You can delete all of it at any time by deleting the profile, or by uninstalling the app.

Purchases

NoMiLudo is free to download with part of the game open, and a single purchase, not a subscription, opens the rest.

  • The purchase is handled entirely by Apple or Google. We never see your name, your payment details or your store account, and no purchase information is sent to us or to anyone else.
  • The app stores one thing about it: a flag on this device recording that the full version was bought. It is deliberately kept out of cloud sync, in the same way the microphone grant is. A purchase belongs to the store account that made it, not to a child's profile.
  • To move the purchase to another device, use Restore in the Parent Dashboard. That asks the store, not us.
  • The offer is only reachable from behind the parental gate, so a child cannot reach it on their own.

Optional cloud sync

Cloud sync exists so a family's progress can move between devices. It is entirely optional and off unless a parent signs in.

  • Signing in uses Google Sign-In and can only be started from behind the parental gate.
  • If, and only if, a parent signs in, we store in Google Firebase (Firebase Authentication and Cloud Firestore):
  • The parent's Google account identifier, email address, display name and profile photo URL
  • For each child profile: the name, avatar, colour, the optional birth month and year, and the progress and settings listed above
  • Every document is stored under the signed-in parent's own account identifier and is readable and writable only by that account. This is enforced by server-side security rules.
  • It is kept until you delete the profile or ask us to erase it, and no longer.
  • We do not sell, rent or share any of this with anyone. It is not used for advertising, profiling or any purpose other than syncing your own progress back to you.
  • Google acts as our data processor for this storage: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, with Google LLC in the United States as a sub-processor. Transfers outside the EU rest on the European Commission's standard contractual clauses and on Google's certification under the EU-US Data Privacy Framework. See https://firebase.google.com/support/privacy.

The websites

nomiludo.com is this page and the rest of the public site. app.nomiludo.com is the same game running in a browser, and everything above applies to it exactly as it does to the app. Neither carries advertising, and neither has any analytics: nothing here measures what a visitor reads, how long they stay or where they lose interest, and the fonts are served from this domain rather than from Google. On the browser version Google is contacted only if a parent signs in, which is the cloud sync described above.

Two pages of the public site, the home page and /get, carry the newsletter sign-up form described below, and that form is the one place on either site where a third party is involved. What it loads, and when, is set out under Newsletter.

  • Hosting. Both are served by Cloudflare Pages, and the downloadable voice packs by Cloudflare R2 (Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA). Cloudflare processes this on our instructions under a data processing agreement; transfers to the United States rest on the European Commission's standard contractual clauses and on Cloudflare's certification under the EU-US Data Privacy Framework.
  • Server log data. Serving a page necessarily means the server sees the requesting IP address, the time of the request, what was asked for, and the browser's user agent and language. That is kept briefly, to deliver the site and to defend it against attack, on the basis of Art. 6 (1) (f) GDPR. It is not combined with anything else, no profile is built from it, and it is never used to identify a visitor.
  • Local storage. Choosing a language in the footer stores that choice in your own browser, so the next visit opens in the same language. It never leaves the browser, and clearing your browsing data removes it. There is no cookie banner because there is nothing to consent to: this is storage strictly necessary for a service you asked for, which § 25 (2) TDDDG exempts.
  • Voice packs. Downloading a recorded voice from the Parent Dashboard is an ordinary file download from voice.nomiludo.com, with the same log data as above. Nothing about the child, the profile or the device is sent with it.

Newsletter

The public site offers a newsletter to sign up for. It carries news about the app: how it is coming along, what has just been built, and the day it reaches the stores. Occasional, and nothing else. The list is used for nothing but that, and is never passed on or sold. There is no newsletter inside the app, and a child playing the game is never shown any of this.

  • What is collected. The email address you type in, and nothing else. No name is asked for and nothing about a child is ever part of it.
  • How your consent is recorded. You tick a box that is not pre-ticked, and we then send you a mail asking you to confirm the address. You are not added until you answer it, which means an address typed in by somebody else cannot be added. That confirmation, with its time, is the record of your consent.
  • The legal basis is your consent, Art. 6 (1) (a) GDPR, together with Section 7 (2) UWG. You can withdraw it at any time, through the unsubscribe link in any message or by writing to the address at the bottom of this page, and withdrawing never makes what happened before it unlawful.
  • Who processes it. Brevo GmbH, Koepenicker Str. 126, 10179 Berlin, Germany, on our instructions under a data processing agreement. Brevo stores and sends this on servers inside the EU; no data leaves the EU for it.
  • When your browser reaches Brevo. Only when you press the button. The two pages carrying the form load nothing at all from sibforms.com when they open, because the form is sent by this site's own code, so visiting them tells Brevo nothing about you. When you do submit, your browser reaches Brevo directly and they see, together with your address and your consent, your IP address, the time, and what your browser says about itself.
  • Spam protection. The form is protected by Cloudflare Turnstile, from the same Cloudflare described under The websites above. It checks that a submission comes from a person rather than a machine, from signals about the request and about the browser making it, and it sets no cookie and stores nothing on your device. It runs on the same two pages only. No further processor and no further transfer is involved beyond the hosting already described there.
  • No storage on your device. The form sets no cookie of its own and stores nothing in your browser.
  • How long. Until you unsubscribe, or until the list is shut down, whichever comes first. Unsubscribing removes the address; the record that it was confirmed and then withdrawn is kept only as long as we need it to show the mailing was lawful.

The legal grounds

For readers who want the formal answer, the bases under Art. 6 (1) GDPR are:

  • Consent, Art. 6 (1) (a). The microphone and cloud sync. Both are off until a parent switches them on from behind the parental gate, which is also the parental consent Art. 8 GDPR asks for. Switching it back off withdraws that consent, and withdrawing never makes what happened before it unlawful. The newsletter is the same, and is confirmed by mail before anything is ever sent to you.
  • The contract you asked for, Art. 6 (1) (b). Keeping a signed-in family's profiles and progress in step across their own devices, and answering questions you write to us with.
  • Legitimate interests, Art. 6 (1) (f). Serving the site, the browser version and the voice packs, and keeping them available and secure. That is the log data described above, and the sign-up form's spam protection on the two pages that carry one. The sign-up itself rests on your consent, not on this.

Everything that stays on your device is not something we hold at all. It never reaches us, and we could not read it if we wanted to.

Deleting your data

  • Delete a profile (Profiles → Manage → 🗑️, behind the parental gate). Removes that child's data from the device and from the cloud. If the device is offline, the deletion is remembered and retried on the next connection.
  • Sign out. Stops all syncing. Data already in the cloud stays until you delete the profile.
  • Reset progress (Parent Dashboard → Settings). Clears stars and unlocked levels for the active profile.
  • Uninstall the app. Removes everything stored on the device.

To have any remaining cloud data erased, contact us at the address below and we will delete it.

Your rights

You can ask us for access to what we hold about you (Art. 15 GDPR), to correct it (Art. 16), to erase it (Art. 17), to restrict what is done with it (Art. 18), to receive it in a portable form (Art. 20), and to object to anything we do on the basis of a legitimate interest (Art. 21). Where we rely on consent you can withdraw it at any time (Art. 7 (3)), which for the microphone and cloud sync is a switch in the Parent Dashboard.

In practice almost none of this ever reaches us, so the Parent Dashboard is the fastest route to most of it. For anything else, write to the address at the top of this page. Asking costs nothing, and we ask you to prove who you are only so far as we need to be sure we are answering the right person.

We take no automated decisions in the sense of Art. 22 GDPR, and we do not profile anyone.

You also have the right to complain to a supervisory authority (Art. 77 GDPR). The one responsible for us is:

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg
Heilbronner Straße 35
70191 Stuttgart
Germany

Children's privacy

NoMiLudo is intended for children and is designed to comply with COPPA, the GDPR (including Art. 8), and the Apple Kids Category and Google Play Families requirements.

We collect no personal information from a child directly. The only child-related information that can ever leave the device (a profile's name, avatar and the optional birth month) is entered by a parent from behind the parental gate, and only leaves the device at all if that parent has also deliberately signed in with their own Google account. There is no advertising, no analytics, no tracking, no social features, no user-to-user communication, no user-generated content sharing and no way to contact anyone from inside the app. The single in-app purchase described above is reachable only from behind the parental gate.

Changes

If this policy changes materially, the updated version will be published here and in the app before the change takes effect.

Contact

Questions, a request to delete data, or anything else:

Jan Schätzle
Mezgerstr. 3
72820 Sonnenbühl
Germany