This is the full privacy notice for Roko, the app for learning chess designed for children aged 3 to 12, and for its website rokochess.com. It is written so that a parent or teacher can understand it without a dictionary. If anything is unclear, write to us and we will fix it.
The short version, in six sentences
- We do not ask for a child's real name, date of birth, photo, voice, location or contacts. A profile is created with a nickname picked from a fixed list and an age range.
- Children have no internet inside Roko. There is no chat, no friends, no leaderboards, no ads and no links a child can open alone. Nobody can contact your child through the app.
- There is no third-party advertising or analytics. No Google Analytics, no Firebase Analytics, no Facebook, no ad networks, no advertising identifiers.
- The whole app works without an account and offline. Without an account, progress lives on your device and in an anonymous copy (no email, no name) that deletes itself after 90 days without use.
- The account is optional and belongs to the adult. It keeps progress when you switch devices. Notifications are optional too: the system asks you once, when setup finishes.
- You can delete everything from inside the app, whenever you want, in Parents' Area → Delete data.
1. Who is responsible
The controller of your personal data is Jose Adrian Rubiera Núñez ("we", "us"), located at Ave Camino de los Parques 3880, Zapopan, Jalisco, 45133, Mexico.
For any privacy matter, including exercising your rights, write to joseadrianmanutd@gmail.com or use the form at rokochess.com/en/support.
We are also the "operator" of Roko under the U.S. Children's Online Privacy Protection Act (COPPA) and the "controller" under the EU General Data Protection Regulation (GDPR) and its UK equivalent.
2. Who Roko is for
Roko is directed to children aged 3 to 12, but it is installed, set up and managed by an adult: a parent, guardian or teacher. Everything related to accounts, settings, notifications, deleting data or links outside the app sits behind a parental gate (a question a young child cannot answer).
We treat everyone who uses the app as if they were a child: we do not ask for an exact age to decide whether to collect more or less data, because we collect the minimum from everyone.
3. What data we process, from whom and why
3.1 If you use Roko without an account
All of this is stored on your device, which is where it really lives:
| Data | Example | Why |
|---|---|---|
| Profile nickname, picked from a fixed list | SwiftRook | So the app can address the child without using their name |
| Age range | Ages 5-6 | To adjust font size, amount of text and difficulty |
| Chosen companion, outfit and look | Penguin with a hat | To personalize the experience |
| Progress | Lessons, stars, gems, games, minigames | So learning is not lost |
| Settings | Language, sound, board theme | So the app works the way you set it up |
There is no field to type into anywhere in profile creation: no name, no photo, no free text.
The anonymous copy. When the device is online, the app creates an anonymous account on our server: no email, no name, just an internal identifier generated by Firebase. It keeps a copy of this same data there, so that if you create an account later your progress is already there and nothing is lost. That identifier is not an advertising identifier and is used only to make the copy work.
An anonymous account is not a backup: if you uninstall the app without creating an account, nobody can get back to it. That is why we delete it automatically, with everything in it, after 90 days without use.
3.2 Anonymous usage statistics
If the Help improve the app option is on (it is on by default and you can turn it off in Parents' Area → Settings), the app sends us, once a day, summed counters such as "3 lessons of the knight island were started today".
These counters carry no user, device or account identifier and no nickname; the server discards who sent them and only adds up numbers. They cannot be traced back to anyone, so they are not personal data. We use them to learn which lessons are hardest and improve them.
3.3 If the adult creates an account (optional)
| Data | From whom | Why | Required? |
|---|---|---|---|
| Email address, or the identifier Apple or Google provides if you sign in with them | Adult | To identify the account and restore progress on another device | Yes, to have an account |
| A copy of the profiles (nickname, age range, companion) and their progress | Child profiles, provided by the adult | To sync between devices and keep progress safe | Yes, that is what the account is for |
| Internal account and profile identifiers | Generated by us | To know which account each progress record belongs to | Yes |
| Sign-in technical data: IP address, date, device type | Adult | Account security and abuse prevention | Yes |
If you use Sign in with Apple and choose to hide your email, we receive an Apple relay address, not yours.
We do not ask for a name, phone number, postal address, date of birth or payment details.
3.4 Notifications (optional)
When initial setup finishes, while the adult still has the device in hand, the app shows the system notification permission once. It never asks again. If you accept it, we store in your account or, if you have not created one, in the anonymous copy described in 3.1:
- The device's notification token (Firebase Cloud Messaging) and a device identifier generated by the app (not the manufacturer's or an advertising one).
- Your time zone and the app's language, so notifications arrive at a reasonable time and in your language.
- The date of the last game played and how many notifications were sent that week, so we never send too many.
Notifications go to the adult's device, never more than one a day or three a week, around 6 p.m. local time, and may mention the profile nickname (for example, "SwiftRook finished the bishop island"). You can turn them off at any time in the system notification settings.
3.5 Detailed activity log (optional, off by default)
Only if you turn it on in Parents' Area → Settings, after reading what it stores, we record per profile: sections viewed, time with the screen visible, exercises, difficulty, answers, hints used and interruptions.
It does not include free text, credentials, touch coordinates, photos, voice or location. It is not anonymous: it is linked to the profile and the account, which is why it is optional. We use it to understand how children learn with the app and to improve it; never for advertising or to make decisions about the child.
Practice and progress work exactly the same without it. You can turn it off and erase its history from the same screen.
3.6 App verification (App Check)
So that only the genuine app can talk to our servers, we use Firebase App Check, which asks the operating system (Apple App Attest or Google Play Integrity) to certify that the request comes from a legitimate copy of Roko installed from the store. That certificate contains no child data and no advertising identifiers, and we do not store it.
3.7 If you contact support
When an adult writes to us by email or through the website form, we process the email address, the message and anything you choose to tell us (for example, the device model or app version) in order to reply. The form asks you to confirm that you are an adult. Please do not include information about your child in the message; we do not need it to help you.
Suggestions you send from the app. If you write to us from Parents' Area → Help us improve, we keep only what you send: the topics you tick, the text you write, which screen it came from, the app version, the system (iOS or Android), the language and the date. It carries nothing from the child's profile: no nickname, age or progress. Please don't include names or personal details. There is no email field: if you want a reply, write to us yourself.
3.8 The website
The website uses no cookies, no analytics, no pixels and no third-party
fonts or scripts, except the service that delivers the support form (EmailJS),
which loads only on that page. It stores in your browser (localStorage)
only the language you choose, so it is shown next time.
The home page reads the app's content figures (how many puzzles, islands, etc.) from our Firebase database; that request carries no data about you.
Like any web server, the hosting provider (Firebase Hosting, by Google) technically logs the IP address and browser of each visit in order to serve the page and protect it from attacks. We do not use those logs for anything else.
3.9 What we never process
- Sensitive personal data (health, ethnic origin, beliefs, biometrics, etc.).
- Location, precise or approximate.
- Camera, microphone, photos, contacts or any other content on the device.
- Advertising identifiers (IDFA, AAID). Roko does not request Apple's tracking permission because it does not track.
- Payment data. If there are ever purchases, the store (Apple or Google) handles them, not us.
4. Purposes: which ones need your consent
Necessary purposes for the service you request (they cannot be turned off without giving up that feature):
- Making the app work and saving progress on the device.
- If you create an account: identifying you, syncing progress and allowing deletion.
- Keeping the account and our servers secure (App Check, technical logs).
- Answering your support messages and rights requests, and reading the suggestions you send us to improve the app.
- Complying with legal obligations.
Optional purposes, which only happen if you accept them and which you can refuse or withdraw at any time without losing anything else:
- Notifications with reminders and achievements (system permission).
- Detailed activity log (off by default).
Anonymous statistics (3.2) are not a purpose involving personal data, but you can turn them off too.
We do not do commercial profiling, advertising of any kind, data sales or automated decision-making that has effects on anyone. The adaptive difficulty of challenges is calculated on the device to choose the next exercise, and nothing else.
We do not use your data or your child's data to train artificial intelligence models.
5. Legal bases (for users in the European Union or the United Kingdom)
| Processing | Basis |
|---|---|
| Progress, profiles, account and sync | Performance of the contract you accept by using the app (Art. 6(1)(b) GDPR) |
| Security, App Check and technical logs | Legitimate interest in protecting the service (Art. 6(1)(f)) |
| Notifications and detailed log | Consent of the adult holding parental responsibility (Arts. 6(1)(a) and 8) |
| Support | Performance of the contract or pre-contractual steps; legitimate interest in helping you |
| Legal obligations | Art. 6(1)(c) |
6. Parental consent
Under Mexican law, consent to process a minor's data is given by whoever exercises parental authority or guardianship. In the United States (COPPA) and the European Union (Art. 8 GDPR) the same is required for children under 13 to 16, depending on the country. In Roko:
- The adult creates the profiles and the account. A child cannot create an account or change settings, because all of that sits behind the parental gate.
- When the app is used without an account, profile data stays on the adult's device: we do not receive it.
- By creating an account, the adult consents to our copying the profiles and progress to our servers to sync them.
- Optional features (notifications, detailed log) require an express action by the adult, explained before it is turned on.
- We do not condition a child's participation in any activity on providing more data than is necessary.
- The only persistent identifiers we use (account and profile identifiers, the notification token and the App Check certificate) are used for internal operations: saving and syncing progress, security, delivering the notifications you accepted and personalizing difficulty. Never for advertising, profiling or contacting the child.
If you are a parent or guardian and believe we hold data about your child that we should not, write to us and we will delete it.
7. Who we share data with
We do not sell, rent or give personal data to anyone. There are no advertisers or data brokers.
To provide the service we use these service providers (processors), which process data only on our behalf, under contract, and may not use it for their own purposes:
| Provider | What it does | Data |
|---|---|---|
| Google LLC / Google Ireland Ltd. — Firebase (Authentication, Firestore, Cloud Functions, Cloud Messaging, App Check, Hosting) | Accounts, database, server functions, notifications, verification and website hosting | The anonymous copy in 3.1, those in 3.3 to 3.6, the suggestions in 3.7 and the technical logs in 3.8 |
| Apple Inc. | Sign in with Apple, notification delivery on iPhone/iPad (APNs) and App Attest | Apple identifier, notification token, App Check certificate |
| Google (Sign in with Google, Play Integrity) | Sign-in and verification on Android | Google identifier, App Check certificate |
| EmailJS (EmailJS Pte. Ltd.) | Delivering the website support form to our inbox | Email, subject and message from the form |
| Google (Gmail) | Receiving and answering support email | Email address and support messages |
We would only disclose data to authorities when a law or a competent order requires it, and to whoever acquired Roko if it were ever sold, in which case this notice would continue to apply and we would tell you beforehand.
8. Where data is stored: international transfers
On your device, always: the local database is the source of truth.
In the cloud, only if you create an account or contact support: on Google
Cloud servers in the United States (region us-central1) and on those of
the providers in section 7.
If you are in the European Union, the European Economic Area, Switzerland or the United Kingdom, these transfers rely on the EU-U.S. Data Privacy Framework (Google and Apple are certified) and, where it does not apply, on the European Commission's Standard Contractual Clauses included in those providers' contracts.
9. How long we keep each item
We keep no personal data indefinitely. This is our retention policy:
| Data | How long | Then |
|---|---|---|
| Data on the device | While the app is installed or until you delete it | Removed with the app or with Delete data |
| Anonymous account (no account created) and its copy of profiles and progress | 90 days without use | Automatic deletion of the account and everything in it |
| Account, profiles and progress in the cloud | While the account exists. If it is not used for 24 months, we delete it (not used = the app was not opened online and nothing was played) | Permanent deletion, same as Delete data → everything |
| Notification token, time zone and language | While the account (or the anonymous copy) exists and the token is valid | Removed when the token expires, the account is deleted or permission is withdrawn |
| Detailed log: events | 90 days | Automatic deletion |
| Detailed log: daily summaries | 13 months | Automatic deletion |
| Support messages | 24 months after the last message | Deletion |
| Help us improve suggestions | While the account exists | When the account is deleted they are kept with no identifier at all: the text can no longer be linked to anyone |
| Server and website technical logs | Up to 30 days | Automatic deletion by the provider |
| Anonymous statistics | No limit, because they are not personal data | — |
When an account is deleted, its content is removed immediately from the live database. Our providers' systems may take up to 30 days to remove technical copies. Automatic deletion on expiry may run a few days after the stated date.
10. How to delete or limit the use of your data
In the app, in Parents' Area:
- Delete data → one profile: removes that profile, its progress and its activity, on the device and in the cloud.
- Delete data → everything: removes all profiles, the account and its copy on the server. This cannot be undone, and the app warns you first. Offline, local data is deleted immediately and remote data as soon as the connection returns; the app shows if anything is still pending. Suggestions you sent are kept, but with no account identifier.
- Settings → Help improve the app: turns off anonymous statistics.
- Settings → Save detailed activity: turns off the log and erases its history.
In the system: withdraw the notification permission.
By email or form: write to joseadrianmanutd@gmail.com or go to rokochess.com/en/delete-account and we will do it for you.
If you never created an account, uninstalling the app deletes what is on the device, and the anonymous copy on the server deletes itself after 90 days. If you want it gone right away, use Delete data → everything before uninstalling.
11. Your rights
As a data subject, or as the parent or guardian of a minor, you can ask us for:
- Access: what data we hold and how we use it. If you wish, we will send it to you in a readable, reusable format (portability).
- Rectification: correcting it.
- Erasure: deleting it. You can also do this yourself in the app.
- Objection: that we stop using it for a purpose.
- Restriction of processing and withdrawal of any consent you gave, without retroactive effect.
- As a parent or guardian (COPPA): to review your child's data, have it deleted and refuse further collection.
How: write to joseadrianmanutd@gmail.com from the account's email address (or tell us which one it is), including:
- Your name and a way to reply to you.
- Which right you want to exercise and on which data.
- If you act for someone else, that you are their representative (parent or guardian).
To protect the account, we may ask you to confirm the request from the account email or from the app. Exercising your rights is free.
Timing: we reply within 20 business days and, where applicable, carry it out within the following 15 business days, as provided by Mexico's Federal Law on the Protection of Personal Data Held by Private Parties. In the EU or the UK, within one month at most. If a complex case needs more time, we will tell you so and why.
12. If you disagree with our answer
- Mexico: you can file a data protection request with the Secretaría Anticorrupción y Buen Gobierno, the competent authority since the 2025 law (formerly INAI).
- European Union / EEA: with the data protection authority of your country.
- United Kingdom: with the Information Commissioner's Office (ICO).
- United States: you can contact the Federal Trade Commission (FTC) at ftc.gov.
We would appreciate it if you wrote to us first: almost everything can be solved with an email.
13. How we protect data
We maintain a written information security program, with a designated person in charge and an annual review of risks and providers, which includes:
- Encryption in transit (TLS) and at rest (Google infrastructure).
- Access rules under which each account can only read and write its own data; the detailed log is written only by the server.
- Verification that requests come from the genuine app (App Check).
- Data minimization: we do not collect what we do not need, so we cannot lose it.
- Access to systems limited to those who need it, with two-step verification.
No system is invulnerable. If a security breach significantly affected your rights, we would notify you without delay by email (if we have it) and in the app, explaining what happened and what you can do, and we would notify the authorities where the law requires.
14. U.S. residents
Roko complies with the Children's Online Privacy Protection Act (COPPA) as amended by the FTC in 2025. In addition to the above:
- The operator's contact information is in section 1.
- The categories of children's data, how they are used and the third parties that receive them are in sections 3, 4 and 7.
- The retention policy is in section 9.
- Parents' and guardians' rights are in section 11.
We do not sell or "share" personal information as those terms are used in state privacy laws (California and others), and we do not do targeted advertising. Residents of a state with its own privacy law can exercise the rights it grants through the same channels as in section 11, and will not be treated differently for doing so.
15. Changes to this notice
If we change this notice, the date and version at the top will change, and we will publish it at rokochess.com/en/privacy.
The text you see inside the app ships inside the app: it is not downloaded and cannot change without an update. If a change affects children's data or adds a new purpose, we will show it to you in the app and ask for your consent again before applying it.
16. Contact
Jose Adrian Rubiera Núñez
Ave Camino de los Parques 3880, Zapopan, Jalisco, 45133, Mexico
joseadrianmanutd@gmail.com · rokochess.com/en/support
We answer in English and Spanish.