Lupis Entdeckerreise
Privacy Policy – Lupi's Discovery Journey (Lupis Entdeckerreise)
Last updated: November 4, 2026
This privacy policy applies to the iOS app "Lupis Entdeckerreise" (home screen name: "Lupi"). In short: the app does not collect any personal data. It has no ads, no tracking, no user account, and it does not connect to the internet by itself.
1. Controller
Marcus Kailbach
Burgstr. 32
50181 Bedburg
Germany
Email: mk.devapp@proton.me
2. Principle: no data collection
The app is made for children from about 3 years of age. It is built so that no data about the child or the parents ever reaches us:
- no account, no sign-in, no entry of names, age or other details
- no advertising and no advertising identifiers (IDFA)
- no analytics, no statistics services, no crash reports sent to us, no third-party SDKs that send data
- no access to camera, microphone, photos, contacts or location
- no links to the internet and no social media integration
- the app works completely offline
3. Data stored only on the device
To work, the app stores a few things only locally on the device:
- game progress: stars collected, games completed, when a world was last played
- treasures found in "Lupi's den"
- settings from the parents' area: volume of voice, sounds and music, daily play time
- the play time used today and – when play time is over – the place in the app to continue from
- whether the full version has been purchased
This information never leaves the device and is not transmitted to us. We cannot see it. It is deleted when the app is deleted from the device.
Note: if iCloud or computer backups are enabled on the device, iOS may include this app data in the backup, as it does for other apps. Apple is responsible for this; we have no access to it.
4. App Store and in-app purchase
The app is downloaded from Apple's App Store. The "Forest" and "Farm" worlds are free; the other worlds can be unlocked with a one-time in-app purchase ("All Worlds"). The purchase is protected by a parental gate (a math question).
Download, purchase, payment, Family Sharing and "Restore Purchases" are handled entirely by Apple; iOS connects to Apple for this. We do not receive any personal data such as your name, Apple ID or payment details; the app only checks on the device whether the purchase exists. Apple only provides us with aggregated, non-personal sales figures.
Apple's privacy policy applies to Apple's processing: https://www.apple.com/legal/privacy/
5. Lupi's voice
Lupi's voice was created with artificial intelligence (AI). All lines are included in the app as finished audio files. The app does not record anything and does not send text or audio to any AI service.
6. Children
The app is aimed at children aged about 3 to 6. We do not collect personal data from children (see section 2). Purchases and the parents' area are protected by a parental gate.
7. Contact by email
If you email us, we process your email address and the content of your message in order to answer your request (Art. 6(1)(b) GDPR for questions about the app, or Art. 6(1)(f) GDPR – legitimate interest in answering enquiries). We delete this data once your request has been dealt with, unless we are legally required to keep it.
8. Your rights
Under the GDPR you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object (Art. 21). Since the app itself does not transmit any data to us, in practice this only concerns emails you have sent us. Please contact us at the email address above.
You also have the right to lodge a complaint with a data protection supervisory authority, for example in your place of residence or the authority responsible for us: the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (LDI NRW), Kavalleriestraße 2–4, 40213 Düsseldorf, Germany.
9. Changes
If the app changes in a way that affects how data is processed, we will update this privacy policy. The current version is always available in the app, in the parents area.
10. This website
The following also applies to this website: it provides information about the app, sets no cookies, uses no analytics or advertising services, embeds no third-party content and has no forms.
The website is hosted on Cloudflare Pages (Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA). When you visit it, Cloudflare processes technically necessary data such as your IP address, the time, the page requested and browser details in order to deliver the page and protect it against attacks (Art. 6(1)(f) GDPR – legitimate interest in a secure, working website). Data may be transferred to the USA; Cloudflare is certified under the EU-US Data Privacy Framework (Art. 45 GDPR). More information: https://www.cloudflare.com/privacypolicy/
Emails to us are handled by the provider Proton AG (Switzerland). Your rights under section 8 also apply here.