Beta Privacy Policy
Last updated 21 September 2026
This policy covers the Little Stomp Club app while it is in closed beta testing, and everything we do around that testing. It sits alongside our website privacy policy, which covers brightlobe.com and littlestompclub.com. Where the two overlap, this one wins for anything to do with the beta.
The short version: the app has no accounts, no advertising, and never profiles your child. Nothing measures what your child does in the game. The app talks to exactly one company, described in section 3: RevenueCat, which knows whether this device has a membership. It is told nothing about your child. When the app crashes, the report goes to Apple, not to us directly. What we hold about a person is what you, the grown-up, give us. What we hold is what you, the grown-up, give us: your email address, your survey answers, and, only if you separately agree to it, recordings of a play session. We never sell any of it, and we never let anyone outside Brightlobe watch your child.
1. Who we are
Brightlobe is the data controller for the personal data described here. Under COPPA we are the operator.
| Controller / operator | Brightlobe Limited |
|---|---|
| Company number | 08376959 |
| Registered address | Brightlobe, 124 City Road, London, EC1V 2NX, United Kingdom |
| Contact | hello@brightlobe.com |
2. Who this policy is for
Little Stomp Club is made for children of roughly three to five. The beta programme is not. Only an adult of 18 or over, who is the parent or legal guardian of the child who will play, can be a tester. Everything described here is agreed to by that adult, for themselves and on behalf of their child.
We do not deal with children directly at any point. There is no sign-up inside the app, nothing for a child to type, and no way for a child to contact us or be contacted by us.
3. What the app sends, and what it does not
This is the important part, so we will be specific. The beta build of Little Stomp Club:
- has no accounts and no log-in. There is nothing to register and no profile;
- has no analytics. No gameplay events, no session telemetry, no heat maps. Nothing measures what your child does in the game;
- has no advertising. No ad network, no ad identifier, no App Tracking Transparency prompt, because there is nothing to track;
- never asks your child for payment details. Payment happens in Apple's own checkout. Neither we nor anyone working for us ever sees your card;
- does not use the microphone, camera, photo library, contacts, location, Bluetooth or health data;
- has no social features. No chat, no messaging, no sharing, no user-generated content;
- does not build a profile of your child and makes no automated decisions about them.
Progress, settings and anything your child does in the game are written to the device itself and stay there. Deleting the app deletes them. We cannot see them, and we have no way to retrieve them.
The one service the app talks to
The app is not fully offline, and we would rather say so plainly than let you discover it. It contacts one company. It is not told your child's name, age, or anything they do in the game.
| Service | What it is for | What it receives | Where |
|---|---|---|---|
| RevenueCat, Inc. | Tells the app whether this device has a paid membership, and would handle a purchase. | An anonymous identifier that RevenueCat generates itself, plus device model, operating system version, app version, country and the connecting IP address. We do not give it your name, your email or your child's details, and we do not link it to your beta sign-up. | USA |
RevenueCat is contacted when the app starts, whether or not anyone ever buys anything. During the beta the membership screen is visible so that we can test it, but purchasing is switched off and nothing can be bought.
We deliberately use no third-party crash or analytics service. When the app fails, we rely on Apple's own crash reporting, described below, because it keeps the report inside a company you already have a relationship with rather than introducing another one. If that ever changes, section 14 says what we will do.
Crash data through Apple
Beta builds are handed out through Apple's TestFlight. When the app crashes, TestFlight may send Apple a technical crash log, and Apple shows us a version of it. These logs describe what the software was doing when it fell over: device model, operating system version, and where in our code the fault happened. They are not tied to a name or an email address, and they do not tell us anything about your child.
That collection is Apple's, under Apple's privacy policy and the TestFlight terms you accept when you install it. You can turn it off: on the device, open the TestFlight app, choose Little Stomp Club, and switch off the sharing of crash and usage data.
We use error and crash data only to fix the app. We never use it to contact anyone, to advertise, or to build a profile of any kind.
4. What we collect from you, the grown-up
| Data | Where it comes from | Why |
|---|---|---|
| Your email address | The beta sign-up form, or an email you send us | To send your TestFlight invitation and talk to you about testing |
| Your first name, if you give it | The sign-up form | So we are not writing to you as "Dear Tester" |
| Your child's age in years, and the device you will use | The sign-up form | To make sure the build fits the age we are testing and runs on your hardware |
| Your confirmation that you are the parent or guardian, are 18 or over, and consent | Recorded with your sign-up, along with the date and which form you used | It is our record that we were allowed to do any of this |
| Your survey answers and anything you write to us about the game | Feedback forms and emails | To work out what to change |
We do not ask for your address, your phone number, your date of birth or any payment details, and none of our forms has a box for them. We ask for your child's age, not their date of birth. We do not need your child's full name, and you should not send it.
5. Watching children play, and recording it
Some testers take part in an observed play session: we watch a child use the game, in person or over a video call, and we take notes. With separate permission, we record the session as video or audio. This is optional. It is a different decision from joining the beta, we ask for it on its own, and you can say no and stay in the programme with nothing changed.
What a recording contains
A recording of a child playing is personal data about that child, and we treat it as the most sensitive thing we hold. It will normally show their hands and the screen, and capture their voice, their reactions and whatever they say while playing. Faces may appear. That is why the rules below are strict.
What we do with it
- Design only. We watch recordings to see where a three-year-old gets stuck, what they try, and what makes them give up. That is the entire purpose.
- Only Brightlobe watches them. They are not shown to investors, not used in pitch decks, not put in marketing, not posted anywhere, and not shared with any other company.
- Never used to train artificial intelligence. Not by us, and not by anyone else.
- Never sold, rented or licensed. Not now, not later.
- Not published in research. If we ever want to use a clip in something public, in a talk, a paper or a demo, we will come back and ask you again, describing exactly what we want to show. Silence is not a yes.
Where they are kept, and for how long
| Stored in | A restricted folder in Brightlobe's Google Workspace (Google Drive), which only the owner of Brightlobe can open |
|---|---|
| Protected by | Encryption in transit and at rest, two-factor authentication, and no public or link sharing |
| Kept for | Up to 12 months after the end of the beta, then deleted. Sooner if you ask |
| Your copy | Ask and we will send you the recording of your own child |
Notes we take while watching are written without your child's name and are kept on the same basis.
Taking it back
You can withdraw consent to recording at any time, for any reason, without giving one. Email us and we will delete the recordings of your child, usually within seven days and always within one month, and confirm when it is done. You do not have to leave the beta to do this.
6. Why we are allowed to hold any of it
Your consent, under Article 6(1)(a) of the UK GDPR. There are three separate consents and they are asked for separately: one to join the beta and be emailed about it, one for your child to take part in an observed session, and one for that session to be recorded. You can withdraw any of them without affecting the others.
Withdrawing consent does not make what we did beforehand unlawful, but it stops us going on.
One thing does not run on consent, because consent would be the wrong basis for it and pretending otherwise would offer you a choice we could not honour:
| What | Basis | Why |
|---|---|---|
| The RevenueCat membership check | Performance of a contract, Article 6(1)(b), or legitimate interests where there is no membership | The app has to know whether this device has access. There is no way to deliver a paid membership without checking it. |
Where we rely on legitimate interests you have the right to object, and we will tell you the outcome. Ask us for our assessment and we will send it.
Where we hold a record that you consented, and the date you did, we keep that as evidence of compliance. That is our legitimate interest under Article 6(1)(f), and it is the one thing that survives a withdrawal, because it is the proof that we behaved properly.
7. Families in the United States
The beta is open to families in the United Kingdom and the United States. If you are in the US, the Children's Online Privacy Protection Act applies, and this section is our notice to you under it.
- What we collect from children: the only personal information of a child we ever hold is a recording of a play session, and only where you have agreed to it, plus your child's age in years, which you give us yourself.
- Persistent identifiers: COPPA treats a device identifier as personal information. The app generates one, for RevenueCat. It falls within COPPA's exception for identifiers used solely to support the internal operations of the service: knowing whether this device has a membership, and keeping the app working. We rely on that exception honestly. We do not use it for advertising, for behavioural profiling, for audience measurement, or to contact anyone. If that ever changed the exception would stop applying, and we would come back and ask you first.
- How we get your consent: you give it yourself, as the parent or guardian, on the sign-up form and again before any recording. We never collect anything from a child before you have.
- We never make participation conditional on you disclosing more about your child than the beta reasonably needs. You can join without ever agreeing to be recorded.
- You can review it. Ask and we will tell you exactly what we hold about your child and send you a copy.
- You can stop it. Ask and we will delete your child's information and stop collecting anything further, while you stay in the beta or leave it, as you prefer.
- We do not disclose children's information to third parties for their own purposes, ever. The only companies that touch it are the providers in section 9, acting on our instructions.
- We do not condition any part of the game on a child giving us information, because the game never asks a child for anything.
To exercise any of this, email hello@brightlobe.com. We will verify you are the parent we already have on file before we act, which usually means replying from the address you signed up with.
8. Designing for children: the Children's Code
The Information Commissioner's Age Appropriate Design Code, usually called the Children's Code, applies to online services likely to be accessed by children in the UK. A game made for three-to-five-year-olds is plainly one of those. Rather than simply assert that we comply, here is each of its fifteen standards and what we actually do.
| Standard | What we do |
|---|---|
| Best interests of the child | Where a design choice is good for us and bad for the child, the child wins. That is why there is no advertising, no profiling, and nothing that measures how they play. |
| Data protection impact assessment | We keep a written assessment covering the beta, the session recordings, and the one service the app contacts. We review it before any change to what the app collects. Ask and we will share it. |
| Age appropriate application | We know our audience: children of roughly three to five, playing with an adult nearby. The beta programme itself is adults-only, and we establish that through the parent, never by questioning the child. |
| Transparency | This policy is written to be read by a tired parent, not a lawyer. Where something is awkward, such as the app not being fully offline, we say so in plain words rather than burying it. |
| Detrimental use of data | We do not sell data, share it for anyone else's purposes, or use it in any way shown to be harmful to children. Recordings are never used to train artificial intelligence. |
| Policies and community standards | We hold ourselves to what is written here. If we fall short, tell us and we will fix it and say what happened. |
| Default settings | High privacy by default, with nothing a parent has to find and switch off. We use no third-party analytics or crash service at all, so there is no privacy-reducing option for a parent to discover and switch off. |
| Data minimisation | The app collects nothing about your child. The one service it contacts receives technical data about the device and the software, and nothing about the person holding it. |
| Data sharing | We do not share children's data. The companies in section 9 process it for us, on our instructions, for no purpose of their own. |
| Geolocation | Not used and not requested. The app has no location permission, and nothing in it knows or asks where your child is. |
| Parental controls | Nothing in the app tracks a child, so there is nothing a parent needs to switch off, and nothing that would let anyone monitor a child covertly. Device-level screen time controls remain yours to set. |
| Profiling | Off, and not built at all. We do not profile children, we make no automated decisions about them, and nothing in the game adapts based on a stored model of a particular child. |
| Nudge techniques | No streaks, no daily rewards, no login bonuses, no leaderboards, no push notifications, and nothing that pressures a child to keep playing or to hand over more data. During the beta nothing can be bought at all. When the membership does go on sale, the commerce will sit behind a parental gate, as Apple requires and as we would do anyway. |
| Connected toys and devices | Not applicable. The app connects to no physical device, toy or accessory. |
| Online tools | Every right in section 12 is exercised by sending one email to hello@brightlobe.com. There is no form to hunt for, no account to log into, and no fee. |
9. Who else can see it
We do not sell or rent your data, and we never will. A small number of providers process it for us, on our instructions:
| Provider | What they do | Where |
|---|---|---|
| Apple Inc. | Distributes the beta through TestFlight, and collects the crash data described in section 3. Apple holds the Apple ID you install with, under its own privacy policy. | USA / EU |
| Google (Google Workspace) | Our email, and the restricted Drive folder holding session recordings and notes. | USA / EU |
| Mailchimp (Intuit Inc.) | Holds the beta mailing list and sends the emails. | USA |
| Cloudflare, Inc. | Hosts our websites and routes email sent to our addresses. | Global network |
| RevenueCat, Inc. | Tells the app whether this device has a membership, as described in section 3. | USA |
We may also disclose data where the law requires it of us. If we are ever legally compelled to hand over anything about a child, we will tell you unless we are forbidden from doing so.
If Brightlobe is ever sold or merged, data may transfer to the buyer. Session recordings are the exception: we will delete them rather than transfer them, unless you tell us otherwise.
10. Data leaving the UK
Apple, Google, Mailchimp, Cloudflare and RevenueCat are US companies, so some of this sits outside the UK. Those transfers rely on the UK's approved safeguards: the UK Extension to the EU-US Data Privacy Framework, and the International Data Transfer Addendum to the EU Standard Contractual Clauses. Ask us and we will give you the detail.
11. How long we keep things
| What | How long |
|---|---|
| Your email address and beta correspondence | Until you unsubscribe or ask us to delete it, or 24 months after our last contact with you, whichever comes first |
| Survey answers and written feedback | Up to 24 months after the beta ends, then deleted or stripped of anything identifying |
| Session recordings and observation notes | Up to 12 months after the beta ends, then deleted |
| Your child's age and device details | Until the end of the beta |
| The RevenueCat device record | For as long as the app is installed and a membership exists. Ask us and we will have it deleted |
| The record that you consented, and when | Six years, as our evidence that we were entitled to hold the rest |
12. Your rights
Under UK GDPR you can ask us to give you a copy of what we hold about you or your child, correct it, delete it, restrict or object to how we use it, send it to you or someone else in a portable format, or stop entirely by withdrawing consent. US families have the equivalent rights under COPPA, set out in section 7.
Email hello@brightlobe.com. It is free, and we will respond within one month. For deletion of a recording we aim for seven days.
If you are unhappy with how we have handled it, you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We would much rather you told us first so we can put it right.
13. Keeping it safe
Recordings sit in a restricted Drive folder with two-factor authentication on the account and no link sharing of any kind. Our sites are served over HTTPS only. Access is limited to the owner of Brightlobe. We are a very small company, which means the list of people who can see anything is short.
No system is perfectly secure. If a breach ever put your data or your child's at risk, we will tell you and the ICO, and we will tell you plainly what happened.
14. Changes
If we change this policy we will update the date at the top. If a change is significant, or if the app ever starts collecting something it does not collect today, we will email every tester and ask again before it takes effect for them. We will not quietly widen what we collect from a child.
15. Contact
Questions, requests, second thoughts or complaints: hello@brightlobe.com