Privacy Policy for Big Happy Holding Company and Subsidiaries (Peekaboo Interactive Games)

1. INTRODUCTION

This Privacy Policy explains how Big Happy Holding Company and its subsidiaries ("Big Happy," "we," "our," or "us") collect, use, and protect information when you use our services.

The key points: We collect only anonymous technical data to improve our apps. We never collect personal information from children or adults.

This policy complies with applicable data protection laws including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and the Children's Online Privacy Protection Act (COPPA).

2. OUR COMMITMENT TO PRIVACY

We believe in protecting privacy, especially for children. Our data practices are designed to be minimal, anonymous, and focused solely on improving app performance and stability.

2.1 Our Principles:

• No personal information collection from anyone
• Anonymous technical data only
• Data used solely for app improvement
• No advertising or marketing use
• Full COPPA compliance for children's safety

3. DATA WE COLLECT

3.1 Anonymous Technical Data:

We collect limited, anonymous technical information including:

• App usage patterns (which features are used, session duration)
• Performance metrics (loading times, feature usage frequency)
• General device information (operating system version, device type - but not device identifiers)

• Technical error information when apps crash
• Device performance data related to crashes
• App version and operating system information

3.2 What We Do NOT Collect:

• Names, email addresses, or any contact information
• Photos, videos, audio recordings, or user-generated content
• Location data or precise geographic information
• Device identifiers or advertising IDs
• IP addresses or browsing history
• Any information that could identify individual users
• Any personal information from children or adults

3.3 Data Anonymization:

All data we collect is anonymous and cannot be linked to specific individuals, devices, or children. We use technical measures to ensure collected data cannot identify users.

4. HOW WE USE DATA

4.1 Permitted Uses:

• Improve app performance and stability
• Fix bugs and technical issues
• Understand which features are most helpful
• Optimize app functionality across different devices

4.2 We Do NOT Use Data For:

• Advertising or marketing
• Selling to third parties
• Creating user profiles
• Tracking individual behavior
• Any commercial purposes beyond app improvement

5. CHILDREN'S PRIVACY PROTECTION

5.1 COPPA Compliance:

• We do not collect personal information from children under 13
• All data collection is anonymous and cannot identify children
• We do not require children to provide any information to use our apps
• We do not share any information that could identify children

5.2 Anonymous Data and Children:

The anonymous technical data we collect (crash reports and usage analytics) cannot be linked to any specific child and is used only to make our apps work better and more safely for all users.

5.3 Parental Rights:

Since we collect no personal information, there is no personal data about your child to review, modify, or delete. Parents may contact us with questions about our privacy practices.

5.4 Safe App Design:

• No social features or communication tools
• No links to external websites
• No advertising
• No personal information collection mechanisms
• No behavioral tracking of individual children

6. DATA SHARING AND THIRD PARTIES

6.1 Third-Party Services:

We use reputable third-party services for anonymous analytics and crash reporting, such as:

• Mobile analytics platforms (for anonymous usage statistics)
• Crash reporting services (for technical error information)

6.2 Data Sharing Restrictions:

• All data shared with third parties is anonymous
• Third parties cannot identify individual users or children
• We do not sell data to anyone
• We do not share data for advertising purposes
• Third parties are contractually bound to protect data privacy

6.3 Legal Disclosures:

We may disclose anonymous data if required by law, but since our data cannot identify individuals, such disclosures would not compromise personal privacy.

7. COOKIES AND TRACKING

7.1 Mobile Apps:

Our apps use anonymous analytics SDKs that may store anonymous identifiers locally on your device. These cannot identify you personally and are used only for anonymous usage analytics.

7.2 Website:

Our website may use essential cookies for basic functionality. We do not use tracking cookies for advertising or behavioral targeting.

8. DATA SECURITY

We implement appropriate technical and organizational security measures to protect the anonymous data we collect, including:

• Secure data transmission
• Access controls and authentication
• Regular security assessments
• Secure data storage practices

9. DATA RETENTION

9.1 Retention Period:

Anonymous analytics and crash data is retained only as long as necessary for app improvement purposes, typically no longer than 24 months.

9.2 Data Deletion:

Since all data is anonymous, individual deletion requests are not applicable. However, we regularly purge old anonymous data as part of our standard data management practices.

10. YOUR RIGHTS

10.1 General Rights:

Since we collect only anonymous data that cannot identify individuals:

• Traditional data subject rights (access, rectification, deletion) don't apply to anonymous data
• You may contact us to confirm our data practices
• You may request information about our privacy practices
• You may lodge complaints with data protection authorities

10.2 California Residents (CCPA/CPRA):

• Right to Know: We collect only anonymous technical data as described above
• Right to Delete: Not applicable to anonymous data that cannot identify you
• Right to Opt-Out: We do not sell personal information
• Right to Non-Discrimination: We provide equal service to all users

10.3 EU/UK Residents (GDPR):

Since we process only anonymous data that cannot identify individuals, GDPR rights related to personal data do not apply. You may contact us to confirm our practices.

11. CONTACT INFORMATION

Data Protection Officer: Mark Barney

Mailing Address:
Big Happy Holding Company
653 Pudding Hill Road
Hampton, CT 06247
USA

Phone: (860) 294-4111
Email: [email protected]

Response Time: We will respond to all inquiries within 30 days.

12. LEGAL COMPLIANCE

12.1 Governing Law:

This Privacy Policy is governed by the laws of Connecticut, USA, except where applicable data protection laws require compliance with local jurisdictional requirements.

12.2 Regulatory Compliance:

• Children's Online Privacy Protection Act (COPPA)
• California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• General Data Protection Regulation (GDPR)
• Other applicable privacy laws

13. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Any changes will be posted on our website with an updated "Last Updated" date.

Continued use of our services after changes are posted constitutes acceptance of the updated policy.

Summary

We collect only anonymous technical data (usage analytics and crash reports) to improve our apps. This data cannot identify you or your children and is never used for advertising, marketing, or sold to third parties. Your privacy and your children's privacy remain fully protected because we never collect personal information of any kind.

If you have questions about this policy or our practices, please contact us using the information provided above.