Privacy Policy

Last updated: 2026-05-15

Effective date: 2026-05-13 Version: 1.0

This Privacy Policy describes how TLM Software Design, Inc. (“TLM,” “we,” “us,” “our”) handles information in connection with the Word Puzzle mobile application and its accompanying website at apps.swtlm.com/word-puzzle-game/ (together, the “Service”).

1. Plain-English summary

We built Word Puzzle as a quiet, ad-free word-puzzle game for children ages 4 and up (typical play range 6–9). We collect as little information as possible.

We do not ask for, collect, or knowingly store any personal information from children — no name, email address, photo, voice recording, location, or contact list.
We do not show advertisements.
We do not sell, rent, or trade personal information.
We do not use advertising identifiers (IDFA / GAID).
We do not create user profiles for marketing.
We do not track children across apps or websites.
The game stores your child’s progress on their device. It is not uploaded to our servers.

We do use a small, fixed set of privacy-respecting tools — Firebase Analytics (Google) for aggregate, non-personalized usage signals and Firebase Crashlytics (Google) for crash diagnostics. Both are configured with child-safe defaults: no advertising identifiers, no cross-app tracking, no audience inference, no Google Signals.

This summary is a courtesy. The defined terms of this Policy are the sections that follow.

2. Who we are

The data controller / business responsible for the Service is:

TLM Software Design, Inc. 27280 Haggerty Road, Ste. C-6 Farmington Hills, MI 48331 United States

Contact: privacy@swtlm.com

Word Puzzle is published worldwide by TLM Software Design, Inc. through the Apple App Store and Google Play. Where the App Store or Google Play appears as the “Seller” of record in a particular jurisdiction, that relationship governs the underlying purchase transaction.

3. Scope of this Policy

This Policy applies to:

The Word Puzzle application installed from the Apple App Store or Google Play.
The website at apps.swtlm.com/word-puzzle-game/ and its sub-pages (including /privacy, /terms, /support, and /press).

It does not apply to other websites, services, or applications that may be linked from the Service, including the Apple App Store, Google Play, or any third-party site reached through an “About” or “Support” link.

4. Children’s Privacy — COPPA

We have designed Word Puzzle to be safe for children. We comply with the United States Children’s Online Privacy Protection Act (COPPA) (15 U.S.C. §§ 6501–6506) and the FTC’s COPPA Rule (16 C.F.R. Part 312).

4.1 What we do not collect from children

Word Puzzle is engineered so that we do not collect any “personal information” from children as defined by COPPA. We do not collect:

First or last name.
Home or other physical address (or any element of it, including street name and city or town).
Online contact information (e-mail, instant-messaging user identifier, voice-over-internet identifier, screen name, user name).
Telephone number.
Social-security number.
A persistent identifier that can be used to recognize a user over time and across different web sites or online services, including cookies, customer numbers held in cookies, IP addresses, processor or device serial numbers, or unique device identifiers — except as specifically and narrowly described in Section 4.3 for support of the internal operations of the Service.
A photograph, video, or audio file containing a child’s image or voice.
Geolocation information sufficient to identify street name and name of a city or town.
Information concerning the child or the parents of that child that the operator collects online from the child and combines with an identifier described above.

4.2 What the child sees on screen

The on-device game stores progress (which levels are complete, coins earned, cards collected, settings preferences, paused-level state, and purchase-entitlement state) in a sandboxed application directory on the device. This data never leaves the device in identified form and is not transmitted to TLM, Google, Apple, or any other party — except:

Aggregate, non-identifying gameplay events transmitted to Firebase Analytics under the safeguards in Section 4.3.
Crash diagnostics transmitted to Firebase Crashlytics under the safeguards in Section 4.3.
Purchase records held by Apple / Google for the in-app bundle purchase (we receive only an anonymized entitlement signal — see Section 7).

A parent can erase all on-device progress at any time through the Parents Hub → Privacy → Delete local data control.

4.3 Permitted internal-operations data (COPPA § 312.4(c)(3))

The COPPA Rule permits operators to collect a narrow set of persistent identifiers solely to support the internal operations of the service. We rely on this exception for:

A device-scoped, randomly-generated identifier (“instance ID”) assigned by the Firebase SDK. The instance ID is generated locally on the device, is not derived from any user-identifying information, cannot be used to recognize the user across different apps, and is reset when the child deletes the app.
Crash-diagnostic context assembled by Firebase Crashlytics: device model, operating-system version, app version, locale, free disk space, free memory, and a stack trace of the failing thread. Crash diagnostics are transmitted only when a crash occurs.

We do not use these identifiers for:

Behavioural advertising.
Audience profiling, look-alike modeling, or marketing analytics.
Cross-app tracking.
Building a profile that is shared with any third party.

We explicitly disable the following Firebase features:

setAnalyticsCollectionEnabled(true) is called only after the application has applied a child-safe consent vector that denies AD_STORAGE, AD_USER_DATA, and AD_PERSONALIZATION and grants ANALYTICS_STORAGE for permitted internal-operations events only.
Google Signals (cross-device user-graph linking) is off.
Audiences and remarketing audiences are off.
IDFA / GAID (advertising identifiers) are not requested.
Personalized-ads exchange with Google Ads is off.

These settings are enforced in our source code at the application binary level and are not user-toggleable.

Because Word Puzzle does not collect personal information from children as defined by COPPA, the rule’s verifiable-parental-consent requirement (16 C.F.R. § 312.5) does not apply to our data practices.

However, the in-app Parents Hub is gated by an arithmetic challenge (“parental gate”) designed to limit child access to: (a) parental settings, (b) the in-app purchase flow, (c) external links to this Privacy Policy, the Terms of Use, the support inbox, the Apple Privacy Policy, or the Google Privacy Policy. This is not a substitute for verifiable parental consent under COPPA; it is a child-design convention.

4.5 Parents — your rights under COPPA

A parent or legal guardian may at any time:

Review the categories of information we receive about their child (Section 6). Because we do not associate any of that information with a specific child, we cannot provide a per-child report — but the categories themselves are fully disclosed in this Policy.
Direct us to delete Firebase Analytics or Crashlytics data associated with your child’s device. Email privacy@swtlm.com from the address you supply, with the device’s Firebase instance ID (available under Parents Hub → Privacy → Diagnostic info). We will delete the records associated with that instance ID within 30 days.
Refuse to permit further collection. Email privacy@swtlm.com. We will set your child’s device into “no analytics” mode by issuing a remote-config signal; you may also uninstall the app, which deletes all on-device data.

4.6 Parental notification

This Policy serves as direct notice to parents of our information practices, pursuant to COPPA § 312.4(d). The Apple App Store and Google Play listing pages, our website at apps.swtlm.com/word-puzzle-game/, and the in-app Parents Hub → Privacy policy link each provide prominent access to this Policy.

5. Information we collect

5.1 From the child’s device (limited to internal operations)

Firebase instance ID (Section 4.3).
Aggregate gameplay events — anonymous counts of: app open, level start, level complete, hint use, pack purchase, app crash, app foreground/background. Events carry the app version, device model, device OS version, and device locale. No event carries an account identifier, email address, name, or contact information, because none exists.
Crash diagnostics (Section 4.3).

5.2 From the parent (when the parent chooses to contact us)

Email address and message content when the parent emails support@swtlm.com or privacy@swtlm.com. We use the email address only to reply. We do not add it to any marketing list. We retain support correspondence for as long as needed to resolve the matter and then for a reasonable archive period not exceeding 24 months.

5.3 From the App Store / Google Play (purchase records)

When the parent buys the in-app “All Packs” bundle, the App Store or Google Play handles payment and provides us, via the RevenueCat receipt-validation service we use as a processor, with an anonymized entitlement signal indicating that a device is entitled to the bundle. We receive no payment-card number, billing name, billing address, or contact information from the platform.

5.4 From the website

Server access logs generated by our hosting provider (Amazon Web Services / CloudFront) when a visitor loads a page. Logs may include the visitor’s IP address, the requested URL, the HTTP status code, the user agent, and a time stamp. We use these logs to operate the site and to investigate abuse. We do not associate website logs with any child or with any in-app activity.
The website sets analytics cookies (_ga, _ga_*) via Google Analytics to measure aggregate visitor behaviour (pages visited, session count, referral source). These cookies are set only after you give consent via the cookie banner on first visit. The website sets no marketing cookies, ad-targeting cookies, or third-party tracking pixels beyond Google Analytics.

6. How we use information

We use the limited information described in Section 5 only for the following purposes:

To operate and maintain the Service.
To debug and improve the Service — fix crashes, identify performance regressions, understand which gameplay flows are reached, in aggregate.
To respond to support requests (Section 5.2).
To detect, prevent, and address technical issues, abuse, fraud, and security incidents.
To comply with law and respond to lawful requests and legal process.

We do not use any information for behavioural advertising, profiling, automated decision-making with legal effect, or training of machine-learning models.

We do not sell personal information. We share information only with the following categories of recipients, each of which acts as our processor / service provider:

Google (Firebase Analytics, Firebase Crashlytics, Firebase Storage). Hosts aggregate analytics events, crash diagnostics, and the paid-pack content delivery network. Firebase is configured with the child-safe settings in Section 4.3. Google’s privacy policy: policies.google.com/privacy.
Apple (App Store, in-app-purchase processing). Apple handles payment for in-app purchases. Apple’s privacy policy: apple.com/legal/privacy.
Google (Google Play, in-app-purchase processing). Google handles payment for in-app purchases on Android. Google’s privacy policy: policies.google.com/privacy.
RevenueCat (in-app-purchase receipt validation). RevenueCat validates App Store and Google Play receipts and provides us with the anonymized entitlement signal in Section 5.3. RevenueCat’s privacy policy: revenuecat.com/privacy.
Amazon Web Services (website hosting). AWS hosts the website static files (Amazon S3) and the content delivery network (CloudFront). AWS’s privacy notice: aws.amazon.com/privacy.

We share information with these processors only to the extent necessary for them to perform the service described above. We do not authorize any processor to use the information for its own commercial purposes.

We may also disclose information when required by law, in response to a valid subpoena, court order, or other legal process; to protect our rights or property; to protect the safety of any person; or in connection with a corporate transaction (merger, acquisition, financing, reorganization, sale of assets, or bankruptcy), in which case any acquiring party will be bound to protect the information on terms no less protective than this Policy.

8. International data transfers

TLM Software Design, Inc. is based in the United States. Information collected by the Service may be processed and stored in the United States and in any country where our processors operate (today: United States, European Union, United Kingdom, and certain Google Cloud regions).

For visitors and users in the European Economic Area (EEA), the United Kingdom, and Switzerland: where personal information is transferred from those regions to the United States or another country that has not been deemed to offer an adequate level of data protection, we rely on the European Commission’s Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) and, where applicable, the EU-U.S. Data Privacy Framework, as the lawful transfer mechanism.

9. Retention

On-device data (gameplay progress, coins, album, settings, purchase entitlement) is retained on the device until the parent clears it via Parents Hub → Privacy → Delete local data, the parent uninstalls the app, or the operating system clears application data.
Firebase Analytics events are retained for 14 months from the date of collection and then aggregated or deleted.
Firebase Crashlytics records are retained for 90 days from the date of collection.
Support correspondence is retained as described in Section 5.2.
Server access logs are retained for 90 days from the date of collection and then deleted.
Purchase / entitlement records are retained as long as the entitlement remains active so we can honour restored-purchase requests.

10. Security

We use commercially reasonable administrative, technical, and physical safeguards to protect information against loss, theft, unauthorized access, use, or alteration. These safeguards include:

Transport-layer encryption (HTTPS / TLS 1.2+) for all network communication.
Strict access controls on our cloud infrastructure (least-privilege IAM, multi-factor authentication on every administrator account).
Source-code review and automated security testing prior to every release.
A privacy-by-design architecture: the app and the website are built so that no personal information from children is collected in the first place (Section 4.1).

No method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect information, we cannot guarantee absolute security. You assume the inherent risks of internet use.

11. Your rights under U.S. state privacy laws

11.1 California (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, gives you the following rights:

Right to know what categories of personal information we have collected, the sources of that information, the business purpose for which we collected it, and the categories of third parties with whom we share it. Sections 5 and 7 satisfy this disclosure obligation.
Right to delete the personal information we have collected about you, subject to certain statutory exceptions.
Right to correct inaccurate personal information.
Right to opt out of “sale” or “sharing” of personal information. TLM does not sell or share personal information as those terms are defined in the CCPA. The Service does not engage in cross-context behavioural advertising.
Right to limit use of “sensitive personal information.” TLM does not collect “sensitive personal information” as defined by the CCPA.
Right to non-discrimination.

To exercise any right, email privacy@swtlm.com from the email address you wish us to use to verify your identity. We will respond within 45 days. We may extend this period by an additional 45 days where reasonably necessary, and we will notify you of the extension.

We have not “sold” or “shared” personal information of any consumer under 16 years of age in the preceding 12 months and we do not intend to do so.

11.2 Other U.S. state laws

Residents of Colorado (CPA), Connecticut (CTDPA), Virginia (VCDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), and similar U.S. state privacy jurisdictions enjoy analogous rights to know, delete, correct, and opt out of targeted advertising or “sales” of personal information. TLM does not engage in targeted advertising or sales of personal information. To exercise any state-law right, email privacy@swtlm.com.

11.3 Appeals

If we deny a privacy request and you are a resident of a state whose privacy law provides an appeals mechanism, you may appeal the denial by replying to our denial email with the word “Appeal” in the subject line. We will respond to the appeal within 60 days.

If you are in the European Economic Area, the United Kingdom, or Switzerland, the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the UK GDPR, and the Swiss FADP provide the following rights:

Right of access (Article 15 GDPR).
Right of rectification (Article 16).
Right of erasure (“right to be forgotten”) (Article 17).
Right of restriction of processing (Article 18).
Right of data portability (Article 20).
Right to object to processing (Article 21).
Right not to be subject to automated decision-making, including profiling (Article 22). TLM does not perform automated decision-making with legal effect.
Right to lodge a complaint with a supervisory authority.

Our legal bases for processing are:

Performance of a contract (Article 6(1)(b)) — to deliver the Service.
Legitimate interests (Article 6(1)(f)) — to maintain, secure, and improve the Service, where these interests are not overridden by the interests, rights, and freedoms of the data subject. The child-safe defaults in Section 4.3 are part of our balancing test.
Compliance with a legal obligation (Article 6(1)(c)) — to respond to lawful requests and tax / accounting obligations.

For children in the EEA (under 16, or the lower age set by an EEA Member State down to 13), processing on the basis of consent is performed only with the consent of the holder of parental responsibility, in accordance with Article 8 GDPR. As described in Section 4, we do not rely on consent as a legal basis for processing children’s personal information, because we do not collect personal information from children as defined in this Policy.

To exercise any right, email privacy@swtlm.com. We will respond within one month and may extend by two additional months where necessary in light of the complexity of the request.

13. Third-party services

The following third-party services may process information in connection with the Service:

Firebase Analytics — Google LLC — Aggregate gameplay analytics — policies.google.com/privacy.
Firebase Crashlytics — Google LLC — Crash diagnostics — policies.google.com/privacy.
Firebase Storage — Google LLC — Paid-pack content CDN — policies.google.com/privacy.
Apple App Store + Apple IAP — Apple Inc. — App distribution + payment — apple.com/legal/privacy.
Google Play + Google Play Billing — Google LLC — App distribution
- payment — policies.google.com/privacy.
RevenueCat — RevenueCat, Inc. — IAP receipt validation (processor) — revenuecat.com/privacy.
Amazon Web Services — Amazon.com, Inc. — Website hosting (S3 + CloudFront) — aws.amazon.com/privacy.
Google Analytics (GA4) — Google LLC — Aggregate visitor analytics for the website (consent-gated; cookies set only after banner acceptance) — policies.google.com/privacy.

We may update this list when we add or remove a service provider. The current list is always published in this Policy.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes — for example, when we add a new processor, change a data category, or change a retention period — we will:

Update the “Last updated” date at the top of this Policy.
Increment the “Version” number.
Provide reasonable advance notice in the Parents Hub → Privacy → Privacy policy screen of the app and at the top of the website Privacy page.

Non-material changes (typographical corrections, formatting, clarifications that do not affect our practices) may be made without notice.

15. Contact

For any privacy question, request, or complaint:

TLM Software Design, Inc. Attn: Privacy 27280 Haggerty Road, Ste. C-6 Farmington Hills, MI 48331 United States

Email: privacy@swtlm.com General support: support@swtlm.com

If you contact us by email, we will not add your address to any marketing list and will retain it only as described in Section 5.2.