RUTHWEST LIMITED

Including Children’s Data Protection & Reporting

Google Play Store Compliance

Applicable to All Applications Published by Ruthwest Limited

Effective Date: March 11, 2026 | Last Updated: March 11, 2026

1. Introduction

Welcome to the applications and services provided by Ruthwest Limited (“Ruthwest,” “we,” “our,” or “us”). Ruthwest Limited develops and publishes a portfolio of mobile applications (collectively, “our Apps” or “the Apps”) available on the Google Play Store and other platforms. We are committed to protecting the privacy of all users, including children under the age of 13 (or the applicable age in your jurisdiction).

This Privacy Policy applies to all applications developed, published, owned, or operated by Ruthwest Limited. It describes how we collect, use, disclose, and safeguard your information when you download, install, access, or use any of our Apps.

This policy has been drafted to comply with the Google Play Families Policy, the Children’s Online Privacy Protection Act (COPPA), the General Data Protection Regulation (GDPR) as it pertains to children, the California Consumer Privacy Act (CCPA), the Kids Online Safety Act (KOSA), and other applicable data protection laws worldwide.

By downloading, installing, or using any of our Apps, you agree to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our Apps.

2. Definitions

Personal Information: Any information that identifies, relates to, or could reasonably be linked to a natural person or household.
Child / Children: Any user under the age of 13 (or the minimum age as defined by local laws, such as 16 under GDPR in some EU member states).
Parent / Guardian: A parent or legal guardian of a child user.
Apps / Applications: All mobile applications developed, published, owned, or operated by Ruthwest Limited, whether currently available or released in the future.
Processing: Any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, or deletion.
Consent: Freely given, specific, informed, and unambiguous indication of agreement to the processing of personal data.
Verifiable Parental Consent (VPC): Consent obtained from a parent or guardian through a method that is reasonably calculated to ensure that the person providing consent is indeed the child’s parent or guardian.

3. Scope of This Policy

This Privacy Policy applies universally to:

All mobile applications currently published by Ruthwest Limited on the Google Play Store and any other distribution platform.
All future applications developed and published by Ruthwest Limited.
Any websites, web apps, or online services operated by Ruthwest Limited in connection with the Apps.
Any services, features, content, or functionality offered through the Apps.

Where a specific App has unique data practices that differ from or supplement this general policy, those practices will be described in a supplementary privacy notice provided within that App. In the event of a conflict between this policy and a supplementary notice, the supplementary notice shall prevail for that specific App.

4. Information We Collect

4.1 Information Collected from All Users

Across our Apps, we may collect the following categories of information:

Device Information: Device type, model, operating system and version, unique device identifiers (e.g., Android Advertising ID), mobile network information, and IP address.
Usage Data: Information about how you interact with our Apps, including screens visited, features used, actions taken, session duration, crash reports, and performance data.
Account Information: If you create an account in any of our Apps, we may collect your name, email address, username, password (stored in encrypted form), and profile information.
Location Data: Approximate location based on IP address. We do not collect precise GPS location unless an App explicitly requires it and you grant permission.
Communications: Information you provide when contacting our support team, submitting feedback, or participating in surveys.
In-App Purchase Data: Transaction records related to in-app purchases, processed through Apple, Google Play’s billing system. Ruthwest Limited does not directly access or store your payment card details.

4.2 Information Collected from Children

For any App that is directed at or may be used by children, we strictly limit data collection to the minimum necessary. Specifically:

We do NOT collect personal information from children without verifiable parental consent.
We do NOT collect precise geolocation data from children.
We do NOT collect contact information from children for marketing purposes.
We do NOT enable children to make personal information publicly available.
We collect only a persistent identifier (e.g., an anonymous device ID) for internal operations such as maintaining the App’s functionality, analytics, and personalization, all as permitted under COPPA.
We do NOT use children’s data for behavioral advertising, profiling, or any purpose beyond the App’s core functionality.

4.3 Information We Do NOT Collect from Children

Under no circumstances do we collect the following from child users:

Full name, home address, or phone number (unless verifiable parental consent is obtained)
Photos, videos, or audio recordings of children
Precise geolocation data
Contact lists or address books
Biometric data (fingerprints, facial recognition, voiceprints)
Financial or payment information
Social media account information

5. How We Use Information

5.1 General Purposes

We use collected information for the following purposes across all our Apps:

To provide, operate, and maintain our Apps and their features
To improve, personalize, and expand our Apps
To understand and analyze how users interact with our Apps
To develop new products, services, features, and applications
To communicate with users, including for customer service, support, and updates
To send push notifications related to updates or informational purposes (with opt-out options)
To detect, prevent, and address technical issues, fraud, or security concerns
To comply with legal obligations and enforce our terms of service

5.2 Use of Children’s Information

Information collected from children is used solely for the following limited purposes:

To enable the child to use the App’s core features and functionality
To maintain and improve the internal operations of the App
To ensure compliance with legal and regulatory requirements
To protect the safety and security of children using the App

We do NOT use children’s data for behavioral advertising, interest-based advertising, profiling, user tracking across apps, or any purpose not directly related to the App’s core functionality.

6. Children’s Data Protection Policy

Ruthwest Limited is deeply committed to protecting the privacy and safety of children. This section sets forth our comprehensive policies and practices for safeguarding children’s data in compliance with COPPA, GDPR (Article 8), Google Play Families Policy, and other applicable regulations. These protections apply to all Apps published by Ruthwest Limited that are directed at or accessible by children.

6.1 Age Verification and Age Gating

We implement appropriate age verification mechanisms across our Apps:

A neutral age gate is presented at first launch or registration that does not encourage users to falsify their age.
The age gate uses a date-of-birth entry method rather than a simple confirmation checkbox.
If a user indicates they are under the applicable age threshold, the App restricts functionality and triggers the parental consent workflow.
Age verification data is stored locally and not transmitted to our servers unless parental consent is obtained.
We periodically re-verify age where applicable and technically feasible.

6.2 Verifiable Parental Consent (VPC)

Before collecting any personal information from a child, Ruthwest Limited obtains verifiable parental consent through one or more of the following methods:

Signed parental consent form submitted via email or electronic signature
Credit card transaction verification (a nominal charge that is refunded)
Government-issued identification verification
Video call verification with a trained representative
Knowledge-based authentication questions
Email-based consent with follow-up confirmation (for limited internal use exceptions permitted under COPPA)

Parents may revoke consent at any time by contacting us at privacy@ruthwestlimited.com. Upon revocation, we will cease collecting information from the child and delete previously collected data within 30 days.

6.3 Parental Rights

Parents and guardians have the following rights regarding their child’s information across all Ruthwest Limited Apps:

Right to Review: Request a review of all personal information collected from their child across any or all of our Apps.
Right to Deletion: Request the deletion of their child’s personal information from our systems.
Right to Refuse Further Collection: Opt out of any further collection or use of the child’s personal information.
Right to Data Portability: Request a copy of the child’s data in a portable, machine-readable format.
Right to Restrict Processing: Limit how the child’s information is used across our Apps.
Right to be Informed: Receive clear and complete information about what data is collected and how it is used.

To exercise these rights, parents or guardians may contact us at privacy@ruthwestlimited.com. We will verify the identity of the requesting party before fulfilling any request. Requests will be processed within 30 days.

6.4 Data Minimization for Children

Ruthwest Limited adheres to the principle of data minimization for all child users across all our Apps:

We collect only the minimum amount of data necessary for the child to use the App’s core features.
We do not condition a child’s participation in activities, games, or features on disclosing more information than is reasonably necessary.
We regularly audit the data collected across all our Apps to ensure ongoing compliance with data minimization principles.
Anonymous or pseudonymous identifiers are used wherever possible in place of personally identifying information.
Default privacy settings for child accounts are set to the most restrictive level.

6.5 Data Retention for Children’s Data

Children’s personal information is retained only for as long as necessary to fulfill the purpose for which it was collected:

Account data is retained for the duration of the account’s active use plus 30 days after a deletion request is received.
Usage analytics for children are aggregated and anonymized within 90 days of collection.
All personally identifiable data for inactive child accounts is automatically deleted after 12 months of inactivity.
Upon receipt of a parental deletion request, all data is purged within 30 days.
Backup copies of deleted children’s data are removed within 60 days.

6.6 Children’s Data Security

We implement enhanced security measures for children’s data across all our Apps:

Encryption of all children’s personal data at rest (AES-256) and in transit (TLS 1.2+).
Access controls restricting employee access to children’s data on a strict need-to-know basis.
Regular security audits and penetration testing of systems that store children’s data.
Separate, segregated storage for children’s data with additional monitoring and logging.
Mandatory privacy and data protection training for all Ruthwest Limited personnel who may access children’s data.
Incident response procedures specifically tailored for breaches involving children’s data.

6.7 Third-Party Services and Children

Ruthwest Limited carefully evaluates all third-party services used in our Apps for compliance with children’s data protection requirements:

No third-party service is permitted to collect personal information from children for advertising or profiling purposes.
All third-party SDKs, APIs, and libraries used in children-directed portions of our Apps are reviewed for COPPA and Google Play Families Policy compliance.
We maintain a documented list of all third-party services with access to children’s data, reviewed quarterly.
Contractual agreements (Data Processing Agreements) with all third parties include specific clauses regarding children’s data protection, breach notification, and audit rights.
Third-party services that fail compliance reviews are removed from our Apps.

6.8 Advertising and Children

Advertising practices across all Ruthwest Limited Apps comply with Google Play’s Families Ads requirements:

No behaviorally targeted or interest-based advertising is shown to children.
All ads displayed to children are age-appropriate and reviewed for content suitability.
Only Google Play-certified ad networks are used for serving ads to child users.
Ad content does not include deceptive or manipulative elements such as fake close buttons, misleading interactive areas, or auto-redirect functionality.
Ads are clearly distinguishable from App content and labeled as advertisements.
No ads for age-restricted products or services (alcohol, tobacco, gambling, etc.) are shown to children.

7. Reporting and Safety for Children

Ruthwest Limited is deeply committed to ensuring the safety of child users across all our Apps. This section outlines our reporting mechanisms and safety protocols.

7.1 In-App Reporting Mechanism

We provide accessible reporting tools within each of our Apps:

A clearly visible “Report” button is available on all user-generated content and user profiles where applicable.
Children can report inappropriate content, bullying, harassment, or any safety concern through a simple, child-friendly interface.
Reports can be submitted anonymously to encourage children to report without fear of retaliation.
All reports are timestamped, assigned a unique tracking identifier, and logged in our centralized Trust and Safety system.
Reporting tools are available without requiring login or account creation where technically feasible.

7.2 Categories of Reportable Content

Users, including children and their parents or guardians, may report the following across any Ruthwest Limited App:

Inappropriate, explicit, or age-inappropriate content
Bullying, harassment, intimidation, or cyberbullying
Hate speech, discriminatory, or abusive content
Predatory behavior, grooming attempts, or suspicious contact from adults
Requests for personal information from children
Spam, phishing, scams, or fraudulent activity
Privacy violations or unauthorized data collection
Impersonation of minors or adults
Self-harm or suicide-related content
Any other content or behavior that makes a child feel unsafe

7.3 Report Review and Response

Ruthwest Limited has established the following procedures for handling reports involving children:

All reports involving children are prioritized and reviewed within 24 hours of submission.
A dedicated Trust and Safety team at Ruthwest Limited handles all reports related to child safety.
Reports indicating imminent danger or exploitation of a child are escalated immediately to senior management and, where required by law, to law enforcement authorities.
Content found to violate our policies is removed promptly, and offending accounts are suspended or permanently banned across all Ruthwest Limited Apps.
The reporting user receives an acknowledgment of their report and, where appropriate, a summary of actions taken (without disclosing details that could compromise an investigation).
Recurring offenders are tracked across all Ruthwest Limited Apps and subject to escalating enforcement actions.

7.4 Mandatory Reporting Obligations

Ruthwest Limited complies with all applicable mandatory reporting laws across all jurisdictions in which our Apps operate:

Any content depicting or suggesting child sexual abuse material (CSAM) is immediately reported to the National Center for Missing & Exploited Children (NCMEC) via the CyberTipline and to relevant law enforcement authorities.
For users outside the United States, we report to the applicable national authority (e.g., IWF in the UK, INHOPE member hotlines internationally).
We cooperate fully with law enforcement investigations related to child safety.
We retain relevant evidence as required by law to support ongoing investigations.
All Ruthwest Limited staff involved in content moderation and Trust and Safety operations are trained to identify and report suspected child exploitation.
We conduct periodic audits of our reporting processes to ensure compliance with evolving legal requirements.

7.5 Parental Reporting and Controls

Parents and guardians have additional reporting capabilities and controls across all Ruthwest Limited Apps:

Parents can report concerns about their child’s experience directly through a dedicated parent support channel or by contacting privacy@ruthwestlimited.com.
Parents can request a review of all content their child has been exposed to within any of our Apps.
Parents can set content filters and communication restrictions for their child’s account.
Parents receive notifications about safety-related incidents involving their child’s account.
Parents can disable or limit social features, messaging, in-app purchases, and public interactions for their child.
Parental control settings are accessible through a parent-authenticated dashboard within each App.

7.6 Proactive Safety Measures

Beyond reactive reporting, Ruthwest Limited implements proactive safety measures across all our Apps:

Automated content moderation using AI and machine learning to detect and remove harmful content before it reaches children.
Image and video scanning technology (PhotoDNA or equivalent) to detect known CSAM.
Keyword and behavioral pattern detection to identify potential grooming or predatory behavior.
Regular safety audits and reviews of each App’s features from a child safety perspective.
Collaboration with child safety organizations and participation in industry safety initiatives.
Age-appropriate design assessments for new features before launch.
Regular updates to our safety tools and processes based on emerging threats and best practices.

8. Data Sharing and Disclosure

Ruthwest Limited does not sell personal information of any user, including children. We may share information only in the following limited circumstances:

Service Providers: We share data with trusted third-party service providers who assist us in operating our Apps, subject to strict confidentiality and data protection agreements. These providers are contractually prohibited from using your data for any purpose other than providing their services to us.
Legal Requirements: We may disclose information when required by law, regulation, legal process, or governmental request.
Safety: We may disclose information to protect the safety of any person, including children, or to prevent illegal activity.
Business Transfers: In the event of a merger, acquisition, or asset sale involving Ruthwest Limited, user data may be transferred. Children’s data will continue to be subject to the protections outlined in this policy, and affected users will be notified.
With Parental Consent: We may share a child’s information with third parties only with verifiable parental consent.
Aggregated or De-Identified Data: We may share aggregated or de-identified data that cannot reasonably be used to identify any individual.

9. Data Security

Ruthwest Limited implements industry-standard security measures to protect personal information across all our Apps and systems:

Encryption of data in transit (TLS 1.2 or higher) and at rest (AES-256)
Regular vulnerability assessments and penetration testing
Access controls and multi-factor authentication for all internal systems
Security incident response plan with defined escalation procedures
Regular employee security awareness and privacy training
Data loss prevention (DLP) tools and monitoring
Secure coding practices, code review processes, and security testing for all App releases
Physical security measures for servers and data centers

While we take reasonable measures to protect your information, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security but are committed to promptly addressing any breaches.

10. Data Breach Notification

In the event of a data breach involving personal information processed by Ruthwest Limited:

We will notify affected users and, for children, their parents or guardians within 72 hours of becoming aware of the breach.
We will notify the relevant supervisory authority (e.g., FTC, ICO, DPA) as required by applicable law.
We will provide a description of the nature of the breach, the categories and approximate number of individuals affected, the likely consequences, and the measures taken to address the breach.
For breaches involving children’s data, we will provide additional notifications to NCMEC if child exploitation material is involved.
We will provide clear guidance to affected users on steps they can take to protect themselves.
A post-breach review will be conducted to identify root causes and prevent future incidents.

11. International Data Transfers

Ruthwest Limited operates globally and may transfer personal data, including children’s data, to countries outside your jurisdiction. When we do:

We ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission.
We comply with the EU-U.S. Data Privacy Framework and UK-U.S. Data Bridge where applicable.
Data is only transferred to jurisdictions that provide adequate levels of data protection or where supplementary measures have been implemented.
Users can contact us to learn about the specific safeguards applied to their data transfers.

12. Your Rights (All Users)

Depending on your jurisdiction, you may have the following rights regarding the data processed by Ruthwest Limited:

Right of Access: Request a copy of the personal information we hold about you.
Right to Rectification: Request correction of inaccurate or incomplete personal information.
Right to Erasure: Request deletion of your personal information.
Right to Restrict Processing: Request that we limit how we use your data.
Right to Data Portability: Receive your data in a structured, machine-readable format.
Right to Object: Object to processing of your data for certain purposes, including direct marketing.
Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.
Right Not to Be Subject to Automated Decision-Making: Object to decisions made solely by automated processing that significantly affect you.
Right to Lodge a Complaint: File a complaint with your local data protection authority.

To exercise these rights, contact us at privacy@ruthwestlimited.com. We will respond within 30 days (or sooner as required by applicable law). These rights apply to data collected across all Ruthwest Limited Apps.

13. Google Play Store Specific Compliance

All applications published by Ruthwest Limited on the Google Play Store comply with Google’s policies and requirements.

13.1 Families Policy Compliance

All Ruthwest Limited Apps directed at or accessible by children comply with Google Play Families Policy requirements.
All APIs, SDKs, and third-party libraries used in our Apps are approved for use in child-directed services.
Our Apps do not contain content inappropriate for their declared target audience.
Target audience and content ratings are accurately declared in the Google Play Console for each App.
We review and update our compliance with Families Policy requirements with each App update.

13.2 Data Safety Section

The Google Play Data Safety section for each Ruthwest Limited App accurately reflects its data collection and sharing practices.
All data types collected are disclosed, including data collected by third-party libraries and SDKs.
Data handling practices are reviewed and updated with each App release.
We maintain consistency between this Privacy Policy and the Data Safety disclosures for each App.

13.3 Designed for Families Program

Where applicable, our Apps enrolled in the Designed for Families program meet all additional requirements for child-directed content.
Advertising in family-directed Apps conforms to Google’s Families Ad requirements and policies.
All interactive elements comply with Google’s family-friendly content standards.
We promptly address any policy violation notices received from Google Play.

14. Cookies and Tracking Technologies

Our Apps may use the following technologies:

Analytics Tools: We use analytics tools (e.g., Firebase Analytics, Google Analytics for Mobile) to understand usage patterns. For child users, analytics are limited to aggregated, non-personal data.
Crash Reporting: We collect crash logs and error reports (e.g., Firebase Crashlytics) to improve App stability. These do not contain personally identifiable information of children.
Local Storage: Our Apps may store preferences, settings, and game progress locally on your device. This data is not transmitted to our servers unless necessary for account synchronization.
Push Notifications: We use push notification tokens to deliver important updates. Users can opt out through their device settings at any time.

We do NOT use tracking cookies, web beacons, pixel tags, or cross-app tracking technologies in the child-directed portions of our Apps.

15. Changes to This Privacy Policy

Ruthwest Limited may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we do:

We will update the “Last Updated” date at the top of this policy.
For material changes, we will provide prominent notice within our Apps, on our website, or via email.
For changes affecting children’s data practices, we will obtain renewed parental consent where required by law.
Continued use of any Ruthwest Limited App after changes constitutes acceptance of the revised policy.
Previous versions of this policy will be archived and available upon request.

We encourage you to review this Privacy Policy periodically to stay informed about how Ruthwest Limited protects your information.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices across any Ruthwest Limited App, including any concerns about children’s data, please contact us:

Company Name: Ruthwest Limited

Email (General): info@ruthwestlimited.com

Email (Privacy): privacy@ruthwestlimited.com

Email (Children’s Privacy): childprivacy@ruthwestlimited.com

Phone: +254716813714

Data Protection Officer: [DPO Name and Contact, if applicable]

For concerns specifically related to children’s privacy and safety, parents and guardians are encouraged to contact our dedicated children’s privacy team at childprivacy@ruthwestlimited.com. We aim to respond to all inquiries within 48 hours.

If you believe Ruthwest Limited has not adequately addressed your concerns, you have the right to file a complaint with your local data protection authority.

17. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of [Your Jurisdiction], without regard to its conflict of law provisions. For users in the European Economic Area (EEA), the provisions of the GDPR shall apply. For users in the United Kingdom, the UK GDPR and Data Protection Act 2018 shall apply. For users in California, the provisions of the CCPA/CPRA shall apply. For users in other jurisdictions, applicable local data protection laws shall apply to the extent they provide additional protections.

End of Privacy Policy