Otters Camp

Privacy Policy

Last updated: October 26, 2025

This Privacy Policy applies to all mobile applications published by Otters Camp (legal entity: Anton Porozhniak), including Elara Learn and any other current or future apps (“we”, “our”, or “us”). This policy explains how we collect, use, and protect your information when you use our apps.

1. Definitions

For the purposes of this Policy:

“Personal Data” means any information that can identify you or your device directly or indirectly. “Anonymous Data” refers to data that cannot identify you and is used for analytics, statistics, or improvement of our services.

2. Information We Collect

We may collect certain information automatically when you use our apps, including:

Progress and activity data related to app usage (such as learning progress, achievements, interaction history, or other in-app activity metrics) Device information (device ID, model, screen size, operating system version) Approximate location or country (based on IP address) IP address and technical performance data Crash reports and error logs

We do not currently collect personally identifying details such as your name, email address, or contact information, since users cannot create accounts at this time. If account features are added in the future, this policy will be updated accordingly.

3. SDKs, Identifiers, and Local Storage

Our apps may use software development kits (SDKs) and device identifiers for analytics, performance tracking, and error detection. These include Firebase Analytics, Unity Analytics, and GameAnalytics. We may also store small amounts of information locally on your device (“local storage”) to remember progress, preferences, or settings.

We do not use cookies or identifiers for advertising or cross-app tracking.

4. Analytics and Crash Reporting

We use third-party services to understand how our apps are used and to improve their performance and stability:

Firebase (Analytics and Crashlytics) by Google LLC Unity Analytics by Unity Technologies GameAnalytics by GameAnalytics Ltd.

These services automatically collect non-personal and aggregated data related to app usage and technical performance. You can learn more about how these providers process data by reviewing their respective privacy policies:

Google Firebase Privacy Policy Unity Privacy Policy GameAnalytics Privacy Policy

5. Payments and Subscriptions

Some of our apps offer in-app purchases or auto-renewing subscriptions. All payments are processed securely by the Apple App Store or Google Play. We do not have access to or store payment card details, billing information, or any financial credentials. Refunds or cancellations must be managed directly through your platform account.

6. How We Use Information

We use the data we collect to:

Operate, maintain, and improve our apps Analyze usage and user engagement Identify and fix technical problems Develop new features and functionality Ensure proper operation across devices and OS versions

We do not use collected data for marketing or advertising purposes, nor do we track users across different applications or websites.

7. Data Sharing

We do not sell or rent user data. We may share limited technical information with third-party service providers such as Firebase, Unity, or GameAnalytics strictly for analytics and operational purposes as described in this Policy.

We may also disclose information if required by law, court order, or government authority.

8. International Data Transfers

Our analytics and hosting providers (such as Google Firebase) may process and store your data on servers located outside of Georgia, including in the European Union and the United States. By using our apps, you consent to the transfer of such data as necessary for providing the service. We take reasonable steps to ensure that these providers protect your data according to applicable standards.

9. Data Retention

We retain analytics and crash data as long as necessary for operational, analytical, and security purposes. We do not automatically delete this data after a fixed time period unless required by applicable law or the service provider’s retention policies.

10. Data Access and Deletion

At this time, users cannot view or request deletion of data collected by our apps. If you believe that we have collected information in error or wish to make an inquiry regarding your data, you can contact us at [email protected].

11. Children’s Privacy

Our apps are not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If you believe that a child under 13 has provided us with personal data, please contact us, and we will take appropriate steps.

12. Security

We take reasonable and appropriate measures to protect information against unauthorized access, alteration, disclosure, or destruction. However, please note that no system or network is completely secure.

13. Third-Party Links

Our apps may contain links to external websites or services. We are not responsible for the content or privacy practices of these third-party services. We encourage you to review their privacy policies before interacting with them.

14. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our apps, data practices, or legal requirements. The updated version will be posted within our apps and on our website, with the “Last updated” date adjusted accordingly.

15. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

Email: [email protected]

16. Governing Law

This Privacy Policy is governed by the laws of Georgia, except where otherwise required by applicable data protection laws (like GDPR).