Under-18 age verification users have a Teen Privacy Policy
Users under 18 who verify their age through KWS are directed to an additional Teen Privacy Policy. Employees, contractors and authorised users of Partner companies are directed to a separate Partner Privacy Policy. Those linked documents are not supplied here.
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Supporting quotations
If you are under 18 and using KWS to verify your age, you can also view our
If you are an employee, contractor, or authorised user of one of our Partner companies
Use & Processing · Context
This policy covers KWS and information reasonably linked to you
The policy, last updated 10 September 2026, covers collection, use, sharing and storage through the KWS age verification and parent consent management platform, including its websites. Personal information includes identifying details and other information reasonably linkable to you. It also addresses information collected directly from children and rights to object to certain processing; the later sections set out those details.
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Supporting quotations
Last updated: 10 September 2026
This Privacy Policy explains how we collect, use, share, and store (process) your personal information when you interact with our age verification and parent consent management platform known as Kids Web Services (KWS), including our websites. When we say ‘personal information’, we not only mean information that can identify you, such as your name, email or address, but also any information that could reasonably be linked back to you.
This Privacy Policy also explains how we process and safeguard any personal information we collect directly from children in the COPPA Children’s Privacy Statement.
We also explain how you can exercise your rights relating to your personal information, including the right to object to certain types of processing we carry out.
Legal Rights & Agreement Rules · Context
Kids Web Services Ltd is responsible for information collected through KWS
Kids Web Services Ltd is the responsible legal entity and belongs to the Epic Games family of companies. The policy directs questions to its Contact Us section.
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Supporting quotations
The legal entity responsible for the information that we collect through KWS is Kids Web Services Ltd (we / us). Kids Web Services Ltd belongs to the
If you have any questions about this Privacy Policy, please see the Contact Us section at the bottom.
Linking & Identification · Company practice
Providing your email again reconnects an AgeGraph record to you
KWS says the information in AgeGraph cannot be attributed to you until you choose to provide your email again for age verification in a KWS-powered game or service. The new email input is hashed with the same algorithm and matched to the stored email hash.
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Supporting quotations
We can’t attribute the information in AgeGraph to you until you choose to provide your email address to verify your age again for a game or service powered by KWS’ technology, which is then hashed using the same algorithm and matched against the hashed email address we have stored.
Parent Consent Management provides app-specific permissions through a Parent Portal
Partners use Parent Consent Management to obtain permission to process a child’s information in their Apps. Parents can manage what the child can share for each Partner App through their designated Parent Portal. KWS is responsible for personal information used for this consent-management service.
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Supporting quotations
service enables our Partners to obtain your permission for the Partner’s processing of your child’s personal information in their Apps. It also enables you to manage the personal information your child can share online for each Partner App via your designated Parent Portal.
We are responsible for how your personal information is used for Parent Consent Management services.
Use & Processing · Company practice
Age Gate identifies device country and whether an age threshold is met
Age Gate lets Partners identify a device’s country and whether the user is above or below that country’s age of digital consent or another age specified by the Partner. Where GDPR applies, the Partner is the controller for this service. KWS directs users to the Partner’s privacy policy and disclaims responsibility for the Partner’s privacy practices.
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Supporting quotations
The Age Gate service enables our Partners to identify the country in which an end-user’s device is located and whether they are over/under the applicable age of digital consent in their country (i.e. the age below which permission from a child user’s parent/guardian is required for certain processing of the child user's personal information) or other age specified by the Partner.
Where the GDPR applies, our Partners act as a controller for personal information processed as part of the Age Gate services.
you should read the Partner’s privacy policy to understand how the Partner uses your personal information for these services. We are not responsible for the privacy practices of the Partner.
Qualifications & exceptions
The threshold may be the country's digital-consent age or another age chosen by the Partner.
The controller statement applies where GDPR applies.
Legal Rights & Agreement Rules · Company practice
Partners are controllers for Kid Account Management where GDPR applies
KWS sometimes provides account management for Partners’ child users. Where GDPR applies, Partners control personal information processed in Kid Account Management; their privacy policies explain their use. KWS disclaims responsibility for Partners’ privacy practices.
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Supporting quotations
On occasion, we also provide account management services for our Partner’s end-users who are children, which we call Kid Account Management services. Where the GDPR applies, our Partners act as a controller for personal information processed as part of the Kid Account Management services.
you should read the Partner’s privacy policy to understand how the Partner uses your personal information for these services. We are not responsible for the privacy practices of the Partner.
Data Access & Collection · Company practice
KWS receives information from you, your interactions and Partners
KWS collects information directly and through interactions with its services, and receives information from Partners when you or your child use their Apps. Account information includes an email supplied directly or through a Partner by you or your child. For Parent Consent Management, KWS also assigns an ID to recognise you in communications with that Partner.
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Supporting quotations
We collect information from you directly and through your interactions with KWS. We also receive information about you from our Partners when you or your child interact with their Apps.
Account information. Your email address, which you give to us directly or which you or your child gives to a Partner who then shares it with us. When you interact with Parent Consent Management services, we also assign you a unique ID number that we use to recognise you when communicating with that Partner.
Data Access & Collection · Company practice
Verification data depends on your chosen method and country
When a Partner, or KWS for a Partner, requests an age check, KWS collects your email and asks you to choose an available verification method. Depending on that choice and your country, it asks for some, never all, of: name, birth date, mailing address, card details, personal identity numbers or specified digits, mobile number, face scan, government ID or face photo. Examples include CPF in Brazil, CURP in Mexico, RRN digits or i-PIN in Korea, and US Social Security number digits. ID Scan & Selfie uniquely compares your image against your selected ID and may involve biometric data.
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Verification information. Information you provide when you respond to a request from, or by us on behalf of, a Partner to verify your age, as well as your email address. You will be asked to select one verification method from the options available to you. The information you will be asked to provide depends on the verification method you choose and the country in which you are located, and will include some, but never all, of the following information: your name, date of birth, mailing address, credit or debit card information, a personal identity number (such as a CPF number in Brazil, a CURP number in Mexico, certain digits of a RRN number or i-PIN in the Republic of Korea, and certain digits of a US social security number in the US), a cell phone number, face scan, a government-issued identity document, or a photo of your face. Please note, if you select ID Scan & Selfie as the method to verify your age, we will uniquely identify your image against your selected ID, which may be considered biometric data.
Qualifications & exceptions
The method and country determine which data is requested; the listed types are not all collected together.
Data Access & Collection · Company practice
KWS automatically collects device and usage data with stated use limits
KWS uses logs, web beacons and similar technologies to collect device and interaction information, including to identify country and language. Device data includes operating systems, hardware/software versions, identifiers, IP address, login details, browser, time zone, country and language. Usage data includes navigation, features, actions, timing, frequency, duration, performance and errors, used to evaluate performance and detect errors. KWS says it does not use this data for online-activity tracking, browser fingerprinting or building profiles for advertising or any other purpose.
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Device and usage information. When you interact with KWS, we automatically collect information about your devices (computers, phones, tablets etc.) and your use of and interactions with KWS, including in order to identify your country and language. We do this using server logs, web beacons, or similar technologies. Device information includes data about the operating systems and hardware and software versions, device identifiers, internet protocol (IP) address, login data, browser type and version, time zone setting, country and language. Usage information includes site navigation, the KWS features you use, the actions you take, the time, frequency and duration of your activities, data about the performance of KWS and any problems you experience, including error reports, each of which are used for the purpose of evaluating the performance of KWS and detecting errors. We do not use device or usage information to track your online activity, for browser fingerprinting or to build a profile on you for advertising or any other purposes.
Cross-references
contrast (model-proposed): KWS says it does not track online activity regardless of Do Not Track settings — KWS collects operational device and usage data while promising not to use it to track online activity or build profiles. The two statements distinguish collection from prohibited uses, rather than establishing a contradiction.
Data Access & Collection · Company practice
Support information includes communications and potentially recorded chats
KWS collects information supplied for help, including names and chat or other communication content. It says support chats with its representatives may be monitored and recorded. This applies both when you contact support and when your child does.
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Customer support information. Information you give us when you contact us for help, such as your name, the content of your chats and other communications with us. When you contact us for customer support, chat sessions with our representatives may be monitored and recorded.
Customer support information. Information your child gives us when they contact us for help, such as their name, the content of their chats and other communications with us. When your child contacts us for customer support, chat sessions with our representatives may be monitored and recorded.
Qualifications & exceptions
Monitoring and recording are described as possible, not inevitable.
Data Access & Collection · Company practice
Child-related data includes age, linked IDs, permissions and preferences
KWS collects a child’s age or birth date, which a Partner may collect from the child or KWS may collect from the parent. It also collects a unique child ID linked to the parent, granted permissions, preferred App-feature access subject to those permissions, and country and language, sometimes region or US state. KWS says it does not collect directly from children except as described in its COPPA statement; child-related data is not necessarily collected directly from the child.
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The information we collect relating to your child includes the following:
Age information. The child’s age or date of birth. The Partner may collect this information directly from the child and/or we may collect it from you.
Unique ID. A unique user ID for the child, which we link to you.
Permissions. The permissions you granted for the child’s access to features of our Partners’ Apps.
Preferences. Your child’s preferred level of access to features of our Partners’ Apps, subject to your Permissions.
Country and Language. The child’s country (and in, in some cases, the child’s region or US state) and language.
We do not collect information directly from children except as described below in our COPPA Children’s Privacy Statement.
Qualifications & exceptions
Child preferences remain subject to parental permissions.
Direct collection from children is limited to the COPPA statement's described cases.
Legal Rights & Agreement Rules · Company practice
ESRB certification has method and implementation conditions
KWS says it participates in ESRB Privacy Certified, an FTC-approved COPPA Safe Harbor program with independent audits, enforcement and accountability mechanisms. Its consolidated Parent Consent Management and Parent Verification technology is reviewed and certified, including AgeGraph when a parent verifies adult status using a COPPA-compliant method. The policy says these technologies facilitate COPPA compliance when Partners implement them correctly; it does not promise every implementation is compliant.
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a Federal Trade Commission (FTC)-approved COPPA Safe Harbor Program.
As a licensee in this privacy certification program, we are subject to audits of our services and other enforcement and accountability mechanisms administered independently by
The technology behind our consolidated Parent Consent Management and Parent Verification solution has been reviewed and certified by ESRB Privacy Certified. This includes AgeGraph, when the parent has verified their adult status using a COPPA-compliant verification method.
When implemented correctly by our Partners, these technologies facilitate compliance with the US Children’s Online Privacy Protection Act (COPPA).
Qualifications & exceptions
AgeGraph inclusion requires a COPPA-compliant adult-verification method.
Facilitating COPPA compliance depends on correct Partner implementation.
Not stated here
The linked ESRB program and certification documents are not supplied; this card reports KWS’s statements, not independent certification terms or verification.
Legal Rights & Agreement Rules · Context
kidSAFE certification applies when KWS uses its default templates
KWS states it is certified by the kidSAFE Seal Program when implemented with KWS’s default templates.
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Supporting quotations
Kids Web Services (KWS) is certified by the kidSAFE Seal Program when implemented with KWS’ default templates.
Retention & Deletion · Company practice
Direct child collection includes support requests with limited retention
Although services are mostly intended for adults or teens and child-related information can come from parents, KWS sometimes collects directly from children. The stated example is support information such as a child’s name and communications; support chats may be monitored and recorded. KWS retains it for 10 days after ticket closure, unless needed for legal obligations, disputes, enforcing agreements or protecting rights.
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This statement explains how we process information collected directly from children. In most cases, our services are intended to be used either by adults or teens.
However, in certain circumstances we collect information directly from a child, including:
Customer support information: Information a child gives us when they contact us for help, such as their name, the content of their chats and other communications for us. When a child contacts us for customer support, chat sessions with our representatives may be monitored and recorded. This information is retained for 10 days after the customer support ticket has been closed, unless it needs to be retained to comply with legal obligations, resolve disputes, enforce our agreements or protect our rights.
Qualifications & exceptions
Ten days runs from closure of the support ticket.
Legal obligations, dispute resolution, agreement enforcement or rights protection may require longer retention.
Sharing & Disclosure · Company commitment
Direct-child data is shared for KWS operations or legal requirements, not sold
KWS shares this child data with service providers facilitating support. It says sharing is only to provide, maintain and secure KWS or when required by law, and that it sells neither this data nor any other data to anyone. The linked provider list is not supplied here, so this card does not identify its current recipients.
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Supporting quotations
This data is shared with our service providers who help us facilitate customer support. We share data only to provide, maintain and secure KWS, or if we’re required to do so by law, as further described here. We do not sell this data (or any other data) to anyone.
Not stated here
The linked service-provider list is not supplied; its current contents are unknown here.
Parents may have review, access, deletion and collection-refusal rights
For information KWS collects directly from a child, the parent’s rights may include reviewing, accessing or deleting it and refusing further collection from that child at any time. The statement frames these as rights that may apply, rather than an unconditional promise of every remedy in every situation.
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As a parent, you have certain rights over how we handle the personal information collected directly from your child. This may include a right for you to review, access, or delete the personal information that has been collected by us from that child, and to refuse at any time to permit the collection from that child of such personal information.
Qualifications & exceptions
Applies to information collected directly from the child; the policy says the listed rights may apply.
KWS maintains an information security program for directly collected child data
KWS says it maintains a comprehensive information security program designed to protect personal information collected directly from children. This states the program’s protective purpose; it is not a guarantee against every security incident.
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Supporting quotations
We maintain a comprehensive information security program designed to protect personal information collected directly from children.
Legal Rights & Agreement Rules · Company commitment
KWS ties processing to purpose-specific legal bases
KWS says it uses information only with a valid reason and legal basis determined by the purpose. Bases may include requested contractual services or pre-contract steps, legitimate interests not overridden by your interests or fundamental rights and freedoms, legal or regulatory duties, vital interests, and consent for specified purposes. Consent can be withdrawn at any time where relied on, without affecting prior processing’s lawfulness. For legitimate-interest processing you may object on rights grounds; KWS says it will stop unless it has compelling legitimate grounds or legal reasons.
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We use the information we collect only when we have a valid reason and legal basis to do so. We determine the legal bases based on the purposes for which we collect your information.
to provide a service you’ve asked for under a contract we have entered into, or which we are about to enter;
where it is necessary for our legitimate interests provided that your interests and fundamental rights and freedoms do not override those interests;
where we need to comply with a legal or regulatory obligation or to protect your vital interests;
where we ask for your consent to process your information for specific purposes and you have the right to withdraw your consent at any time.
Right to withdraw consent: Where you have previously provided your consent, you have the right to withdraw consent at any time where we are relying on consent as the legal basis upon which to process your personal information. However, this will not affect the lawfulness of the processing based on consent before its withdrawal.
Right to object (legitimate interest): Where we process your personal information based on legitimate interests, you can object to this processing where you feel it impacts on your fundamental rights and freedoms. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
Qualifications & exceptions
Legitimate interests are subject to your overriding interests and fundamental rights and freedoms.
Withdrawal applies where consent is the processing basis and does not retrospectively undo lawful processing.
Objection may be overridden by compelling legitimate grounds or legal reasons.
Service delivery uses specified adult and child information
For services to you and Partners, the table lists your account, verification, device/usage and support information, plus your child’s age, unique ID, permissions, preferences, country and language. The stated basis is contract performance or pre-contract steps for Partner-App access; below contractual capacity, it is KWS’s legitimate interest in operating and supplying requested or accessed services, subject to the policy’s overriding-rights limit. Method-specific consent and AgeGraph have additional bases described separately.
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Purpose: To provide our services to you
We use your information to provide our services to you and our Partners.
Account information
Verification information
Device and usage information
Customer support information
Age information
Unique ID
Permissions
Preferences
Country and Language
Performance of the contract you are party to which requires our services or for pre-contractual steps to enable you to access the relevant Partner Apps, or if you are under the age of contractual capacity, our legitimate interest to operate and provide you with services you access or request.
where it is necessary for our legitimate interests provided that your interests and fundamental rights and freedoms do not override those interests;
Qualifications & exceptions
The legitimate-interest alternative applies to users below contractual capacity and remains subject to overriding rights.
Verification methods and AgeGraph have further specified legal bases.
Age data supports access checks and tells Partners when consent is no longer needed
KWS uses verification information to let you consent to a child’s App features or access a Partner App or age-restricted feature yourself. It also uses verified status in AgeGraph. It stores a child’s age information to notify the Partner when the child reaches an age at which parental consent is no longer required for processing their information.
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We use your Verification information to verify your age so that you can: (i) consent to your child accessing features of our Partners' Apps, or (ii) access a Partner App or age-restricted feature of a Partner App. We also use your verified status for the purposes of AgeGraph .
We store your child's Age information to notify our Partner when they have reached an age where they no longer require your consent to the processing of their personal information.
Legal Rights & Agreement Rules · Company practice
Verification methods have different consent bases
For ID Scan & Selfie, KWS lists explicit consent for biometric processing and says this use also serves the substantial public interest in safeguarding children. Face scan relies on consent in certain jurisdictions; ConnectID relies on consent when selected. These statements concern the chosen method, not every age check.
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Supporting quotations
Explicit consent for biometric processing where you select ID Scan & Selfie as your verification method to verify your age. Use of your biometric data for these purposes is also in the substantial public interest to safeguard children.
Consent in certain jurisdictions if you select face scan as your verification method to verify your age.
Consent if you select ConnectID as your verification method to verify your age.
Qualifications & exceptions
The face-scan consent basis is stated only for certain jurisdictions.
Legal Rights & Agreement Rules · Company practice
AgeGraph relies on interests in reducing repeat collection and easing parental consent
KWS identifies legitimate interests for AgeGraph: avoiding repeated collection and processing of verification information, reducing collection and making verification safer, and making parental consent easier to obtain as part of its internet-safety mission. It says easier consent makes children more likely to be honest about age. The policy’s general condition still applies: legitimate interests must not be overridden by your interests and fundamental rights and freedoms.
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For AgeGraph our legitimate interest in: (i) eliminating the need to collect and process Verification information more than once, minimising personal information collection and providing a safer service to you and our Partners; and (ii) pursuing our mission to make the internet safer by making it easier for you to provide, and children and our Partners to obtain, verifiable parental/guardian consent. The easier it is for you to provide—and children and our Partners to obtain—verifiable parental consent, the more likely that children will be honest about their age.
where it is necessary for our legitimate interests provided that your interests and fundamental rights and freedoms do not override those interests;
Qualifications & exceptions
Subject to the general limit for overriding interests and fundamental rights and freedoms.
KWS uses listed data to maintain services, troubleshoot and provide support
The maintenance row lists your account, verification, device/usage and support data and your child’s age, unique ID, permissions, preferences, country and language. KWS uses these for proper operation, troubleshooting and support. Its basis is contract performance or pre-contract access steps, or, below contractual capacity, legitimate interests in operating, maintaining and providing requested or accessed services, subject to overriding rights.
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Purpose: To maintain our services
We use your information to ensure our services are operating properly, to troubleshoot and provide customer support.
Account information
Verification information
Device and usage information
Customer support information
Age information
Unique ID
Permissions
Preferences
Country and Language
Performance of the contract you are party to which requires our services or for pre-contractual steps to enable you to access the relevant Partner Apps, or if you are under the age of contractual capacity, our legitimate interest to operate, maintain and provide you with services you access or request.
where it is necessary for our legitimate interests provided that your interests and fundamental rights and freedoms do not override those interests;
Qualifications & exceptions
The legitimate-interest alternative applies below contractual capacity and remains subject to overriding interests and rights.
Device, usage and support data may help improve or develop services
KWS may sometimes use device/usage and customer-support information to improve or develop products, updates, functionality and features based on feedback and how people use them. It relies on legitimate interests in improvement and development while applying privacy safeguards, subject to the general overriding-rights limit.
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Purpose: To improve and develop new products and services
We may sometimes use your information to help us improve and develop products and services, including to develop updates and add new functionality, products and features based on your comments and feedback and an understanding of how you and others use them.
Device and usage information
Customer support information
Our legitimate interest in improving and developing new products and services, while applying appropriate safeguards that protect your privacy.
where it is necessary for our legitimate interests provided that your interests and fundamental rights and freedoms do not override those interests;
Qualifications & exceptions
The row specifies device/usage and support data, rather than every collected category.
Privacy safeguards and the overriding-rights limit apply.
Safety processing uses specified data to protect services and people
To protect KWS, users, Partners and their users, KWS uses your account, verification, device/usage and support data plus a child’s unique ID, country and language. Examples include detecting errors, fraud, policy breaches and criminal or malicious activity. Depending on circumstances, it relies on legal duties, vital interests or legitimate interests in security, preventing misuse and protecting rights, property and interests, with privacy safeguards and the general overriding-rights limit.
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Purpose: To promote safety and security
We use your information to help protect and improve the safety and security of our services, our end-users, our Partners and their end-users.
For example, we use information to detect and protect against error, fraud, breach of our terms or policies, or criminal or malicious activity.
Account information
Verification information
Device and usage information
Customer support information
Unique ID
Country and Language
Depending on the circumstances, we rely on the following legal bases: (i) to comply with legal obligations; (ii) to protect vital interests; or (iii) our legitimate interest in providing a secure and safe service and preventing fraud and unauthorised use of our products and services, violations of our terms and policies or other harmful or illegal activity, and in protecting our and others' rights, property and interests, while applying appropriate safeguards that protect your privacy.
where it is necessary for our legitimate interests provided that your interests and fundamental rights and freedoms do not override those interests;
Qualifications & exceptions
The child-data categories listed for this purpose are unique ID, country and language.
The legal basis depends on circumstances; legitimate interests remain subject to safeguards and overriding rights.
Safety processing may rest on legal duties, vital interests or legitimate interests
The safety row’s legal-basis cell lists alternatives depending on circumstances: compliance with legal obligations, protection of vital interests, or legitimate interests in safe services, preventing fraud, unauthorised use, breaches and harmful or illegal activity, and protecting rights, property and interests. It also specifies privacy safeguards. This is the safety row’s basis, not the communications row’s basis that follows.
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Depending on the circumstances, we rely on the following legal bases: (i) to comply with legal obligations; (ii) to protect vital interests; or (iii) our legitimate interest in providing a secure and safe service and preventing fraud and unauthorised use of our products and services, violations of our terms and policies or other harmful or illegal activity, and in protecting our and others' rights, property and interests, while applying appropriate safeguards that protect your privacy.
Qualifications & exceptions
The applicable basis depends on circumstances and the legitimate-interest basis includes privacy safeguards.
KWS uses account, device and support information for direct communications
For direct communication, the table lists your account, device/usage and support data, plus your child’s support information. KWS may confirm verification or email ownership, notify you of a child’s permission request or use of your email for Partner-App access, respond to you or your child, or announce changes to terms, policies, products or services. The basis is contract performance; if there is no contract or you lack contractual capacity, it cites legitimate interests in providing services and/or fulfilling and answering requests. The general legitimate-interest limits elsewhere in the policy still apply.
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Supporting quotations
Purpose: To communicate with you
We use information we collect, like your email address, to interact with you directly.
We may email you to let you know that you have been successfully verified.
We may notify you of a new permission request from your child. We may email you to confirm that the email address belongs to you.
We may email you to let you know that your email address has been submitted to access a Partner App or age-restricted feature of a Partner App.
We may also respond to inquiries or other communications from you or your child, or inform you of changes to our terms, policies, or products or services.
Account information
Device and usage information
Customer support information
Customer support information
When using, processing or sharing information for this purpose, we do so on the legal basis of performance of a contract or, if we have not entered into a contract with you or you are under the age of contractual capacity, our legitimate interest to operate and provide you with services and/or our legitimate interest in fulfilling and responding to your requests.
Qualifications & exceptions
The legitimate-interest alternatives apply when there is no contract or the user is below contractual capacity.
Use & Processing · Company commitment
KWS says it does not send marketing communications to you or child App users
The communications section expressly excludes marketing communications to you and to children using Partners’ Apps, while separately allowing the described service and support messages.
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Supporting quotations
We do not send marketing communications to you or children using our Partners' Apps.
Sharing & Disclosure · Company commitment
KWS limits sharing to the policy and says it does not sell information
KWS says it shares personal information only as described in this policy, for example to provide, maintain or secure the service or meet legal requirements, and does not sell any information to anyone. For data collected directly from children, its COPPA statement uses the narrower wording that sharing is only to provide, maintain and secure KWS or when legally required; this is not an unrestricted sharing permission.
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Supporting quotations
We do not share your personal information with others except as described in this Privacy Policy (like to provide, maintain and secure KWS, or if we’re required to do so by law). We do not sell any of your information to anyone.
We share data only to provide, maintain and secure KWS, or if we’re required to do so by law, as further described here. We do not sell this data (or any other data) to anyone.
Qualifications & exceptions
The COPPA statement specifically limits direct-child data sharing to KWS operations or legal requirements.
Not stated here
The linked service-provider list in the COPPA statement is not supplied here; no current provider list is inferred.
Providers and professional advisers may receive information
KWS shares information with service providers such as IT/hosting firms and card processors, including verification information for age checks. Providers processing on KWS’s behalf serve the policy’s purposes and have contractual privacy, security and confidentiality duties. KWS also sometimes shares with advisers such as lawyers, accountants and insurers who may be independent controllers, including for enforcement or claims. Some providers and servers are outside the UK, Switzerland and EEA. The linked current-provider list is not supplied.
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Service providers. As with most companies, we use third parties to help us provide KWS, such as IT and hosting providers or payment card processors. For example, we share Verification information with payment card processors we use to verify your age. Some of these providers may process your personal information on our behalf, for the purposes set out in this Privacy Policy. These providers are subject to contractual obligations governing privacy, data security and confidentiality.
We also share personal information in some cases with our professional advisers and other service providers who are sometimes independent ‘data controllers’, such as lawyers, accountants and insurers (e.g. when enforcing our contract with you or in the event of claims against us).
As we explain above, we use third-party service providers to help us provide KWS, such as hosting providers or payment card processors. Some of these providers, including their servers, are based outside the UK, Switzerland and EEA.
Qualifications & exceptions
On-behalf processing is for policy purposes and subject to contractual privacy, security and confidentiality duties.
Professional advisers may instead act as independent controllers.
Not stated here
The linked list of current service providers is not supplied; its identities and terms cannot be established here.
Partners receive verification status and child-permission updates
When you or your child uses a Partner App, KWS shares information to provide services requested from it or the Partner. It communicates verified status for parental permissions or App/feature access, may send child age information when parental consent is no longer needed, and sends updates to the child’s preferences and parental permissions given through the Parent Portal.
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Partners. If you or your child uses a Partner App, we share your personal information with our Partners to deliver the services which you have requested from either us or our Partners. For example, if you verify your age through KWS, we communicate your verified status to the Partner to enable the Partner to proceed with obtaining your permissions (whether using Parent Consent Management or otherwise) for their collection of your child’s personal information, or giving you access to their App or age-restricted features of their App. If your child is an end-user of a Partner, we may communicate their Age information to the Partner in order to notify the Partner that your child has reached an age where they no longer require your consent to the collection of their personal information. We also provide Partners with updates to your child’s Preferences and the Permissions you give your child through the Parent Portal.
Qualifications & exceptions
Applies when you or your child uses a Partner App, for requested services.
Epic group sharing is limited by policy purposes or your authorisation
KWS may share with Epic Games group companies, including future acquisitions, only as necessary for purposes in this policy or as you otherwise authorise. It gives group assistance with Partner customer support as an example.
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Supporting quotations
Other companies within our group. We may share your information with our Epic Games family of companies, including companies that we may acquire in the future, but only to the extent necessary to fulfil purposes set out in this Privacy Policy, or otherwise as authorised by you. For example, our group companies assist us in the provision of customer support to our Partners.
Qualifications & exceptions
Only as necessary for stated policy purposes or as otherwise authorised by you.
Not stated here
The linked Epic Games family page is not supplied; this card does not establish a current list of group companies.
Sharing & Disclosure · Permission or license
KWS may disclose information when it believes legal or protective needs justify it
KWS may share information if it believes disclosure is reasonably necessary for law or legal process, pursuing remedies or claims, enforcing terms, securing services, protecting rights, property, interests or safety, or risk management. The listed protected groups include KWS, employees, customers, its users and Partners’ users. Data categories and legal bases depend on circumstances; KWS generally cites legal duties, vital interests or legitimate interests in security, preventing misuse, protecting rights and responding to government or law-enforcement requests. The policy’s direct-child sharing limits still apply to child-collected data.
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Supporting quotations
Other legal or regulatory process.
We may share your personal information if we believe it is reasonably necessary:
where required by law;
to comply with legal processes;
to permit us to pursue available remedies, including commencing or responding to any claims;
to enforce or apply our terms;
to protect the security or integrity of our services;
to protect the rights, property, interests or safety of KWS, our employees, customers, our end-users or our Partners’ end-users; or
for risk management purposes.
The categories of information we disclose and our legal basis for doing so depends on the circumstances, but generally it is to comply with legal obligations, to protect vital interests or act in our legitimate interest to provide a secure and safe service and preventing fraud and unauthorised use of our products and services, violations of our terms and policies or other harmful or illegal activity, and in protecting our and others’ rights, property and interests, and responding to legal requests from governmental and law enforcement agencies.
We share data only to provide, maintain and secure KWS, or if we’re required to do so by law, as further described here.
Qualifications & exceptions
KWS must believe sharing is reasonably necessary for a listed purpose.
Data categories and legal bases depend on circumstances.
Direct-child information remains subject to the COPPA sharing limits.
Not stated here
The referenced terms are not supplied here; their obligations and enforcement provisions are not analyzed.
An acquiring entity may receive information but remains limited by this policy
In a merger, acquisition or asset sale, KWS may share personal information with the acquiring or receiving entity. Categories and bases depend on circumstances and include legitimate interests in operating, selling and expanding the business. If ownership changes, new owners may process information only in the same way this policy sets out.
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Supporting quotations
If we are acquired. If we are involved in a merger, acquisition, or sale of assets, we may share your personal information with the acquiring or receiving entity. The categories of information we disclose and our legal basis for doing so depends on the circumstances, but would include our legitimate interest in operating, selling and expanding our business, including through such transactions. If a change happens to our business, the new owners may only process your personal information in the same way as set out in this Privacy Policy.
Qualifications & exceptions
Applies to a merger, acquisition or asset sale.
New owners may only process information in the way this policy sets out.
Sharing & Disclosure · Company practice
KWS may share de-identified aggregate information with Partners
KWS may derive and share aggregate information as part of its services, such as the percentage of parents consenting to a game feature. It says the data is de-identified so that in a Partner’s hands it cannot be associated with a person or reveal your identity directly or indirectly.
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Supporting quotations
A note about aggregated data. We may derive aggregated data from your personal information and we may share this information in aggregated form with our Partners as part of our services. For example, we may aggregate Usage information to calculate the percentage of parents/guardians who provide verifiable parental consent to their child accessing a certain feature of one of our Partner’s games. However, because this data has been through a process to de-identify personal information so that it can no longer be associated in the Partner’s hands with a person, the aggregated data cannot directly or indirectly reveal your identity to the Partner.
Qualifications & exceptions
The stated de-identification limit concerns the data in the receiving Partner’s hands.
Security & Safeguards · Company commitment
Security safeguards do not guarantee against loss, misuse or alteration
KWS maintains administrative, physical and technical safeguards tailored to information sensitivity. Its security team regularly reviews practices and improves them as needed; KWS works to restrict access to a need-to-know basis, encrypts personal information using secure server software and partners only with security companies meeting and committing to its standards. It expressly does not guarantee that loss, misuse or alteration will never occur.
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Supporting quotations
We value your trust and maintain a comprehensive information security program designed to protect personal information using administrative, physical, and technical safeguards. The specific security measures used are based on the sensitivity of the personal information collected. While we cannot guarantee that loss, misuse or alteration of data will not occur, we have measures in place designed to protect against inappropriate access, loss, misuse, or alteration of personal information under our control.
Our security team regularly reviews our security and privacy practices and enhances them as necessary to help protect the integrity of our systems and your personal information.
We work to limit access to your personal information to those employees, agents, contractors and other third parties strictly on a “need to know” basis.
We use secure server software to encrypt personal information, and we only partner with security companies that meet and commit to our security standards.
Qualifications & exceptions
Specific safeguards depend on information sensitivity.
KWS does not guarantee prevention of all loss, misuse or alteration.
Legal Rights & Agreement Rules · Restriction or exception
KWS disclaims responsibility for linked third-party services
KWS correspondence may link to unaffiliated or independently operated websites, services or mobile apps, including Partners’ offerings. KWS accepts no responsibility or liability for those operators’ content, security or privacy practices.
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Supporting quotations
Some of the correspondence you receive from us may contain links to third-party websites, online services or mobile applications that are not affiliated to or operated by us, including those of our Partners. We are not responsible and accept no liability for the content, security or privacy practices of those other operators.
Account & Service Control · User right or choice
Access, deletion and correction rights have location and legal limits
Available rights vary with location and applicable law. KWS lists access to and a copy of personal information, including collected and disclosed categories; deletion in certain cases with valid grounds and subject to law; and correction of inaccurate information, potentially after verifying the new data’s accuracy.
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Supporting quotations
We provide you with rights and choices about the personal information we collect and hold about you. The specific choices available to you may vary depending on your location and applicable law.
Right of access: You have a right to request access to your personal information and to be provided with a copy of your personal information, including the categories of your personal information we collect and disclose.
Right of deletion: You have the right, in certain cases, to request that we delete your information, provided there are valid grounds for doing so and subject to applicable law.
Right of correction: You have the right to request that we correct inaccurate information about you, though we may need to verify the accuracy of the new data you provide to us.
Qualifications & exceptions
Specific choices vary by location and applicable law.
Deletion requires valid grounds and applies only in certain cases.
You can object to legitimate-interest processing, subject to exceptions
Where KWS relies on legitimate interests, you can object if you feel processing affects fundamental rights and freedoms. KWS says it will stop unless it has compelling legitimate grounds or the processing is needed for legal reasons. Under the separate marketing-objection entry, it says it sends no marketing to its or Partners’ end-users.
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Supporting quotations
Right to object (legitimate interest): Where we process your personal information based on legitimate interests, you can object to this processing where you feel it impacts on your fundamental rights and freedoms. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
Right to object (marketing): We do not send marketing communications from KWS to our end-users or end-users of our Partners.
Qualifications & exceptions
Compelling legitimate grounds or legal reasons may allow processing to continue.
Transfer and temporary restriction rights are conditional
Depending on applicable rights, you may receive certain information in a structured, commonly used, machine-readable format and transmit it to a third party. You may temporarily restrict processing in certain cases with valid grounds. The policy does not promise portability of every item or restriction in every situation.
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Supporting quotations
Right to transfer: You may have the right to receive certain of your information in a structured, commonly used and machine-readable format and to transmit such information to a third party.
Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your information by us, provided there are valid grounds for doing so.
The specific choices available to you may vary depending on your location and applicable law.
Qualifications & exceptions
Portability concerns certain information; temporary restriction requires valid grounds in qualifying cases.
Consent withdrawal does not undo prior processing’s lawfulness
If you previously consented and KWS relies on consent for processing, you can withdraw it at any time. That withdrawal does not affect the lawfulness of processing based on consent before withdrawal.
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Supporting quotations
Right to withdraw consent: Where you have previously provided your consent, you have the right to withdraw consent at any time where we are relying on consent as the legal basis upon which to process your personal information. However, this will not affect the lawfulness of the processing based on consent before its withdrawal.
Legal Rights & Agreement Rules · User right or choice
You may complain to KWS or a data-protection regulator
For concerns about data handling or legal rights, KWS directs complaints to privacy@kidswebservices.com. The policy also identifies rights to complain to the UK Information Commissioner or your local data-protection supervisory authority.
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Supporting quotations
If you have a complaint about the handling of your personal data, or feel that we have not complied with your legal rights, please contact us by emailing
You also have the right to lodge a complaint with our supervisory authority, the UK Information Commissioner
You can also lodge a complaint with your local supervisory authority for data protection.
Account & Service Control · User right or choice
Withdrawing a child’s consent may remove access to apps or services
Parents or guardians may have rights to review, access or delete information KWS collected from the child as controller and to refuse collection at any time. If consent is withdrawn, the child may lose access to certain apps, games or digital services. KWS says it will tell you at withdrawal if that is the case.
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Supporting quotations
Rights relating to your child’s personal information: As a parent/guardian, you have certain rights over how we handle the personal information of your child. This may include a right for you to review, access, or delete the personal information that has been collected by us (in our capacity as a controller) from that child, and to refuse at any time to permit the collection from that child of such personal information. If you withdraw your consent, your child may lose access to certain apps, games or other digital services. We will advise you if this is the case at the time you withdraw your consent.
Qualifications & exceptions
The rights concern information KWS collected from the child in its controller capacity and are described as rights that may apply.
Rights requests can be emailed and may require identity verification
If the Account Management FAQs do not let you exercise a right, you can email privacy@kidswebservices.com at any time. KWS may verify identity when warranted for a disclosure, such as by login or additional information, to avoid unauthorised disclosure. Requests are usually free, but KWS may charge where law allows, for example for manifestly unfounded or excessive requests. US and Australian residents are also directed to the location-specific rules.
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Supporting quotations
If you want to exercise any of your rights and are not able to do so by following the instructions in our Account Management FAQs, you can email us at privacy@kidswebservices.com at any time.
Before we process such requests, we may ask you to verify your identity (like by logging-in to your account or providing us with certain information) if warranted for a particular disclosure. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. No payment is usually required to exercise your rights. However, we may request payment where allowed by law (for example, if your request is manifestly unfounded or excessive).
If you are a United States or Australian resident, refer to the Location-specific rules section below for more information on your legal rights.
Qualifications & exceptions
Identity checks depend on what is warranted for the disclosure.
Fees may apply where legally allowed, including for manifestly unfounded or excessive requests.
Not stated here
The linked Account Management FAQs are not supplied; their additional instructions are not analyzed.
Account & Service Control · Procedure
Age-verification disputes go to the Partner
To contest an age-check result, including an estimated age from face scan, KWS directs you to the Partner. The Partner makes the final decisions about your app, game or service account.
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Supporting quotations
Please note that we provide age verification services for our Partners (i.e. operators of apps, games and other digital services). To dispute an age verification outcome (including an estimated age if you used face scan as your verification method), please contact the Partner directly. They make all final decisions relating to your app, game or service account.
Retention & Deletion · Company practice
Retention depends on purpose, data type and legal needs
You can request deletion of some information at any time by emailing privacy@kidswebservices.com. Otherwise KWS keeps information as long as necessary for collection purposes or other legitimate purposes, including legal obligations, disputes, agreement enforcement and rights protection. Periods vary by data and interaction context. KWS considers amount, nature and sensitivity, harm risk, purposes and alternative means, and legal, regulatory, tax or accounting requirements; this is not a fixed deadline for all information.
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Supporting quotations
You can delete some personal information whenever you like by contacting us at privacy@kidswebservices.com.
Otherwise, we retain personal information for as long as necessary to fulfil the purposes we collected it for, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements or protecting our rights.
Retention periods vary significantly depending on the different data types, the purposes for which they were collected and the context of our interactions with you.
the amount, nature and sensitivity of the data;
the potential risk of harm from unauthorised use or disclosure of the data;
the purposes for which we process the data and whether we can achieve those purposes through other means;
applicable legal, regulatory, tax or accounting requirements.
Qualifications & exceptions
The at-any-time deletion statement covers some information, not every record.
Legal and other legitimate needs can extend retention.
Support information is normally kept for ten days after ticket closure
KWS’s specific support example is ten days after the ticket is closed. It may retain that information longer when needed for legal obligations, resolving disputes, enforcing agreements or protecting rights.
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Supporting quotations
For example, customer support information is retained for 10 days after the customer support ticket has been closed, unless it needs to be retained to comply with legal obligations, resolve disputes, enforce our agreements or protect our rights.
Qualifications & exceptions
The clock starts at ticket closure.
Legal obligations, disputes, enforcement or rights protection can justify longer retention.
Cross-references
qualifies (model-proposed): Retention depends on purpose, data type and legal needs — Support information has a stated ten-day period after ticket closure, subject to the listed legal, dispute, enforcement and rights-protection extensions.
Retention & Deletion · Company commitment
Providers must delete unneeded data; Partner-controller retention is separate
KWS requires third-party providers to delete information once no longer necessary for their services or legal, regulatory, tax, accounting or reporting requirements. For Partner-controlled Age Gate and Kid Account Management processing, users must consult the Partner’s privacy policy or contact it to learn retention periods; KWS’s periods do not establish those Partners’ periods.
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Supporting quotations
We require any third-party service providers we use to delete personal information once it is no longer necessary for them to provide the services or to satisfy any legal, regulatory, tax, accounting or reporting requirements.
Where our Partners act as controllers when processing you or your child’s personal information (i.e. Age Gate services and Kid Account Management services), please refer to their privacy policies or contact the Partner directly for information on how long they retain your personal information.
Qualifications & exceptions
Provider legal, regulatory, tax, accounting and reporting needs are retained exceptions.
Partner-controller retention must be checked with the Partner.
Not stated here
Partners’ privacy policies are not supplied; their retention periods are unknown here.
Information may transfer outside the UK, Switzerland and EEA
Group companies are in the US and other countries outside the UK, Switzerland and EEA; some providers, servers and Partners are also outside those regions. Destination countries may offer different protection. KWS says it uses contracting frameworks approved by the UK and Swiss governments and European Commission, designed for essentially equivalent protection as applicable, and may need transfers to provide KWS under existing agreements such as its Terms of Use.
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Supporting quotations
We transfer your personal information in the following ways:
As we explain above, we share your personal information within our group of companies. Our group companies are located in the United States and other countries outside the UK, Switzerland and EEA.
As we explain above, we use third-party service providers to help us provide KWS, such as hosting providers or payment card processors. Some of these providers, including their servers, are based outside the UK, Switzerland and EEA.
As we explain above, we also provide your information to Partners. Some of these Partners are based outside the UK, Switzerland and EEA.
Countries where we and our service providers and Partners operate may not offer the same level of data protection as your home country. We use specific contracting frameworks approved by the UK Government, Swiss Government and European Commission that are designed to give personal information protection essentially equivalent to that in the UK, Switzerland and EEA (as applicable).
We may also need to transfer your information to provide KWS to you in accordance with our existing agreements with you, such as the
Qualifications & exceptions
Equivalent protection is the stated design of contracting frameworks; destination-country law may differ.
Not stated here
The linked KWS Terms of Use and the contracting instruments are not supplied; their detailed transfer terms are not established here.
Necessary and analytics cookies can be blocked, with possible service effects
KWS and other organisations use necessary cookies to make the service work. KWS may also set analytics cookies to measure use and improve the service. You can block or request alerts through browser settings, but some parts may stop working. The linked cookie table is not supplied, so particular cookies and their durations are not inferred.
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Supporting quotations
A cookie is a small piece of text sent to your browser by a website you visit. We and other organisations use necessary cookies to make KWS work. We may also set analytics cookies that help us make improvements by measuring how you use KWS. You can set your browser to block or alert you about these cookies, but some parts of KWS may not then work.
Qualifications & exceptions
Analytics cookies may be set; blocking cookies may impair parts of KWS.
Not stated here
The linked cookie table is not supplied; specific cookies, purposes beyond this summary and durations are unknown here.
Data Access & Collection · Company commitment
KWS says it does not track online activity regardless of Do Not Track settings
KWS says it does not track end-users’ online activities whether or not Do Not Track is enabled. It also says it is unaware of third parties collecting users’ online activities over time and across other websites while users use KWS. This does not mean KWS collects no device or usage data: it separately describes automatic operational and performance collection, while excluding tracking, fingerprinting and profile-building uses.
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Supporting quotations
KWS does not track our end-users’ online activities, regardless of whether or not they have “Do-Not-Track” enabled in their browser.
We are not aware of any third party that may collect personal information about our end-users’ online activities over time and across third party websites when our end-users use our website or services.
Device and usage information. When you interact with KWS, we automatically collect information about your devices (computers, phones, tablets etc.) and your use of and interactions with KWS, including in order to identify your country and language.
We do not use device or usage information to track your online activity, for browser fingerprinting or to build a profile on you for advertising or any other purposes.
Qualifications & exceptions
The statement about third-party tracking is limited to KWS’s awareness.
Operational device and usage collection still occurs.
Cross-references
contrast (model-proposed): KWS automatically collects device and usage data with stated use limits — KWS collects operational device and usage data while promising not to use it to track online activity or build profiles. The two statements distinguish collection from prohibited uses, rather than establishing a contradiction.
Sharing & Disclosure · Company practice
KWS does not respond to GPC because it says it does not sell or target ads
KWS does not respond to Global Privacy Control signals. Its stated reason is that it neither sells personal information nor uses or shares it for targeted advertising, the activities those opt-outs address. Other disclosures described in the policy still occur; this is not a promise never to share information.
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Supporting quotations
For the same reasons, we do not respond to Global Privacy Control (GPC) signals, which are designed to allow users to opt out of the sale of their personal information or use of their personal information for targeted advertising purposes. We do not sell your personal information, or use or share it for targeted advertising purposes. See Reasons we share your personal information for more information on when we share your personal information.
Legal Rights & Agreement Rules · Procedure
Australian residents can escalate unresolved inquiries to the OAIC
Location-specific rules depend on residence. An Australian resident dissatisfied with KWS’s response or resolution may complain to the Office of the Australian Information Commissioner at enquiries@oaic.gov.au or +61 1300 363 992.
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Supporting quotations
Depending on where you are resident, specific rules apply.
If you are a resident of Australia and you are not happy with how we responded to your inquiry or it has not been satisfactorily addressed, you may lodge a complaint with the Office of the Australian Information Commissioner at enquiries@oaic.gov.au or +61 1300 363 992.
Qualifications & exceptions
For Australian residents dissatisfied with the response or handling of their inquiry.
Legal Rights & Agreement Rules · Procedure
US residents can contact ESRB Privacy Certified about unresolved inquiries
A US resident who believes KWS has not answered or satisfactorily handled an inquiry is directed to ESRB Privacy Certified at privacy@esrb.org or its linked online contact form.
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Supporting quotations
If you are a resident of the United States and believe that we have not responded to your inquiry or it has not been satisfactorily addressed, please contact ESRB Privacy Certified at privacy@esrb.org or by using their online contact form
Qualifications & exceptions
Applies to US residents with an unanswered or unsatisfactorily handled inquiry.
Not stated here
The linked ESRB contact form is not supplied; its fields and handling process are not analyzed.
Legal Rights & Agreement Rules · Context
The California supplement uses CCPA definitions and covers KWS as a Business
For California residents, the supplement describes additional rights and details under the amended CCPA and regulations. Its capitalised terms, including Personal Information, Sensitive Personal Information, Sell, Share and Business, take their CCPA meanings. KWS says it acts as a Business in direct interactions, including age verification and AgeGraph. This is a California-specific role and does not substitute GDPR terminology.
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This additional section applies to California residents because of the specific privacy laws in that state. It explains the additional rights and details required by the California Consumer Privacy Act of 2018, as amended, and its implementing regulations (CCPA). For the purposes of this section, Personal Information, Sensitive Personal Information, Third Parties, Business Purposes, Commercial Purposes, Sell, Share and Business have the meanings given to them under the CCPA.
We act as a Business when we interact with you directly, including when you verify your age and participate in AgeGraph.
Qualifications & exceptions
Applies to California residents and uses CCPA-defined terms.
California’s twelve-month collection list varies with your KWS interactions
When acting as a Business, KWS says its past-12-month collection included identifiers; the information category described in California Civil Code Section 1798.80(e), including verification data; commercial and internet-activity information, including usage; geolocation limited to country and US state; protected-classification characteristics including age 40 or older; and sensitive information such as government ID. These are all collected categories across KWS, not a claim that every category applies to every person.
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When acting as a Business, we have collected the following categories of Personal Information in the past 12 months (using the categories described in the CCPA). This list includes all categories that we collect, but the categories that apply to you will vary depending on how you interact with KWS:
Identifiers – including Account information and Device and usage information.
Personal information described in Section 1798.80(e) of the California Civil Code – including Verification information you provide.
Commercial information – including Usage information.
Internet activity – including Usage information.
Geolocation – we only collect the country, and if in the US, the state in which you are located.
Characteristics of protected classifications under California or federal law - including age (40 or older).
Sensitive Personal Information - including Verification information you provide like your government ID.
Qualifications & exceptions
California supplement; the list concerns the past 12 months when KWS acts as a Business.
Categories applicable to a person depend on their interactions.
Geolocation is limited here to country and, in the US, state.
Not stated here
The cited California Civil Code text is not supplied; no additional statutory-category contents are inferred.
Sharing & Disclosure · Company commitment
California sensitive-information use is limited; KWS says it does not Sell or Share
Using the CCPA meanings, KWS says it uses or discloses Sensitive Personal Information only as necessary to perform KWS or as the CCPA permits. It says it does not Sell or Share Personal Information, including for end-users it knows are under 16. This CCPA-specific statement coexists with the ordinary service disclosures described elsewhere.
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Supporting quotations
We do not use or disclose Sensitive Personal Information for purposes other than those that are necessary to perform KWS or permissible under the CCPA.
We do not Sell or Share Personal Information, including for our end-users that we know are under the age of 16.
For the purposes of this section, Personal Information, Sensitive Personal Information, Third Parties, Business Purposes, Commercial Purposes, Sell, Share and Business have the meanings given to them under the CCPA.
Qualifications & exceptions
Sell, Share and Sensitive Personal Information use CCPA meanings.
Sensitive-information purposes may include those otherwise permissible under the CCPA.
Cross-references
contrast (model-proposed): Partners receive verification status and child-permission updates — KWS's California promise not to Sell or Share uses CCPA-defined terms; it coexists with service-related Partner disclosures described in the policy and does not mean that no information is disclosed.
California source, purpose and recipient disclosures refer to the main policy
The California supplement directs readers to the main collection section for source categories, the purposes-and-bases section for business or commercial collection purposes including sensitive information, and the sharing section for third-party recipient categories. It does not replace those sections with a different recipient or purpose list.
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Supporting quotations
the categories of sources from which your Personal Information is collected, see Personal information we collect;
the Business Purposes or Commercial Purposes for collecting your Personal Information, including Sensitive Personal Information, see Why we collect your personal information and our legal basis for processing; and
the categories of Third Parties to whom we disclose your Personal Information, see Reasons we share your personal information.
Qualifications & exceptions
These cross-references are part of the California supplement.
Account & Service Control · User right or choice
California residents have access and correction rights, with response limits
California residents may know and access collected information, including categories, sources, collection purposes, disclosed-to third-party categories and specific pieces, and correct it. KWS may limit responses where necessary for legal claims, compliance with laws or obligations, or law-enforcement cooperation.
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If you are a California resident, you have the right to:
know and access what personal information we collect about you, including the categories of personal information collected and sources, the business or commercial purposes for collection, the categories of third parties with whom we disclose personal information, and the specific pieces of personal information collected;
correct your personal information; and
We may also limit how we respond to your requests, including when necessary to handle legal claims, comply with applicable laws or legal obligations, or cooperate with law enforcement.
Qualifications & exceptions
California residents only.
Legal claims, compliance needs or law-enforcement cooperation can limit responses.
California deletion has operational and legal retention exceptions
California residents have a deletion right, but KWS may retain information when needed for operational or legal reasons. Examples include providing KWS, transactions or contract performance; security, integrity or debugging; exercising legal rights for itself or others; internal uses aligned with user expectations; and legal obligations. Responses may also be limited for legal claims, compliance or law-enforcement cooperation.
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Supporting quotations
deletion of your personal information.
We will delete your personal information, unless retention is necessary for operational or legal reasons, including to:
provide KWS, complete transactions, or perform our contract with you;
ensure the security or integrity of KWS, or debug KWS;
exercise legal rights on behalf of ourselves or others;
enable internal uses aligned with user expectations; or
comply with a legal obligation.
We may also limit how we respond to your requests, including when necessary to handle legal claims, comply with applicable laws or legal obligations, or cooperate with law enforcement.
Qualifications & exceptions
California residents only; deletion does not require removing records needed for the listed operational or legal reasons.
Other state-law rights apply according to the law in force where you live
The policy identifies Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia as having comprehensive laws in effect at the policy date, and notes other states may enact laws later. Terms take the meanings of the applicable state law. For residents of states with a comprehensive law in effect, it lists knowing whether personal data is processed and accessing a copy, with further rights and limits in the following text. This reports the dated policy, not an independent check of current legislation.
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Other US state residents
Certain US states, including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia have each enacted a comprehensive privacy law, which are in effect as of the date of this Privacy Policy. Other states may enact comprehensive privacy laws in the future. These laws provide residents of those states with certain rights to their personal data. Terms used in this subsection are defined by the applicable privacy law in force in your state of residence. Generally, however, they provide residents with the rights set forth below.
If you are a resident of a state with a comprehensive privacy law in effect, you have the right to:
know whether we are processing your personal data;
access and obtain a copy of your personal data;
Qualifications & exceptions
Depends on a comprehensive privacy law being in effect in the resident's state; terms follow that state law.
Other state-law correction and deletion rights have exceptions
In the other-US-state subsection, residents of states with a comprehensive privacy law in effect can request deletion and correction, except that the correction right excludes Utah and Iowa. Legal obligations and operational needs can limit responses to rights requests, including access: providing services or contracts, development research, technical fixes, expected internal operations, preventing or responding to security incidents and fraud, legal claims, compliance and law-enforcement cooperation.
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Supporting quotations
correct your personal data (except for residents of Utah and Iowa); and
deletion of your personal data.
Certain legal obligations and operational needs may limit how we respond to your requests. These exceptions may include:
providing KWS or performing our contracts;
conducting research to develop or improve KWS;
identifying and fixing technical issues;
performing other internal operations consistent with user expectations;
preventing or responding to security incidents, fraud, identity theft, or other illegal or harmful activities;
handling legal claims;
complying with applicable laws or legal obligations; or
cooperating with law enforcement.
access and obtain a copy of your personal data;
Qualifications & exceptions
Correction excludes Utah and Iowa under this policy's other-state list.
Listed legal and operational needs may limit responses.
KWS says it does not sell, target ads or use significant-effect automated profiling
The other-US-state subsection says KWS does not sell collected personal data, process it for targeted advertising, or automatically profile users to make decisions with legal or similarly significant effects. This expressly includes users it knows are under 18. The profiling statement is about that specified form of decision-making, not a claim that every automated verification operation is absent.
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Supporting quotations
We do not sell personal data that we collect, process personal data for targeted advertising or profile our end-users through automated means to make decisions that have legal or similarly significant effects, including for our end-users that we know are under the age of 18.
Qualifications & exceptions
The automated-profiling restriction concerns decisions with legal or similarly significant effects.
Legal Rights & Agreement Rules · Context
Other-state disclosures refer to the main collection, purpose and sharing sections
The other-state subsection refers readers to the main policy for processed data categories, purposes, recipients and shared-data categories. For sensitive data from a known child under 13, it points to the child-information discussion. These references do not supply a new or unlimited processing permission.
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the categories of personal data processed by us, see Personal information we collect;
our purposes for processing personal data, see Why we collect your personal information and our legal basis for processing;
the categories of third parties with whom we share personal data and the categories of personal data we shared, see Reasons we share your personal information; and
our processing of sensitive data from a known child under 13, see information relating to your child as set out here.
Account & Service Control · Procedure
Verifiable rights requests and appeals use the Contact Us channels
The US rights procedure requires a request from you, or an authorised representative for a California resident, with enough information to verify identity and understand it. A California agent must provide the resident’s signed written permission, and the resident may need direct identity verification. KWS may deny requests if identity or authority cannot be verified. Appeals use the same Contact Us methods. KWS says it will not discriminate for exercising privacy rights under applicable law.
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To exercise your privacy rights, use one of the methods listed in the Contact us section below. Only you (or an authorized representative on behalf of a California resident) may submit a verifiable request, which must include enough information for us to confirm your identity and understand the request. Authorized agents of California residents must include written permission signed by the resident, who may also need to verify their identity directly. Requests may be denied if we cannot verify your identity or authority. Appeals can be submitted using the same contact methods listed in the Contact us section below.
We will not discriminate against you for exercising any of your privacy rights under applicable law.
Qualifications & exceptions
The stated representative route is for California residents.
Unverified identity or authority can lead to denial.
The policy says Nevada residents may direct businesses not to sell certain collected information, while KWS itself says it does not sell personal information. Nevada residents wishing to exercise the stated right can email privacy@kidswebservices.com.
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Nevada residents have the right to direct a business not to sell certain kinds of personal information that the business has collected about them. We do not sell personal information. If you are a Nevada resident and wish to submit a request relating to this right, please email us at privacy@kidswebservices.com.
Qualifications & exceptions
This procedure is for Nevada residents and concerns certain kinds of collected personal information.
Account & Service Control · Procedure
KWS’s Data Protection Officer accepts privacy questions and assistance requests
For questions about privacy practices, information or assistance, the policy gives privacy@kidswebservices.com and the postal address: Attn: Data Protection Officer, Kids Web Services Ltd, C/O Shepherd And Wedderburn LLP, 1-6 Lombard Street, London, England, EC3V 9AA, United Kingdom. US users can also call (919) 447-4560.
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If you have any questions regarding our privacy practices, need information or require assistance, please contact us at:
Attn: Data Protection Officer
Kids Web Services Ltd, C/O Shepherd And Wedderburn LLP, 1-6 Lombard Street, London, England, EC3V 9AA, United Kingdom
privacy@kidswebservices.com
If you are located in the US, you can also call us on: (919) 447-4560.
Account & Service Control · Procedure
EEA and Brazil users have named regional privacy contacts
Users inside the EEA can alternatively contact Attn: KWS GDPR Representative, Mishcon de Reya Representative Services (Europe) Limited, 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, Ireland, at representative@mishcon.com. For users in Brazil, the policy names Data Protection Officer Henrique Fabretti of Opice Blum, Bruno Advogados Associados and gives privacy@kidswebservices.com.
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If you are located inside the European Economic Area (EEA), you can alternatively contact our representative in the EEA at:
Attn: KWS GDPR Representative
Mishcon de Reya Representative Services (Europe) Limited, 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, Ireland
representative@mishcon.com
If you are located in Brazil, you can contact our Data Protection Officer in Brazil: Henrique Fabretti of Opice Blum, Bruno Advogados Associados
privacy@kidswebservices.com
Qualifications & exceptions
The alternative EEA contact applies to users located inside the EEA; the Brazilian contact applies to users located in Brazil.
Legal Rights & Agreement Rules · Company practice
KWS may change the policy and gives additional notice in some cases
KWS may modify the policy at any time and will update its Last updated date. In some cases, such as material or substantive changes to policies and practices, it will also notify users by email or within KWS as appropriate. Users who object may seek deletion through the stated rights procedures; this reference does not remove the policy’s deletion conditions and retention exceptions.
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We may modify this Privacy Policy at any time. When we do, we will update the ‘Last updated’ date on this Privacy Policy. In some cases, such as when we make material or substantive changes to our policies and practices, we will also notify you of the relevant changes by email or within KWS as appropriate.
If you object to any changes, you may delete your personal information as described in How to exercise your rights.
Qualifications & exceptions
Additional email or in-service notice applies in some cases, such as material or substantive changes.
Deletion follows the existing rights procedures and their limits.
KWS supports age checks and parents’ control over children’s data sharing
KWS is an age verification and parent consent management platform. Individuals use it to verify age or manage their child’s online information sharing. App, game and digital-service operators are its Partners: they use it to check users’ ages or verify an adult parent or guardian and obtain consent before processing certain child information where countries’ privacy laws require it.
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KWS is an age verification and parent consent management platform.
It’s used by:
You, to verify your age and/or manage what personal information your child can share online.
Operators of apps, games and other digital services (Apps), whom we call our Partners as follows: (i) if you are an end-user of their Apps, to verify your age; or (ii) if you are a parent or guardian of a child end-user of their Apps, to verify that you are an adult and to obtain your consent before they process certain personal information of your child (required by privacy laws in certain countries).
Legal Rights & Agreement Rules · Company practice
KWS controls direct Parent Verification and Age Verification interactions under GDPR
Parent Verification checks that a child user’s parent or guardian is an adult; Age Verification checks an end-user’s age. Where GDPR applies, KWS is the controller responsible for personal information processed in direct interactions during those services, including verifying age or participating in AgeGraph.
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service enables our Partners to verify that the parents or guardians of their child end-users are adults (Parent Verification).
Where the General Data Protection Regulation (GDPR) applies, we act as a controller of any personal information processed when you interact with us directly.
service enables our Partners to verify the age of their end-users (Age Verification).
Where the GDPR applies, we act as a controller of any personal information processed when you interact with us directly. For example, when you use our services to verify your age or participate in our AgeGraph.
Partners control information handled before referral and in their own interactions
For both Parent Verification and Age Verification, the Partner is the controller for processing before you reach KWS and when you deal with the Partner directly. KWS tells you to read that Partner’s privacy policy and disclaims responsibility for its privacy practices. This separates the Partner’s handling from KWS’s direct verification interactions.
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The Partner is the controller of any personal information processed before you are directed to the KWS website and when you interact with the Partner directly.
We are not responsible for the privacy practices of the Partner.
The Partner is the controller of any personal information processed before you are directed to the KWS website and when you interact with the Partner directly.
you should read the Partner’s privacy policy to understand how the Partner uses your personal information.
AgeGraph reuses a successful verification across participating Partner Apps
After successful Parent Verification or Age Verification, KWS stores verified status against a hashed email address so you can use your email to manage a child’s permissions or access other participating Partner Apps without supplying verification information again. Adult verification can carry between the two verification services. KWS calls this network AgeGraph and is solely responsible for how its personal information is used.
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Once you have successfully verified your age through our Parent Verification or Age Verification service, we will store your verified status alongside your hashed email address.
Then, you can use your email address to: (i) manage your child's permissions for the same and other Partner Apps that use our Parent Verification service, or (ii) access other Partner Apps that use our Age Verification service. This is so that you won’t need to provide your Verification information again.
If you have successfully verified that you are an adult through our Parent Verification service, you won’t need to provide your Verification information again when accessing Partner Apps using our Age Verification service, and vice versa.
We call this network of verified individuals AgeGraph. We are solely responsible for how personal information is used for AgeGraph.
AgeGraph eliminates the need to collect Verification information more than once, minimising personal information collection and providing a safer service to you and our Partners.
Qualifications & exceptions
Requires successful verification and Partner Apps using the relevant KWS services.
Cross-references
has exception (model-proposed): You can opt out of AgeGraph — The ability to remove yourself from AgeGraph limits continued reuse of the stored verification across Partner Apps.
Account & Service Control · User right or choice
You can opt out of AgeGraph
You can always choose removal from AgeGraph by emailing privacy@kidswebservices.com or using the opt-out link in the successful-verification confirmation email.
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You can, however, always choose to be removed from AgeGraph by emailing privacy@kidswebservices.com or using the opt-out link in the email we send you confirming that you have successfully verified.
AgeGraph keeps verification metadata, but not the verification details themselves
After successful verification, verified status includes your age threshold, verification method, first and subsequent verification dates and times, associated Partner and App, initial device country, and KWS and verification-provider transaction IDs. KWS says it never stores the underlying verification details, such as card details, in this description of AgeGraph. The status is stored against your hashed email address, scrambled so it is no longer directly identifiable as an email address.
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Once you have been successfully verified, we remember this by storing:
your verified age threshold (e.g. 16+ , 18+);
the method of verification used, e.g. ‘individual verified by payment card using Stripe’, but we never store the verification details (e.g. your card details) themselves;
the date and time you verified your age for the first time and subsequent times using AgeGraph, as well as the Partner and Partner App for which those verifications were made;
the country in which your device is located at the time of initially interacting with us; and
a KWS generated transaction ID for each verification and any transaction IDs provided to us by our verification partners such as Stripe.
We call this the verified status.
We then store this verified status against your hashed email address in AgeGraph. In non-technical terms, this means we scramble your email address using an algorithm so that it’s no longer directly identifiable as an email address.
Qualifications & exceptions
The described record is created after successful verification.