Effective Date: March 12, 2026 Last Updated: April 22, 2026
TERRITORIAL NOTICE: The Kiddleton App is intended solely for residents of the United States. This App is not available to, or intended for, residents of Canada (including the Province of Quebec). If you are not a US resident, you are prohibited from downloading or using this Kiddleton App.
Thank you for using the Kiddleton App (the "App"). The App is owned and operated by GENDA Americas Inc. ("Kiddleton," "we," "our" or "us"). "Kiddleton" is a brand name of GENDA Americas Inc. This Kiddleton App Privacy Policy ("Privacy Policy") explains how we collect, use, store, and share your information when you use our services. For details regarding international data transfers, please see the "Transfer of Personal Information Internationally" section below.
BY ACCESSING OR USING THE APP OR KIDDLETON OFFERINGS (DEFINED BELOW IN THE "BACKGROUND" SECTION), YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT USE THE APP OR UTILIZE KIDDLETON OFFERINGS.
This Privacy Policy covers our treatment of personal information, as defined herein, and other information that we collect when you, the end-user ("User," "you" or "your"): (a) download, install, access or use the App; (b) view and/or downloads any of the text, audio, video, photographs, graphics, artwork, and/or other featured content (collectively, "Content"); (c) register via Apple, Google, mobile phone number (SMS), or any other supported verification or authentication methods to receive free plays ("Free Plays") to be used on one (1) or more physical "claw" type amusement games ("Claw Games") operated by third-party game providers; and/or (d) use features such as store search, prize browsing, and digital wallet integration. The App, Content, and Free Plays, and all related features are referred to collectively as the "Kiddleton Offerings".
Capitalized terms not defined herein shall have the meanings set forth in the Kiddleton App Terms and Conditions ("Terms and Conditions").
This section applies to residents of the State of California and supplements the information contained elsewhere in this Privacy Policy, pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA").
The following table describes the categories of personal information we have collected from consumers in the preceding twelve (12) months:
| Category | Examples | Source | Purpose | Third Parties Shared With | Sold/Shared for Cross-Context Behavioral Advertising | Retention Period |
|---|---|---|---|---|---|---|
| Identifiers | Name, e-mail address, phone number, unique device identifiers | Directly from you; authentication providers | Account creation, authentication, customer support | Service providers (hosting, marketing platforms) | No | For the duration of your active account plus 2 years for legal and tax record-keeping. |
| Authentication Data | Apple ID subject, Google account ID, SMS verification codes | Directly from you; Apple, Google | Account sign-in and security | Service providers (hosting) | No | For the duration of your active account. |
| Geolocation Data (Sensitive PI) | Precise location (when permitted) | Your device (with your permission) | Nearby store search, distance calculations, location-based notifications (with opt-in consent) | Service providers (mapping) | No | Precise coordinates are typically deleted or de-identified within 30 days of use unless pinned to a specific transaction. |
| Internet/Electronic Activity | App usage data, screens viewed, session duration, IP address | Collected automatically from your device | App improvement, analytics, troubleshooting | Service providers (analytics) | No | Analytics data is typically retained for 14 to 26 months before being aggregated or deleted. |
| Device Information | Device model, operating system version | Collected automatically from your device | App compatibility, troubleshooting | Service providers (analytics, crash reporting) | No | For the duration of your active account plus 1 year for troubleshooting and security auditing. |
| Commercial Information | Free Play balance, coupon redemption history | Generated through your use of the App | Service delivery, fraud prevention | Service providers (hosting) | No | For 7 years to comply with financial auditing and tax reporting requirements (as coupons represent a financial value). |
We determine the retention period for each category of personal information based on: (1) the duration of our relationship with you; (2) any legal or regulatory obligations to which we are subject; (3) whether retention is advisable in light of our legal position (such as statutes of limitations, litigation, or regulatory investigations); and (4) technical necessity.
Under the CCPA, precise geolocation data is classified as "sensitive personal information." We collect precise geolocation data only with your affirmative opt-in consent (by granting location permission on your device). We use this data solely for the purposes described in the "Location Data" section of this Privacy Policy. We do not use or disclose your sensitive personal information for purposes other than those permitted under the CCPA.
You have the right to limit our use and disclosure of your sensitive personal information. You may exercise this right at any time by revoking location permission through your device's settings, or by contacting us using the methods described in the "How to Exercise Your Rights" section below.
As a California resident, you have the following rights:
To exercise any of the rights described above, please submit a verifiable consumer request by:
E-mailing us at: get-answers@genda-americas.com
Sending U.S. Mail to: GENDA Americas Inc., 246 S. Taylor Ave., Suite 200, Louisville, CO 80027
Verification process: To protect your privacy and security, we will verify your identity before processing your request. The level of verification is proportionate to the sensitivity of the data involved and depends on the type of request:
For requests to know categories of personal information: We will verify your identity to a reasonable degree of certainty by matching at least one (1) data point you provide (such as your e-mail address or phone number) against information we maintain.
For requests to know specific pieces of personal information: We will verify your identity to a reasonably high degree of certainty by matching at least two (2) data points you provide against information we maintain.
For requests to delete: We will verify your identity to a reasonable degree of certainty by matching at least one (1) data point and may separately confirm the deletion request via the e-mail address or phone number associated with your account.
We will confirm receipt of your request within ten (10) business days and provide information about how we will process your request, including our verification process. We will respond to your verifiable consumer request within forty-five (45) days of receipt. If we require additional time (up to an additional forty-five (45) days), we will inform you of the reason and the extension period in writing.
You may designate an authorized agent to make a request on your behalf. To do so, you must provide the authorized agent with written permission to submit the request, and we may require you to verify your identity directly with us.
We may offer Free Plays to Users who register for an account through the App. This program constitutes a "financial incentive" under the CCPA because it involves the collection of personal information in exchange for a benefit. You may opt into this program by creating an account. You may opt out at any time by deleting your account as described in the "Deleting, Modifying and Updating Your Information" section. The value of the Free Plays is reasonably related to the value of the personal information we collect, based on our reasonable assessment of the expenses related to collecting, storing, and managing the personal information and the revenue generated by offering the Kiddleton Offerings. Our good-faith estimate of the value of your personal information is based on the average marketing cost per new customer acquisition minus the cost of the Free Play credits provided.
If you are a resident of the State of California and would like to learn how your "personal information" (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, please contact us using the methods described above.
This section applies to residents of the State of Texas, pursuant to the Texas Data Privacy and Security Act (Tex. Bus. & Com. Code Chapter 541, "TDPSA"), effective July 1, 2024.
As a Texas resident, you have the following rights regarding your personal data:
To exercise your TDPSA rights, please contact us at get-answers@genda-americas.com or by U.S. Mail to the address listed in the "Contact Us" section. We will respond to your request within forty-five (45) days of receipt. We may extend this period by an additional 45 days if reasonably necessary, in which case we will notify you within the initial response period.
If we decline your request, you may appeal our decision within a reasonable time by e-mailing get-answers@genda-americas.com with the subject line "TDPSA Appeal." We will respond to your appeal in writing within sixty (60) days. If your appeal is denied, you may file a complaint with the Texas Attorney General using their Online Complaint Portal or directly visiting https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/.
Pursuant to Nevada Revised Statutes Chapter 603A, Nevada residents have the right to opt-out of the "sale" of their "covered information" for monetary consideration.
Important Note: We do not currently sell your personal information as defined under Nevada law. However, we will maintain your request on file should our practices change in the future.
If you are a resident of Delaware, you have specific rights under the Delaware Personal Data Privacy Act (DPDPA). This section provides details on how App complies with this law and how you can exercise your rights.
Under the DPDPA, we collect and process the following categories of personal data based on your use of the App:
We use these categories for account management, service delivery (Free Plays), and app optimization.
As a Delaware resident, you have the following rights regarding your personal data:
In accordance with the DPDPA, we do not process sensitive personal data (such as precise geolocation) without your prior affirmative consent. You may revoke this consent at any time via your device settings.
To exercise your Delaware privacy rights, please contact us at get-answers@genda-americas.com or by mail at the address listed in the "Contact Us" section.
Effective January 1, 2026, we will honor recognized, automated universal opt-out preference signals (such as Global Privacy Control) that indicate your intent to opt out of the sale of data or targeted advertising.
Resident of certain US states, including, but not limited to, Colorado, Connecticut, Virginia, Oregon, and Montana, have specific rights under their respective state laws. These rights include the Right to Access, Correct, Delete, and Port your personal data.
Please submit your request via the methods in our "Contact Us" section. We will respond within 45 days. If your appeal is denied, you may contact your state's Attorney General.
For purposes of this Privacy Policy, "personal information" means information that identifies, relates to, or could reasonably be linked to an individual. This includes identifiers such as IP addresses, device identifiers, and internet activity information. We collect personal information when you register for an account or interact with the Kiddleton Offerings.
We may collect the following categories of the following information:
We limit collection to the information reasonably necessary to provide and improve our services.
When you use the App, we automatically collect certain information from your device. Please note that under applicable privacy laws (including the CCPA), much of this information constitutes "personal information" even though it does not directly identify you by name. This automatically collected information includes:
We use automatically collected information to improve the design and content of the Kiddleton Offerings, diagnose technical problems, personalize your experience, and analyze usage in aggregate.
We use the personal information we collect for the following specific purposes:
We do not use the personal information we collect for purposes that are incompatible with the specific purposes described above without first providing you notice and, where required by law, obtaining your consent.
We do not sell your personal information to third parties. We may share your personal information with the following categories of service providers who perform functions on our behalf:
We share personal information with these service providers only to the extent necessary for them to perform their functions, and we do not permit them to use your personal information for any other purpose.
We may also contact you with updates and information related to your account or the Kiddleton Offerings, and to keep you informed of our products and services.
Legal & Business Transfers: We may also disclose your information: (i) to comply with legal obligations or valid law enforcement requests; (ii) to protect our rights or property; or (iii) as part of a merger, sale, or business transfer.
The App includes features that use your device's location to help you find nearby arcade and amusement machine store locations. When you use these features:
You may register and sign in to the App through Apple Sign-In, Google Sign-In, or SMS authentication. When you sign in through these services:
When using these services, your data is also subject to the respective privacy policies and terms of Apple, Google, or the applicable authentication provider.
We use this information solely to create and manage your account within the App. It is up to you which authentication method to use and what information to share with us.
The App may integrate with Apple Wallet and Google Wallet to deliver Free Play coupons. When you use these features:
If you register using SMS authentication or opt in to receive SMS communications from us, the following applies:
If you choose SMS as your authentication method, we will use your phone number solely to send verification codes for account sign-in and security purposes. Your phone number provided for authentication is not automatically enrolled in promotional messaging. Authentication-related messages cannot be opted out of while you maintain an SMS-based account.
We may offer you the opportunity to receive promotional SMS messages regarding Free Play offers and other Kiddleton Offerings. Promotional messaging is separate from authentication messaging and requires your prior express written consent in compliance with the Telephone Consumer Protection Act ("TCPA"). You will not receive promotional SMS messages unless you have affirmatively opted in to receive them (for example, by checking a consent box or texting a keyword to a designated number).
By providing your phone number, you represent that you are the current subscriber or authorized user of the phone number provided. You agree to promptly notify Kiddleton if your phone number changes or is reassigned by e-mailing us at: get-answers@genda-americas.com.
We may send you push notifications regarding Free Play coupon distributions, promotions, and other updates related to the Kiddleton Offerings. You may opt out of receiving push notifications at any time by adjusting your device's notification settings.
We use third-party marketing and analytics platforms to help us deliver and optimize our communications with you. These service providers receive certain data (e.g., e-mail address, device identifiers, and app usage data) solely to provide services on our behalf.
We require our service providers to:
Advertising Identifiers: We do not currently use advertising identifiers (such as Apple's IDFA or Google's Advertising ID) to track you across apps or websites owned by other companies. If we begin using such identifiers in the future, we will obtain your affirmative consent as required by Apple's App Tracking Transparency framework and applicable laws.
We may utilize analytic services to capture and analyze usage patterns within the App. These analytic services collect information about your use of the Kiddleton Offerings, including screens viewed, features used, session duration, the type of device and operating system you are currently using, and your approximate location.
While we use this information in de-identified or aggregate form to generate statistical reports, we treat the underlying data as personal information in accordance with this Privacy Policy and applicable laws. We use these insights solely for internal analysis and app optimization. You may limit certain analytics collection by adjusting your preferences in the "Your Privacy Choices" section of the App settings.
The App may contain links to or integrations with third-party services, including but not limited to Apple Maps and Google Maps to provide navigation to store locations.
We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:
| Data Type | Retention Period |
|---|---|
| Account information (name, e-mail, phone) | Retained while your account is active, plus thirty (30) days after account deletion |
| Authentication tokens | Deleted upon logout or token expiry |
| Location data | Not stored persistently; used in real-time for distance calculations and discarded |
| Free Play balance and redemption history | Retained while the account is active, plus thirty (30) days after account deletion. If used for a specific eligibility decision, records are retained for one (1) year to comply with standard US record-keeping and dispute resolution practices. |
| App usage and analytics data | De-identified or aggregated and anonymized; retained for up to twenty-four (24) months |
| Compliance Records | Records of privacy requests/responses are retained for 24 months (Texas/US best practice) |
| Backup systems | Personal information purged from backup systems within ninety (90) days of account deletion |
Notwithstanding the above, we may retain personal information for longer periods where required by law (such as for tax, accounting, or regulatory purposes), where necessary to resolve disputes or enforce our agreements, or where subject to a litigation hold or government investigation.
We endeavor to safeguard and protect our Users' personal information. When Users make personal information available to us, their personal information is protected both online and offline. When we store and transmit personal information, that information is encrypted with advanced TLS (Transport Layer Security). Data at rest is encrypted using industry-standard encryption provided by our cloud infrastructure provider (Amazon Web Services).
We take rigorous measures to ensure your personal information remains private and inaccessible to the Public. To maintain this security, your data is stored in a secure cloud environment with strict access controls, where access is strictly limited solely to authorized personnel – including our employees, contractors, affiliates, and trusted third-party agents – who require it to perform their specific job duties.
We implement industry-standard security measures to protect your data. However, please be aware that no storage facility, electronic storage, technology, software, security protocols or method of transmission over the Internet or via wireless networks is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Any transmission of data is at your own risk.
In the event of a security breach involving your personal information, we will notify you and the appropriate regulatory agencies (such as the Texas Attorney General, California Attorney General) in accordance with applicable laws.
We will provide this notice without unreasonable delay, For California and Texas residents, notice will be provided within 30 days of discovery. Notification will be sent via email or in-app message and will include (a) what happened; (b) what information was involved; (c) what we are doing; (d) what you can do; (e) for more information; and (f) any additional information and process required by law; such as for Texas, whether law enforcement is currently investigating the incident. We may delay notification only if requested by law enforcement, or if necessary to determine the scope of the breach and restore system integrity.
We reserve the right to release current or past personal information: (I) in the event that we believe that the Kiddleton Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (II) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena; or (III) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Kiddleton is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice within the App of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.
Kiddleton may create, use, license, or sell aggregate or de-identified data derived from User information for lawful purposes, such as analytics, research, and improving the Kiddleton Offerings. "Aggregate" or "de-identified" data is information that has been processed so that it cannot reasonably be linked to, or used to identify, an individual or household.
Where we maintain or use de-identified data, Kiddleton commits to:
Regardless of the de-identification status, Kiddleton honors "Do Not Sell or Share" requests and Global Privacy Control (GPC) signals as required by applicable state and federal laws.
The App is intended for individuals eighteen (18) years of age or older. By creating an account or using our services, you represent and warrant that you meet this age requirement.
Kiddleton does not knowingly collect, use, or disclose personal information from individuals under the age of 18 without appropriate legal consent as outlined below.
Children Under 13. In accordance with the Children's Online Privacy Protection Act (COPPA) and the Texas Data Privacy and Security Act (TDPSA), Kiddleton does not knowingly collect personal information from children under 13. If we discover we have inadvertently collected information from a child under 13 without verifiable parental consent, we will:
Minors Aged 13–17 (California and Texas).
Parental Rights. Parents or guardians who believe their minor child has provided us with personal information without required consent may contact us at get-answers@genda-americas.com. You may request to review, delete, or stop the further collection of your child's information. We will verify your identity before processing such requests to protect the minor's privacy.
Kiddleton encourages parents and guardians to monitor the online and mobile activities of their children.
Your Opt-Out Rights and Communication Preferences. You have the right to control how we communicate with you and how we process your data.
To stop receiving promotional emails, push notifications, or SMS, you may:
Residents of California and Texas have additional legal rights:
Notwithstanding your marketing preferences, we will continue to send "transactional" or "functional" communications necessary for your use of the Kiddleton Offerings. This includes account authentication codes, security alerts, and notices regarding material changes to our Privacy Policy or Terms.
At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected.
You may do so by:
We will process your request within thirty (30) days of receipt.
To protect your privacy and security, we will take steps to verify your identity before granting access or fulfilling any request to modify or delete personal information. We may require you to provide information that matches the data we already have on file or to log in to your account.
We reserve the right to decline requests that:
If we decline a request, we will notify you within thirty (30) days of the reason for our decision and provide information on how you may appeal.
Upon account deletion:
Geographic Restrictions and International Transfers: The App is intended for use solely by residents of the United States. If you are using the App from a country other than the United States, please be aware that your personal information will be transferred to, stored, and processed on to our servers located in the United States. By using the App and/or otherwise communicating electronically with us, you acknowledge and consent to this transfer. We protect your information as described in this Privacy Policy regardless of where it is stored. However, please be aware that while your personal information is located in the United States, it may be subject to local US laws and accessible to U.S. courts, law enforcement, and national security authorities. We maintain strict accountability for your data and use contractual safeguards or other means to ensure a comparable level of protection is provided during international processing.
Kiddleton reserves the right to change or update this Privacy Policy at any time by posting a notice within the App or on our website, with a date in which changes or updates are made. A material change includes, but is not limited to: collecting new categories of personal information, using personal information for a substantially different purpose, or sharing personal information with new categories of third parties. If we make material changes, Kiddleton will notify Users by: (a) sending the modified policy to our Users via email; and/or (b) providing an in-app notification; and/or (c) any other reasonable means such as a prominent splash screen upon App launch, as permitted under applicable state, federal law. Where required by law, you will have a choice as to whether we use your information in a different manner, and we will obtain your explicit opt-in consent before processing.
This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law provisions. Any disputes arising from or related to this Privacy Policy shall be resolved in accordance with the dispute resolution provisions set forth in the Terms and Conditions.
Our privacy practices are designed to comply with the requirements of the Apple App Store and Google Play Store. The information disclosed in our App Privacy labels (Apple) and Data Safety sections (Google) is consistent with this Privacy Policy. If you have questions about any discrepancy, please contact us.
If you have any questions about this Privacy Policy or our privacy practices in general, please e-mail us at: get-answers@genda-americas.com; or send us U.S. Mail to: GENDA Americas Inc., 246 S. Taylor Ave., Suite 200, Louisville, CO 80027.
If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact the Privacy Officer or our Privacy Team at:
GENDA Americas Atten: Privacy Officer ([Michael Williams]) 246 S. Taylor Ave., Suite 200 Louisville, CO 80027 Email: get-answers@genda-americas.com
We aim to respond to all inquiries within thirty (30) days of receipt.
If you have questions or concerns about our privacy practices, please contact us first. If we are unable to resolve your concern, you may contact the following authorities: