Privacy Policy

Last updated: 31 October 2026

Contents

1. Who we are
2. What this policy covers
3. What we collect, and why
4. Children
5. Who else is involved
6. How long data is kept
7. International transfers
8. Security
9. Your rights
10. Complaints
11. Changes to this policy
12. Contact us

1. Who we are

NeuroKind Games is an independent game studio run by Dr Oli Delgaram-Nejad in the United Kingdom. We make games and apps for itch.io, Roblox and Google Play, plus this website. We are the "data controller" for the small amount of personal data described here, which means we decide how it's used and are responsible for it.

You can reach us at c0gn8pgr@gmail.com or on +44 7496 341876.

2. What this policy covers

• this website, c0gn8.github.io;
• our browser games on itch.io, including Charleston, our live AI penguin, and his live stream on Twitch;
• our Roblox games;
• our Android apps on Google Play;
• emails and messages you send us.

itch.io, Twitch, Roblox and Google Play are run by other companies, which collect data under their own privacy policies (for example your account, purchases and how you use their platform). We don't control that collection, so please read their policies too: itch.io, Twitch, Roblox and Google.

3. What we collect, and why

3.1 This website

The website has no accounts, forms, analytics, advertising or cookies. One outside service is involved in showing it to you:

• GitHub Pages hosts the site. Like any web host, it processes your IP address to deliver the pages and to protect against attacks. See GitHub's privacy statement.

The website's lettering (fonts) is stored on the website itself, so your browser never contacts Google or any other font service. We don't receive or keep any of this data ourselves. Lawful basis: legitimate interests (showing you a working, secure website).

The website's Donate on GoFundMe button is a plain link: nothing from GoFundMe loads on our pages, so it sets no cookies and tracks nothing here. If you click it, you leave our site for GoFundMe, where GoFundMe's privacy policy applies to anything you do there, including donating. We never receive donors' card details. As the organiser, we may see a donor's name, the amount and any message they leave (unless they choose to donate anonymously); we use this only to say thank you, and never share it. Donations are for adults only; our games never ask children for money.

3.2 Our browser games on itch.io

Our games don't ask for any personal information, and contain no ads or analytics. Some save your progress or settings (for example, "you've already seen the welcome screen") in your browser's local storage. That information stays on your device: we never receive it, and you can delete it at any time by clearing your browser's site data. Our games carry their own lettering (fonts), so they never contact Google or any other font service. itch.io shows us anonymous totals, such as how many people viewed or downloaded a game, which don't identify anyone.

Typing and talking to IRIS. In IRIS and Biscuits you can type orders to IRIS, the ship's computer. The game understands them on your device; they're never sent anywhere. You can also talk to IRIS out loud. Voice works only after you choose it, and your browser asks you for permission to use the microphone. Where your browser can recognise speech on your own computer (recent versions of Chrome on a desktop or laptop), IRIS uses that, and the sound never leaves your device. Otherwise, the game asks you first, because your browser then sends the sound of what you say to the company that makes it (Google for Chrome, Microsoft for Edge) to turn it into words, under that company's privacy policy. We never receive your voice or what you said. The game remembers, on your device, that you chose voice, and the new ways of saying orders that IRIS has learned from you. Children under 13 should ask a parent or carer before choosing voice; typing works just as well.

3.3 Charleston, our live AI penguin

Charleston lives on our own computer, and the itch.io page connects to it live. Visitors can watch him and do a few kind things from a fixed menu: wave, send a gift, grant his wishes, suggest what he does next, or pick an answer when he asks visitors a question. No visitor can type messages, create an account, or give Charleston any personal information. The only person who can write to Charleston is the studio owner, from our own computer; those messages and Charleston's replies are shown publicly and contain no visitor data.

Charleston's thoughts are generated by Claude, an AI made by Anthropic. Anthropic receives Charleston's own situation (what he's doing, anonymous totals such as "5 visitors suggested stargazing"), but no visitor IP addresses or other personal data. Visitors reach Charleston through a secure tunnel run by Tailscale, which routes the connection and so handles your IP address. His journal, paintings, music and blog are created by him and contain no visitor data.

Charleston on Bluesky. Charleston has a Bluesky account (@charlestonpenguin.bsky.social). Each time he publishes a blog post, his computer automatically shares its title, opening lines, a link and his painting (or a picture of one of the little arcade games he makes for his own arcade machine) there. It only posts: it never reads replies, mentions or messages, and never shares anything about visitors. Following or replying to him on Bluesky is covered by Bluesky's privacy policy, and we don't receive anything about who follows him beyond what Bluesky shows publicly.

Charleston on Twitch. We also stream Charleston's world live on Twitch. The stream shows only his world (no visitor data, and nothing else from our computer). Watching or chatting on Twitch is covered by Twitch's own privacy notice: we don't receive viewers' personal data, only anonymous totals Twitch shows us, such as how many people watched. Charleston can't see Twitch chat, and we keep chat restricted and moderated. Twitch is for ages 13 and over; younger children can watch Charleston on itch.io instead, where nobody can chat at all.

Ads on Twitch. Twitch runs adverts on the streams it hosts, and as a Twitch Affiliate our agreement with Twitch means we can't turn them off completely. We keep them to the minimum Twitch allows. The adverts are chosen and shown by Twitch (part of Amazon), not by us, and Twitch may use viewers' information to choose them, as explained in Twitch's privacy notice, which also explains your ad choices. We never see who watches an advert or anything about them. Our games, this website and Charleston's itch.io page have no adverts at all.

Lawful basis: legitimate interests (running the experience and preventing abuse).

3.4 Our Roblox games

Our Roblox games don't ask for any personal information. Like most Roblox games, they may save your in-game progress (for example scores, unlocks or settings) on Roblox's servers, linked to your Roblox user ID, a number Roblox assigns to your account. We can't see your real name, email address, age or anything else about your account. Roblox runs accounts, chat, purchases, age checks and parental controls under its own rules and privacy policy, and gives us only anonymous gameplay statistics.

Lawful basis: legitimate interests (saving your progress so the game works as you'd expect).

3.5 Our Android apps on Google Play

• Our apps collect no personal data. They don't ask for your name, email address, photos, contacts or location, and don't use the Android advertising ID or other device identifiers.
• Your progress (for example your pet and its outfits, or your sticker book) is stored on your device only, and is deleted when you uninstall the app. In Stick and Learn, children can make people that look like themselves, their family and friends from drawn sticker pieces (skin tone, hair, clothes, glasses, a wheelchair and so on). These are just stickers saved in the app on the device: no photo is taken, nothing is analysed, and nothing leaves the device.
• Our apps contain no ads, no in-app purchases, no chat, no social features and no links to social media.
• Our apps have no internet access: they don't request Android's internet permission, so they can't send anything anywhere.
• We use no third-party software kits (SDKs) that collect data.
• Android's cloud backup is switched off for our apps, so your saves aren't copied to your Google account either.
• Each app shows a short version of this policy inside it (BrainyPet and Stick and Learn: the Grown-ups area, behind the padlock; Mind Palace: Settings, then Privacy).
• Google Play may send us anonymous crash reports and download statistics through its Play Console, under Google's privacy policy. These help us fix bugs and don't identify you.

Each app's Data safety section on Google Play matches this policy. If an app ever needs to change any of this, we'll update this policy and the Data safety section before the change is released.

3.6 When you contact us

If you email or phone us, we use your contact details and message only to reply. Emails are held in our Gmail account (provided by Google). Lawful basis: legitimate interests (answering you).

4. Children

Many of our games are suitable for children, and some are made especially for them. We design every game so that it doesn't collect personal information from children.

4.1 COPPA (United States, children under 13)

We comply with the Children's Online Privacy Protection Act. We don't knowingly collect personal information from children under 13. Our games don't ask for it, and there's no chat in our itch.io games or Android apps for children to share it through. Our Android apps can't connect to the internet at all. In IRIS and Biscuits, anything typed stays on the device, and voice control works only after a player chooses it (see section 3.2): we never receive any recording or transcript of a child's voice. On Roblox, chat is provided and filtered by Roblox under its own children's privacy rules. If we ever plan a feature that would need a child's personal information, we'll first give parents direct notice and get verifiable parental consent, and let parents review or delete it at any time.

4.2 UK and EU rules for children

Under the UK GDPR and EU GDPR, children's data deserves special protection. We follow the UK Age Appropriate Design Code (the Children's Code):

• the most private settings by default;
• only the minimum data needed for a game to work;
• no profiling and no location tracking;
• no nudges that encourage children to give up privacy;
• no sharing of children's data;
• explanations children can understand.

We don't rely on consent for any processing, so the age of digital consent (13 in the UK, between 13 and 16 in EU countries) doesn't come into play. If that ever changes, we'll ask a parent or guardian for consent for younger children.

4.3 Google Play Families Policy

Our apps for children, or that include children in their audience, follow the Google Play Families Policy:

• accurate target audience and content settings;
• no collection of advertising IDs, device identifiers or location;
• no ads, no third-party SDKs that collect data, and no social features;
• content suited to the age groups we select.

4.4 Roblox and itch.io

Roblox and itch.io set their own age rules and parental controls for their accounts and features, including Roblox's chat, which Roblox filters and lets parents limit or turn off. Parents can manage these in each platform's settings. Our itch.io games have no chat with other players at all, and none of our games ask children for personal details.

If you believe a child has given us personal information, contact us at c0gn8pgr@gmail.com and we'll delete it promptly.

5. Who else is involved

We never sell personal data, and never share it for advertising. The only other organisations involved are those that help run our games, each handling only what's described above:

We'd also disclose information if the law required it, or to protect someone's safety.

6. How long data is kept

• Charleston: IP addresses for about 10 minutes and suggestion hashes for up to 2 hours, in memory only.
• Game progress: on your device until you delete it, or on Roblox until Roblox deletes your account data.
• Emails and messages: for up to 2 years after our last contact, then deleted.
• Platform data (itch.io, Roblox, Google, GitHub, Tailscale): for as long as each company's own policy says.

7. International transfers

Some of the companies above are based in the United States. Where your data goes there, it's protected by the safeguards those companies provide, such as the UK–US Data Bridge, the EU–US Data Privacy Framework, or standard contractual clauses.

8. Security

Our best protection is collecting almost nothing. On top of that, connections are encrypted (HTTPS), Charleston's computer is reachable only through a secure tunnel that never exposes our home network, suggestion data is hashed, and only the studio owner has access.

9. Your rights

Under the UK GDPR and EU GDPR, you can ask us to:

• see the personal data we hold about you;
• correct it;
• delete it;
• restrict or object to how we use it;
• give it to you in a portable format.

Parents and guardians can make these requests for their children. If you live in California or another US state with a privacy law, you have similar rights to know, correct and delete, and to opt out of the "sale" or "sharing" of personal information. We don't sell or share it.

To make a request, email c0gn8pgr@gmail.com. We'll reply within one month. Because we collect so little, we often won't hold anything that identifies you, but we'll always tell you what we find.

10. Complaints

If you're unhappy with how we've handled your data, please contact us first and we'll do our best to put it right. You can also complain to:

• the UK Information Commissioner's Office: ico.org.uk;
• your local data protection authority if you're in the EU;
• the US Federal Trade Commission for concerns about children's privacy: ftc.gov.

11. Changes to this policy

We'll update this page whenever our games or the law change, and show the new date at the top. If a change affects children's data, we'll make it clear in the game or app before the change takes effect, and ask parents for consent where the law requires.

12. Contact us

NeuroKind Games · Dr Oli Delgaram-Nejad
Email: c0gn8pgr@gmail.com
Phone: +44 7496 341876