Legal
Privacy Policy — CadeNET
Effective Date: July 2026
Privacy Policy
Last updated: July 2026
This Privacy Policy is issued by **Haldun Akkoyunlu** (trading as "**Xibalba Software**", "we", "our", or "us"), the data controller for personal data processed through our website (xibalbasoftware.com), mobile applications, games, and related online services. We design this Policy to meet a high common standard under applicable privacy and child-protection laws, including the EU/UK GDPR, Turkey's KVKK (Law No. 6698), the US COPPA framework, and California CCPA/CPRA where they apply.
Where a translation of this Policy is provided, the **English** version prevails if there is any conflict.
1. Data Controller
Haldun Akkoyunlu (Xibalba Software)
Email: info@xibalbasoftware.com
Website: https://www.xibalbasoftware.com
2. Scope
This Policy covers all Xibalba Software consumer products listed on our website (apps, games, and web services such as CadeNET), unless a product-specific notice states otherwise. Internal tools and unpublished studio utilities are out of scope.
3. Information We Collect
Depending on the product and your choices, we may process:
We do not ask for government ID numbers or precise continuous GPS tracking as a core product feature.
4. How We Use Information
We use personal data to:
5. Legal Bases (GDPR / UK GDPR)
Where GDPR applies, we rely on: (a) consent; (b) performance of a contract; (c) legal obligation; and/or (d) legitimate interests in operating, securing, and improving our services — balanced against your rights.
6. Third-Party Services
Our products may use third parties that process data under their own policies, including:
7. Retention
We keep personal data only as long as needed for the purposes above, or longer when required by law (e.g. tax/accounting). You may request deletion as described in Section 10; we will erase or anonymise data unless a legal exception applies.
8. International Transfers
Service providers may process data outside Turkey or the EEA/UK. Where required, we use appropriate safeguards (such as Standard Contractual Clauses or equivalent mechanisms recognised under applicable law).
9. Children, COPPA, and Parent-Facing Products
**Games and general apps:** Our games and most apps are intended for a general audience and are **not directed to children under 13** (or the equivalent minimum age in your country). We do not knowingly collect personal information from children under 13 for those products. If you believe we have collected such information, contact us and we will delete it promptly.
**Baby Grow Sense (and similar parent tools):** These products are directed to **parents and caregivers (adults)**, not to children as end users. Any baby/child-related data (for example growth measurements, journal notes, or schedules) is entered by the adult account holder. We treat such information carefully; we do not sell children's personal information; and we do not use behavioural advertising, interstitial ads, or rewarded video ads in Baby Grow Sense. Limited non-personalised or contextual banner advertising may appear only where permitted by store and legal rules. YouTube integrations, if any, are used in restricted/kid-safe modes where applicable.
**EU/UK under-16 rules:** Where member-state or UK rules set a higher digital-consent age (up to 16), we require that under-age users only use our services with parental authority as required by law.
10. Your Rights
Depending on your location, you may have rights to access, correct, delete, restrict, or object to processing; data portability; and withdrawal of consent.
To exercise rights, email info@xibalbasoftware.com. We may need to verify your request.
11. Cookies, SDKs, and Opt-Out
Our website and apps may use cookies, SDKs, and similar technologies for essential operation, analytics, and (where applicable) advertising. You can control personalised ads through:
12. Security
We apply reasonable technical and organisational measures (access controls, encrypted transport where applicable, least-privilege practices). No method of transmission or storage is 100% secure.
13. Changes
We may update this Policy by posting a new version on this page with a revised "Last updated" date. Material changes will be highlighted on the website or in-app where appropriate.
14. Contact
Haldun Akkoyunlu (Xibalba Software)
info@xibalbasoftware.com
https://www.xibalbasoftware.com