Last updated October 19, 2025
We are Salasto ("Company," "we," "us," "our"). We operate http://www.shubeklubek.com (the "Site") and the mobile application Shubek Lubek (the "App"), as well as any related products and services (the "Services"). Contact us at shubeklubek@salasto.com.
These Legal Terms constitute a legally binding agreement between you and Salasto concerning your access to and use of the Services. By accessing the Services, you agree to be bound by these Legal Terms. IF YOU DO NOT AGREE, YOU MUST DISCONTINUE USE IMMEDIATELY.
CHILDREN'S APP NOTICE: This application is designed for children aged 3-12 years. All users must have explicit parental or guardian consent. The paying subscriber (parent/guardian) is responsible for providing consent for data collection.
TABLE OF CONTENTS
2.INTELLECTUAL PROPERTY RIGHTS
9. USER GENERATED CONTRIBUTIONS
11. MOBILE APPLICATION LICENSE
14. CHILDREN'S PRIVACY AND PARENTAL CONSENT
15. PARENTAL RIGHTS AND CONTROLS
17. DATA COLLECTION AND PROCESSING
The Services are designed for children aged 3-12 years and comply with applicable children's privacy regulations including COPPA (USA) and GDPR (EU).
The Services are primarily designed for and marketed to users in Iraq. However, the Services are available internationally and may be accessed from other countries.
We own or license all intellectual property rights in our Services, including all content, software, designs, and trademarks ("Content" and "Marks").
Your Use: Subject to these Terms, we grant you a non-exclusive, non-transferable, revocable license to access and use the Services for personal, non-commercial use only.
Your Submissions: By sending us feedback or suggestions ("Submissions"), you assign all intellectual property rights in such Submissions to us.
Your Contributions: The Services may allow you to create, submit, or post content ("Contributions"). All children's Contributions require parental gate verification before external sharing and are subject to content moderation.
By using the Services, you represent that:
You agree to keep your password and Parental PIN confidential and are responsible for all account use.
Parental Verification: Registration requires parental verification through an OTP, App Store or Google Play subscription, and Parental PIN setup. We log consent events for compliance purposes.
By registering, you confirm you are the parent/guardian with authority to provide consent for data collection.
We accept payment through:
You agree to provide current, accurate purchase information and authorize charges to your payment method. We may change prices at any time.
Our users will be charged in their country's currency according to App Store/Google Play pricing.
All pricing and currency conversion is managed by Apple and Google according to their policies. You are responsible for any currency conversion fees charged by your payment provider.
Parental Authorization: All purchases require parental gate verification.
Billing: Your subscription continues and auto-renews monthly unless canceled. You consent to recurring charges without prior approval until you cancel.
Cancellation: Cancel through App Store or Google Play subscription settings. Cancellation takes effect at the end of the current paid term.
Note: Account deletion does not cancel subscriptions. Cancel separately through your platform (App Store/Google Play).
Platform Refunds: All subscriptions are processed through App Store or Google Play. Submit refund requests directly to Apple or Google:
Accidental Purchases: We recognize children may make accidental purchases. For accidental/unauthorized purchases:
Request refund through your platform (App Store/Google Play) immediately
Refunds are subject to Apple/Google policies and typically process within 5-10 business days.
You may not:
The Services may allow you to create, submit, or post content ("Contributions"). When you create Contributions, you represent that:
Children's Content: For children's Contributions (aged 3-12):
We may remove any Contribution at any time without notice if it violates these Terms.
Adult Contributions: By posting Contributions as a parent/guardian, you grant us a worldwide, royalty-free license to use, copy, reproduce, and distribute such Contributions for any purpose.
Children's Contributions: For children's Contributions, you grant us a limited license to:
This does NOT include rights to use children's content for advertising, marketing, or commercial exploitation. Parents can request deletion at any time.
If you access Services via the App, we grant you a limited, non-transferable license to install and use the App on devices you control, in accordance with these Terms.
You shall not: decompile, reverse engineer, modify, or use the App for commercial purposes.
Apple and Android: The license is subject to App Store and Google Play terms. Apple and Google are third-party beneficiaries of this license.
We reserve the right to: monitor the Services; take legal action against violators; restrict access to Contributions; remove excessive content; and manage the Services to protect our rights and users.
Please review our Privacy Policy at http://www.shubeklubek.com/privacy-policy. By using the Services, you agree to our Privacy Policy.
Data Hosting: Services are hosted in Doha, Qatar. By using Services, you consent to data transfer to Doha, Qatar.
EU Users: We implement Standard Contractual Clauses for data transfers as required by GDPR.
US Users: We comply with COPPA regardless of hosting location.
Age Requirements: This app is for children aged 3-12. Parental consent required for users under 16 (EU) or under 13 (US).
Parental Consent: Before collecting children's information, we require explicit parental consent through App Store or Google Play subscription. Consent covers:
Consent Management: Parents may review, modify, or withdraw consent through Parents Space.
Parents Space: Parents can access data controls using their Parental PIN to:
PIN Reset: Reset PIN through OTP verification to registered mobile number. For assistance, contact shubeklubek@salasto.com.
Data Requests: Request access, correction, or deletion by contacting shubeklubek@salasto.com. We respond within 30 days per applicable law.
The following require Parental PIN verification:
Notifications: Parents control all notifications through Parents Space. All are opt-in. We do not send marketing to children.
Data Minimization: We collect only the minimum information necessary for the App to function properly.
Information Collected:
a) Account: Mobile number, Parental PIN, child's name/age/gender (optional)
b) Avatar: Temporary selfie (optional, deleted immediately), generated avatar
c) Voice: Recording samples (optional, can be deleted)
d) Usage: Story progress, achievements, choices
e) Technical: Device identifiers, IP address, session tokens
Processing Purposes: Personalizing content, generating avatars, tracking progress, ensuring security, complying with legal obligations.
No Advertising: We do not use children's information for behavioral advertising.
Data Retention:
Security: All data is encrypted and stored securely.
Parents may request deletion through Parents Space or by emailing shubeklubek@salasto.com.
Upon deletion:
IMPORTANT: Account deletion does not cancel subscriptions. Cancel separately through App Store or Google Play.
These Terms remain in effect while you use the Services. We may terminate your account at any time for violating these Terms or applicable law.
These Terms are governed by the United Arab Emirates law. We comply with COPPA (USA) and GDPR (EU) regardless of jurisdiction.
Disputes submit to Dubai, UAE courts. We may also bring proceedings in your country of residence.
Contact us at shubeklubek@salasto.com before legal action to resolve informally.
THE SERVICES ARE PROVIDED "AS-IS" AND "AS-AVAILABLE." WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED. WE ARE NOT LIABLE FOR ERRORS, INTERRUPTIONS, SECURITY BREACHES, OR THIRD-PARTY CONTENT.
WE ARE NOT LIABLE FOR INDIRECT, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING FROM YOUR USE OF THE SERVICES. OUR LIABILITY IS LIMITED TO THE AMOUNT PAID BY YOU OR $100, WHICHEVER IS LESS.
This does not affect statutory rights under children's privacy laws that cannot be waived.
We implement reasonable security measures to protect children's information.
Parents are responsible for:
Parents can view, download, edit, and delete the child's data through Parents Space.
Salasto
DIFC, Gate Village 8
Dubai, UAE
Email: shubeklubek@salasto.com
Or contact us using the contact form
For privacy inquiries, data requests, refunds, or support, email us with a clear subject line.
