🎨 Privacy Policy - Draw & Learn

Last Updated: March 25, 2026

1. Introduction

Draw & Learn is developed by Roberto Pires Almeida ("we", "our", or "the app"). We are committed to protecting the privacy of children and families. This Privacy Policy explains our practices regarding data collection, use, and protection.

2. Information We Do NOT Collect

We want to be crystal clear: Draw & Learn does NOT collect, store, transmit, or share any of the following:

• ❌ Personal Information - No names, emails, phone numbers, or addresses
• ❌ Location Data - We never access your location
• ❌ Camera - We do not access the camera
• ❌ Contacts - We never access your contact list
• ❌ Microphone - We don't record audio (we only speak to your child via text-to-speech)
• ❌ Analytics or Tracking - No third-party analytics, no advertising IDs, no tracking
• ❌ Drawings or Artwork - Your child's drawings are stored only on your device and never uploaded
• ❌ Usage Data - We don't track what your child draws, how long they use the app, or which categories they prefer

3. Data That Stays on Your Device

The following information is stored locally on your device only and is never transmitted anywhere:

• ✅ User Preferences - Language selection, sound settings
• ✅ Saved Drawings - Artwork created in the app
• ✅ Subscription Status - Managed entirely by Apple via StoreKit
• ✅ Optional Photo Export - If a parent chooses to save artwork to Photos, the app requests add-only photo access to write the selected image

4. Apple StoreKit and Purchases

All in-app purchases and subscriptions are handled exclusively by Apple through StoreKit:

• Apple processes all payment information
• We never see your payment details
• Purchase history is managed by your Apple ID
• We only receive a verification token from Apple confirming the subscription status
• All subscription management (cancellation, refunds, etc.) is done through your Apple ID settings

For Apple's privacy practices, please see: https://www.apple.com/privacy/

5. Speech Synthesis

Draw & Learn uses Apple's on-device AVSpeechSynthesizer to provide voice feedback from "Bob the learning buddy." This feature:

• Runs entirely on your device
• Does not record or transmit any audio
• Does not require an internet connection
• Can be turned off using the sound toggle

5A. Saving Artwork to Photos

Draw & Learn can export a drawing to the device photo library only when a parent or guardian chooses the save action. In that case:

• The app requests add-only photo library permission
• The app writes only the selected exported image
• The app does not read or scan the full photo library
• If permission is denied, the drawing remains only inside the app unless manually shared another way
• Save to Photos, printing, and deletion of saved drawings are protected by a parental gate

6. Third-Party Services

We do not integrate any third-party SDKs, analytics services, or advertising networks.

The only external service we use is Apple's StoreKit for subscription management, which is built into iOS.

7. Internet Connection

Draw & Learn works entirely offline after the initial download. An internet connection is only needed for:

• Downloading the app from the App Store
• Processing in-app purchases through Apple
• Restoring purchases on a new device

8. Children's Privacy (COPPA Compliance)

Draw & Learn is designed for children ages 3-8. We comply with the Children's Online Privacy Protection Act (COPPA) and similar international regulations:

• We do not knowingly collect personal information from children
• We do not allow children to publicly post or distribute personal information
• We do not enable behavioral advertising
• All purchases are protected by a parental gate
• No third-party access to any data

9. Data Security

Since all data stays on your device:

• Your data is protected by your device's security features (passcode, Face ID, etc.)
• No data transmission means no risk of data breaches
• You can delete all app data by deleting the app

10. Your Rights and Control

You have complete control over all data associated with Draw & Learn:

• Delete Drawings: Swipe to delete any saved drawing in the "My Art" gallery
• Reset Preferences: Delete and reinstall the app
• Manage Subscriptions: Settings → [Your Name] → Subscriptions
• Delete All Data: Delete the app from your device

10A. Parent Supervision

Parents and guardians are responsible for supervising children while using the app, deciding whether to export or share artwork, and ensuring children take regular breaks from screen time.

11. International Users

Draw & Learn is available worldwide. Since we don't collect or transmit any personal data, there are no cross-border data transfers to worry about.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. We encourage you to review this policy periodically.

If we make material changes that affect children's privacy, we will:

• Notify users through the App Store update notes
• Comply with all applicable laws regarding parental notification and consent

13. Contact Us

If you have any questions about this Privacy Policy or our practices, please contact us:

• Email: info@cambyte.co.uk
• App Store Support: Through the App Store page for Draw & Learn

14. Parental Rights

Parents and guardians can:

• Review what minimal information is stored locally on their device
• Refuse to permit further collection of data (by deleting the app)
• Request deletion of data (by deleting saved drawings or the app)

Since we don't collect personal information, there is no data for us to access, review, or delete remotely.

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© 2026 Roberto Pires Almeida. All rights reserved.