Privacy Policy

1. Introduction

This privacy policy describes how Sentium Ltd ("we", "us", "our") handles information in connection with the Alfie the Owl family of apps, including Alfie Colouring, Alfie Puzzles, and future Alfie apps (together, the "Apps").

Sentium Ltd is a company registered in England and Wales, company number 16512683, with a registered office at Suite Ra01, 195–197 Wood Street, London, England, E17 3NU.

2. What information we collect

The Apps are designed to collect as little information as possible. Specifically:

• We do not collect any personally identifiable information.
• We do not use device identifiers for advertising.
• We do not integrate any third-party analytics or tracking SDKs.
• We do not use cookies or similar technologies.

3. Information we do NOT collect

We specifically do not collect:

• Names, email addresses, or contact information
• Location data
• Device identifiers for advertising (IDFA, IDFV, GAID)
• Photos or camera access (unless the user explicitly saves an image to their own library)
• Contacts
• Microphone data

4. How we use information

Because we collect no personal data, there is no use of personal data to describe. The Apps function entirely on-device. Any crash reporting, if enabled, is handled by Apple via standard iOS mechanisms and contains no personally identifying information.

5. Children's privacy

The Apps are designed for children aged 4 to 10. We take children's privacy exceptionally seriously. We comply with:

• The UK General Data Protection Regulation (UK GDPR)
• The Children's Code (Age Appropriate Design Code) issued by the UK ICO
• The EU General Data Protection Regulation (EU GDPR) for users in the EEA
• The Children's Online Privacy Protection Act (COPPA) for users in the United States

We do not knowingly collect personal information from any user, regardless of age.

6. Third parties

We do not share any user data with third parties. We do not integrate advertising networks. We do not integrate analytics services that track individuals. Subscription purchases are handled entirely by Apple via StoreKit; we do not see or store payment information.

7. In-app purchases

Where an App offers in-app purchases or subscriptions, these are handled entirely by Apple. Billing, renewal, refunds, and payment information are managed through the user's Apple ID. We receive only an anonymous confirmation that a purchase is active.

8. Data security

Because we do not collect or store personal data on our servers, there is no central repository of user data to secure. Any artwork, saved progress, or user-created content resides only on the user's device. If the App is uninstalled, that data is permanently removed.

9. Your rights under UK GDPR and EU GDPR

Under UK GDPR and EU GDPR, you have the right to:

• Access any personal data we hold about you
• Request rectification of inaccurate data
• Request erasure ("right to be forgotten")
• Restrict processing
• Data portability
• Object to processing

To exercise any of these rights, email us at support@sentium.app. Because we do not collect personal data, in most cases the response will be a confirmation that we hold no information about you.

10. Data controller details

The data controller for the Apps is:

11. Complaints

If you are unhappy with how we have handled your data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO): ico.org.uk.

12. Changes to this policy

If we make material changes to this privacy policy, we will post the updated policy here with a new effective date. We recommend checking this page periodically for updates.

13. Contact

For questions about this privacy policy or your data:

Email: support@sentium.app

Post: Sentium Ltd, Suite Ra01, 195–197 Wood Street, London, England, E17 3NU, United Kingdom.