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.

Each App in the family is built to the same set of privacy commitments. The short version: the Apps run on your device, do not collect personal data, contain no advertising, and integrate no third-party trackers, analytics or SDKs of any kind.

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.
• We do not request, present or honour the App Tracking Transparency permission, because we do not track.

3. Information we do NOT collect

We specifically do not collect:

• Names, email addresses or contact information
• Location data (precise or coarse)
• Device identifiers for advertising (IDFA, IDFV, GAID)
• Photos or camera access (unless the user explicitly saves an image to their own library)
• Contacts
• Microphone or audio input
• Health or fitness data
• Biometric data (Face ID, Touch ID — we do not use them)
• Network or connection data beyond what iOS itself reports to Apple

4. Information stored only on your device

For the Apps to function, a small amount of data must be stored locally on the device. None of this leaves the device, none of it is sent to Sentium, and none of it is shared with anyone. It is held in iOS's standard local storage (UserDefaults) and is removed if the App is uninstalled.

For Alfie Puzzles specifically, the on-device data is:

• Your settings preferences — piece counts per category, the "show puzzle guide" toggle, and the sound effect / background music toggles.
• The list of puzzle IDs your child has completed, used to display a small star on already-finished thumbnails.
• A cached "is the user's premium subscription currently active?" flag, refreshed from Apple's StoreKit on app launch and after any purchase or restore action.

This information is anonymous, never associated with any identity, and never transmitted off the device.

5. 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, and most function fully offline once installed.

The only information that ever reaches Sentium is what Apple itself shares with us through the standard App Store Connect dashboard — anonymised, aggregated metrics such as the total number of downloads in a country, the iOS version distribution of users, and Apple-collected crash reports. These are produced by Apple, are not attributable to individual users, and are not enriched, joined or augmented by us.

6. 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
• Apple's "Made for Kids" category requirements, under which the Apps are listed

We do not knowingly collect personal information from any user, regardless of age. The Apps contain no advertising, no chat or messaging, no friends list or social features, no user-to-user content of any kind, and no behavioural tracking. Any link from the App to an external web page (for example to this privacy policy or to support resources) is gated behind a parental challenge to prevent a child from leaving the App accidentally.

7. 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. We do not integrate any third-party SDKs in the Apps.

The only entity that processes any data in connection with the Apps is Apple, acting as the platform provider. Apple processes:

• App Store download and installation
• Subscription billing, renewal, and cancellation through your Apple ID
• Standard iOS crash reports if a user has opted in to share diagnostics with developers via iOS Settings
• Aggregated, anonymised App Store usage statistics surfaced to us in App Store Connect

Apple's processing is governed by Apple's own privacy policy at apple.com/legal/privacy.

8. In-app purchases and subscriptions

Where an App offers in-app purchases or subscriptions (Alfie Puzzles offers a single auto-renewing Premium subscription priced at $1.99 USD per month with a seven-day free trial for new subscribers), the entire purchase flow is handled by Apple via StoreKit 2. Billing, renewal, refunds, payment instruments, and the user's Apple ID are managed by Apple — Sentium never sees any of these details.

What Sentium sees from a successful purchase is limited to the fact that the user's Apple ID currently holds a valid, non-expired entitlement for the subscription product, returned to the App by StoreKit's local entitlement check. We see no name, no email, no payment details, no transaction amount, no Apple ID, no IP address, and no other identifying information.

Restoring a previous purchase uses the same StoreKit mechanism and conveys the same minimal, anonymous entitlement signal. Sandbox / test purchases (used by us and by Apple's reviewers during development and review) function identically and equally do not transmit personal data to Sentium.

9. 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, settings, or completion records reside only on the user's device, in iOS's standard sandboxed app storage. If the App is uninstalled, that data is permanently removed.

10. 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.

11. Data retention

Sentium retains no user data because Sentium collects no user data. The on-device information described in section 4 persists for as long as the App is installed and is removed when the App is uninstalled or when the user clears the App's data from iOS Settings.

12. Data controller details

The data controller for the Apps is:

13. 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.

14. 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. The version of this policy that applies to your use of an App is the version that was effective at the time of your most recent interaction with the App.

15. 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.