Draft. This text is a working draft and has not yet been reviewed by a lawyer. Highlighted parts are placeholders.
Privacy Policy
This policy explains how [COMPANY NAME] (“we”, “us”) handles information when you use the Oasis AAC app for iPad (the “App”) and this website. Oasis AAC is an augmentative and alternative communication (AAC) app: people tap picture cards or type to build sentences that the iPad speaks aloud.
The short version
- What a person says with the App — sentences, cards, photos, recordings and settings — is stored on the iPad. We do not receive it.
- You do not need an account to use the App.
- We do not show ads and we do not sell or share personal data for advertising.
- The App connects to our servers only to download languages and voices and to check for updates. These requests do not contain anything a person has said.
- Usage statistics are sent only if you allow it, and never include words, sentences, names or photos.
1. Who is responsible
The controller of personal data is [COMPANY NAME], [REGISTERED ADDRESS]. You can reach us at privacy@oasisaac.com.
2. Information that stays on your device
The App keeps the following only in its own storage on the iPad. We have no access to it:
- sentences and the words a person chooses, and counts of how often words are used (to improve the App's suggestions on that iPad);
- cards, folders and favourites a person creates, including photos taken with the camera and voice recordings;
- settings such as voice, speed, grid size, looks and touch preferences.
If you create a backup, the App writes a file that you save where you choose (for example Files or iCloud Drive). Where that file is stored is governed by that service's terms, not by us. Deleting the App deletes the data stored by it on the iPad.
Camera and microphone
The App asks for camera access only when you take a photo for a card, and for microphone access only when you record a voice for a card. Photos and recordings stay on the iPad.
Speech
Downloaded voices speak entirely on the iPad. If you choose one of Apple's system voices, speech is produced by iPadOS on the device.
3. Information we receive
| What | When | Why |
|---|---|---|
| Technical request data: IP address, time, the file requested, app version | When the App downloads a language, a voice or a voice sample, and once per start to check whether updates are available | To deliver the files and keep the service secure and working (legitimate interest) |
| Usage statistics: an install identifier created by the App, device type, iPadOS and App version, which screens and settings are used, counts such as how many sentences were spoken per day | Only if you allow statistics in the App | To understand which features help and to fix problems (consent) |
| Error reports: what went wrong in the App, without personal content | Only if you allow statistics in the App | To fix errors (consent) |
| Your email and message | When you write to us | To answer you |
Usage statistics never include words, sentences, card labels, names, photos, recordings or file paths. You can turn statistics off at any time in the App's settings; the App then deletes the statistics it has not sent yet.
4. Service providers
We use these providers to run the service. They process data only on our instructions:
- Cloudflare, Inc. — delivery of language and voice downloads and hosting of this website.
- PostHog — usage statistics and error reports, stored in the European Union, only with your consent.
- Apple — App Store distribution and, if offered, purchases and subscriptions. Apple handles payments; we do not receive your payment details.
5. Children
Many people who use AAC are children. The App does not require an account and does not ask a child for personal information. A parent or other responsible adult decides whether to allow usage statistics. If you believe a child has sent us personal information, contact us and we will delete it.
6. Health-related information
Using an AAC app can suggest that a person has a condition that affects speech. For this reason we do not collect the content of communication, and usage statistics are not linked to a name or any other identity.
7. How long we keep data
- Technical request logs: [e.g. up to 30 days].
- Usage statistics and error reports: [e.g. up to 12 months].
- Emails: as long as needed to answer and follow up, then deleted.
8. Your rights
Depending on where you live (for example under the GDPR in the EU, the UK GDPR, PIPEDA in Canada or state laws in the United States), you may have the right to access, correct, delete or receive a copy of your data, to object to or restrict processing, and to withdraw consent at any time. Write to privacy@oasisaac.com. Because statistics are not linked to your identity, we may ask for the install identifier shown in the App to find them. You may also complain to your data protection authority.
9. International transfers
Our providers may process data outside your country. Where required, transfers are protected by appropriate safeguards such as the European Commission's standard contractual clauses.
10. Security
Downloads use encrypted connections (HTTPS) and are verified with checksums before they are installed. Data on the iPad is protected by iPadOS. No method of transmission or storage is completely secure, but we work to protect the information we handle.
11. Changes
We will update this policy when the App or the law changes and show the new effective date here. If a change is significant, we will tell you in the App.
12. Contact
[COMPANY NAME], [REGISTERED ADDRESS] — privacy@oasisaac.com