Privacy policy

In short

Owlbrush is made for children and collects no data about them. There is no account, no advertising, no analytics or tracking tools and no cookies. Coloured-in pictures, painting progress and settings stay on this iPad. Data only arises when the app loads the list of books or a book from our server, and when you buy a book through Apple. To load a bought book, the app sends Apple's purchase confirmation to our server once for checking; it is not stored.

1. Controller

Annico, owner: Annika Boewer
Siemensstr. 17, 12459 Berlin, Germany
Phone: +49 155 11499784
Email: info@annico.eu

2. What stays on the iPad

Coloured-in pictures and “My pictures”, the painting progress of every page, the last page read, loaded books and your settings (language, voice, volumes, calm mode) are stored on this device only. We do not receive this data. You can delete it in the grown-ups' area (“Reset all coloured pictures”, “Books on this iPad”) or by deleting the app. Depending on your device settings, pictures and settings may be part of your iCloud or device backup with Apple; loaded books are excluded from it.

3. Loading the list of books and the books

When it starts, the app asks for the current list of books. When your child or you want them, it loads books, covers and the music sounds from our server sl-cdn.annico.eu. For this, the server necessarily processes:

• the IP address of the device
• date and time of the request
• the file requested, status code and amount of data transferred
• identifier of the app and operating system (user agent)

The purpose is to deliver the books, to keep the server secure and to find errors. The legal basis is Art. 6 (1) (b) GDPR (providing the content you asked for) and Art. 6 (1) (f) GDPR (legitimate interest in a secure, working service). Our server writes no access logs: this information is only processed while the request lasts and is not stored. Only when a connection fails for technical reasons can the IP address appear in an error log, which is deleted after ten weeks at the latest. We do not analyse who loads which book and do not combine this data with any other data.

The server is operated by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany, which processes the data on our behalf (Art. 28 GDPR).

4. Buying books

Books are bought as in-app purchases in the App Store. Apple handles payment and the purchase under its own responsibility; Apple's privacy policy applies. We receive no payment or account data. The app checks on the device through Apple's StoreKit which books have been bought (also for “Restore purchases” and Family Sharing). Apple only gives us, as the provider, summarised sales figures without names.

Without a purchase the app only loads each book's free sample. To load a bought book in full, the app sends Apple's purchase confirmation for that book once to our server sl-api.annico.eu (also run by IONOS in Germany, see section 3). The purchase confirmation is a record signed by Apple with the app, the book, transaction numbers, purchase and signing date, price and currency, App Store country and technical check values from Apple; it contains no name, email address, Apple ID or payment data. The server only checks Apple's signature and whether the purchase belongs to this book and has not been refunded, and answers with a link to the book that is valid for one hour. The purchase confirmation is processed only for this check, while the request lasts, and is neither stored nor logged. Section 3 applies to the connection; to prevent abuse, the server counts requests per IP address for one minute in memory. The legal basis is Art. 6(1)(b) GDPR (providing the book you bought). If a book is loaded again, for example after deleting it or on another iPad, the check is repeated.

5. Microphone

For blowing exercises, the app can use the microphone once you allow it. It only measures how strongly your child blows, so that the paper boat moves, for example. Nothing is recorded, stored or transmitted. You can withdraw the permission at any time in the iPadOS settings; the exercises then work without the microphone.

6. Saving, sharing, printing

Only when your child or you tap it does the app save a picture to the Photos app (adding only, it never reads your photos), open the iPadOS share menu or print via AirPrint. You choose where a picture is shared to; the terms of the service you choose then apply. Nothing is sent to us.

7. Crash reports

If you have allowed sharing with app developers in the iPadOS settings under “Privacy & Security → Analytics & Improvements”, Apple provides us with crash and diagnostic reports that do not identify anyone. This is based on your consent to Apple and can be switched off there at any time.

8. Children

The app does not ask for names, dates of birth or contact details and has no chat or online features. Purchases, settings and links out of the app are behind a parental gate. We use no third-party advertising or analytics services.

9. Sharing data

We do not sell data and do not pass data on to third parties. Our processor IONOS is bound by contract to protect the data at least as well as this policy describes.

10. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on Art. 6 (1) (f) GDPR (Art. 21). An informal email to info@annico.eu is enough. Because we keep no user accounts, server logs can only be matched by IP address and time.

You can also complain to a data protection supervisory authority, for example the Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59–61, 10555 Berlin, Germany.

11. Changes

We update this policy when the app or the law changes. The version in the current app applies.