1. Introduction & Scope

Phonic Run Pty Ltd ("we", "our", "us", or "Phonic Run") builds foundational literacy software for early-childhood learners aged 3–8. This Privacy Policy explains how we handle information in connection with:

• The Phonic Run mobile application available on both Google Play (Android) and the Apple App Store (iOS), including the consumer Parent Tier and the professional Pro Tier (used by Speech-Language Pathologists and clinical educators);
• Our marketing website at phonicrun.com.au (including the pre-launch waitlist); and
• Any associated support channels (email, support portal).

Because our primary end-users are children, our architecture is built on a single non-negotiable principle: Zero Data Collection, Zero Behavioural Tracking, and Absolute Local Sovereignty. The Phonic Run app is engineered as an offline-first application using a local SQLite database. No child data, no voice telemetry, and no persistent personal identifiers are ever transmitted from the user's device to us or to any third party.

This single policy is written to satisfy, simultaneously, the Google Play Console Data Safety section and Families Policy; Apple's App Privacy ("Nutrition Label") disclosure requirements in App Store Connect; Apple's Kids Category guidelines (Guideline 1.3) and App Tracking Transparency (ATT) framework; and COPPA and the Australian Privacy Principles (APPs).

2. Information We Do Not Collect (Zero-Retention Framework)

To ensure full transparency for parents, educators, and app store reviewers on both platforms, we explicitly confirm the app does not collect, harvest, store, or transmit:

• Personally Identifiable Information (PII) about children — no legal names, phone numbers, home addresses, school names, dates of birth, or email addresses of minor users are ever requested by the app itself.
• Precise or approximate location data.
• Behavioural or biometric profiling — no keystroke logging, navigation-speed tracking, or cross-session behavioural profiling.
• Persistent voice recordings — see Section 5 for how optional speech-practice audio is handled.
• Advertising identifiers (Android Advertising ID / Apple's IDFA) — the app contains zero advertising SDKs, and therefore never requests App Tracking Transparency (ATT) authorisation, because it performs no tracking as defined by Apple.
• Analytics or crash-telemetry SDKs — zero instances of Google Analytics, Firebase Analytics, Meta/Facebook Pixels, Crashlytics, or any comparable cross-app tracking tool are bundled with the application.
• Contacts, calendar, camera roll, or device-file access beyond the app's own local sandboxed storage.
• Any data sold to, or shared with, data brokers or advertisers, under any circumstance.

3. Information Stored Locally on the Device (On-Device Sovereignty)

The only data generated by the app is operational progress metadata required to power the 10-phase learning roadmap. This data is created, stored, and processed entirely on the user's own device and is never transmitted off-device, regardless of whether the device runs Android or iOS:

• Local SQLite Database (phonics_app_storage.dart): Stores child/"Runner" profiles — a parent-chosen display nickname and avatar selection only (no requirement or field for a legal name) — along with mastery percentages, phase-completion states, quiz results, and saved reading activities ("Make Your Own Story" creations).
• Anonymised Clinical Rosters (Pro Tier): Speech-Language Pathologists and clinical educators using the Pro Tier are instructed to track clients via Unique Client ID Pseudonyms (e.g., AP-1049). No real client names should be entered into the system, and the app does not require or validate real names.
• Local App Settings (SharedPreferences): Includes onboarding-completion flags and — on platforms where enabled — daily reminder notification preferences (enabled/disabled state and preferred reminder time). No notification content or scheduling data is transmitted to any server; reminder messages are generated and scheduled entirely on-device using Android's and iOS's native local notification frameworks.
• Encrypted Manual Backups: Users may export a timestamped copy of their local SQLite database directly to their device's file system and re-import it later. These backup files are created and consumed entirely by the user; we have no access to, and never receive a copy of, these backup files.

Deleting the app, or using the in-app "Delete Child Profile" function, permanently and immediately erases this information from the device. Because no copy exists anywhere else, this constitutes complete and irreversible data deletion on both Android and iOS.

4. Device Permissions

The app requests the following device permissions. Each is scoped to a specific optional feature, is requested only when that feature is first used (via Android runtime permissions and iOS's usage-description prompts / notification authorisation), and can be declined without disabling core literacy lessons:

Permission	Why it is requested	Data leaves the device?
Microphone	Powers optional speech-articulation practice ("record your voice and play it back") in select lessons.	Never. Recordings are written to a volatile session cache and automatically, permanently deleted when the lesson session ends or the app closes.
Notifications	Only requested if a parent opts into optional daily practice reminders from the Parent Hub.	Never. Reminder text is generated locally and scheduled using the device's native notification system (Android's notification manager or iOS's UNUserNotificationCenter).
Internet access	Reserved for non-personal functions such as checking for app updates and, in the Pro Tier, optional peer-to-peer backup transfer initiated manually by the user. The core learning experience works fully offline.	No child data is transmitted through this permission under normal app operation.

All permission prompts include a clear, plain-language explanation of why the permission is being requested at the moment it is requested (contextual "just-in-time" consent), consistent with both Google Play's permissions best practices and Apple's Human Interface Guidelines for permission requests.

5. Microphone & Audio Data — Detailed Handling

• Audio recorded during optional speech-practice activities is held only in a volatile, in-memory/temporary session cache.
• Recordings are used exclusively for immediate playback to the parent/child pair within the same session.
• Recordings are never uploaded, transmitted, analysed by a remote server, or used to train any AI/ML model.
• Recordings are automatically deleted when the lesson or quiz session concludes, or when the app is backgrounded/closed — whichever occurs first.
• No persistent voice library, voiceprint, or biometric identifier is ever created or retained.
• Under Apple's App Privacy data-type taxonomy, this means "Audio Data" is Collected but Not Linked to the user's identity, and Not Used for Tracking. (See Section 17.)

6. Third-Party Services & Infrastructure

We minimise third-party exposure to the absolute operational minimum. None of the services below receive child usage data, lesson content, or in-app progress data:

• App Store Distribution (Apple App Store & Google Play): Purchase/installation transaction processing is handled entirely by Apple Inc. and Google LLC under their own respective privacy policies. Any in-app purchase on iOS is processed exclusively through Apple's StoreKit / In-App Purchase system.
• Payment Processing (Stripe): Used only for optional B2B/clinical web-checkout pathways (Pro Tier licensing) outside the app itself, under PCI-DSS Level 1 compliance. No child data is ever processed by Stripe.
• Web Hosting (Cloudflare Pages): Our marketing website and support pages are hosted on Cloudflare over standard HTTPS.
• Email Marketing for the Pre-Launch Waitlist (MailerLite): Our marketing website includes an optional, adult-facing waitlist sign-up form. This data is submitted directly by an adult visitor to MailerLite solely to send launch updates. This form is hosted only on our website — it is not present anywhere inside the mobile app, and no child ever interacts with it.
• Support Channels: Handled via low-touch, privacy-first channels (direct email / simple contact form).

We do not use any third-party advertising network, data broker, analytics SDK, or cross-app tracking tool inside the mobile application, on either platform.

7. How We Use Information

Because the app does not transmit personal information off-device, there is no server-side "use" of child data to describe. Locally, the limited data described in Section 3 is used exclusively to:

• Resume a child's progress across sessions on the same device;
• Power the adaptive 10-phase roadmap and mastery-tracking logic;
• Allow a parent/clinician to manually back up or transfer progress between their own devices.

Waitlist data submitted voluntarily by adults on our website is used exclusively to send pre-launch updates and respond to inquiries, and is never sold or shared with third parties for their own marketing purposes.

8. Data Sharing & Sale of Data

We do not sell, rent, trade, or otherwise share personal information or child data with any third party for monetary or other valuable consideration, under any circumstance. Because no child data is ever transmitted to our servers, no such data exists in our possession to share or sell in the first place. This applies identically regardless of which app store distributed the app to the user's device.

9. Data Retention & Deletion

• In-app data: Retained locally on the device for as long as the app remains installed, or until the parent deletes a specific child profile or uninstalls the app. Uninstalling the app on either Android or iOS removes the local database and all associated local data.
• Manual backups: Retained only on storage media the user personally controls (e.g., their own phone's file system or iCloud/Files app). We have no ability to access, list, or delete these files remotely, because we never receive them.
• Waitlist data (website only): Retained by MailerLite until the user unsubscribes or requests deletion by contacting us directly (see Section 13).

10. Your Rights & Choices

Under the Australian Privacy Principles and comparable international frameworks, individuals generally have rights to access, correct, and request deletion of their personal information. Because the app does not transmit personal data to us, these rights are already fully exercised by the user simply through:

• Access/Correction: Directly editing a Runner's nickname/avatar/progress within the app at any time.
• Deletion: Deleting a Runner profile in-app, or uninstalling the app entirely, which immediately and permanently erases all associated local data.
• Portability: Using the built-in encrypted backup/export tool to obtain a copy of a Runner's local data at any time.

For the website waitlist, any visitor may request access to, correction of, or deletion of their submitted contact details at any time by emailing us at the address in Section 13.

11. Children's Online Privacy — COPPA, APPs, Google Play Families Policy & Apple Kids Category Compliance

Phonic Run is designed from the ground up to be compliant with the U.S. Children's Online Privacy Protection Act (COPPA), the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), the Google Play Families Policy, and Apple's App Store Review Guideline 1.3 (Kids Category).

Because the app does not collect personal information from children under 13 (or any age), no "verifiable parental consent" collection mechanism is required for data-harvesting purposes, as no such harvesting occurs. Specifically:

• The app functions as an independent, closed-loop educational utility, controlled entirely by the parent or supervising clinician under a "side-by-side" co-regulation model.
• Any optional feature that could expose a child to an external destination is locked behind a Global Parental Gate (see Section 12), consistent with Apple's requirement that Kids Category apps not include links out of the app unless gated behind a parental mechanism.
• The app contains no social features, no chat, no user-generated content shared with other users, no external links reachable by a child without passing the Parental Gate, and no in-app purchases accessible without adult verification.
• The app includes no third-party advertising or behavioural/contextual ad networks of any kind, consistent with both the Families Policy and Apple's Kids Category prohibition on third-party advertising and analytics not specifically certified for children's apps.
• The app does not include any third-party analytics SDK — including those Apple otherwise permits under limited "kids category" exceptions — eliminating the need for such disclosures entirely.

12. Parental Controls & Safety Gates

• Global Parental Gate (AlphaPalsLayout): All external links, subscription/settings screens, and parent-dashboard transitions are locked behind an active adult-verification challenge.
• Zero-Touch Support Architecture: Support inquiries are routed through low-touch, privacy-first channels.
• No Autonomous Purchasing: Any subscription or purchase flow (processed via Apple's In-App Purchase system on iOS, or Google Play Billing on Android) is only reachable after the Parental Gate has been successfully passed by an adult.

13. Contact & Compliance Inquiries

If you have any questions, compliance inquiries, or requests regarding this Privacy Policy or our data handling practices — including parental requests to review, correct, or delete any information — you may contact us directly:

• Entity: Phonic Run Pty Ltd
• Jurisdiction: South Australia, Australia
• Email: phonicrun@gmail.com
• Web: phonicrun.com.au

We will respond to all legitimate privacy inquiries within a reasonable timeframe, consistent with the Australian Privacy Principles.

14. International Users & Data Transfers

Because no personal or child data is transmitted from the device to our servers, there is no cross-border transfer of child data to disclose. Our marketing website and waitlist form (which only collects data voluntarily submitted by adults) may be processed using infrastructure located outside your country of residence; those providers maintain their own compliance programs for international data handling.

15. Security Measures

• All locally stored app data remains within the operating system's sandboxed app storage, inaccessible to other apps under normal OS security models (Android application sandboxing and iOS Data Protection).
• Manual backup files can be optionally protected by the user via their own device/file-system security (including iCloud encryption).
• Because no child data is transmitted off-device, there is no server-side database of child information that could be subject to a remote data breach.
• Our website's waitlist form is transmitted over standard HTTPS/TLS encryption.

16. Google Play Data Safety — Explicit Declaration

For avoidance of doubt, consistent with the Google Play Data Safety declaration for this app:

• Data collected: None.
• Data shared with third parties: None.
• Data collected is encrypted in transit: Not applicable — no personal/child data leaves the device.
• Users can request data deletion: Yes — via in-app profile deletion or app uninstall.
• App contains ads: No.
• App uses an advertising ID: No.

17. Apple App Privacy ("Nutrition Label") — Explicit Mapping

For avoidance of doubt, consistent with Apple's App Privacy details required in App Store Connect, Phonic Run's data-collection practices map to Apple's standard data-type categories as follows:

Apple Data Type Category	Collected?	Linked to Identity?	Used for Tracking?
Contact Info	No	—	—
Health & Fitness	No	—	—
Financial Info	No (handled by Apple's StoreKit)	—	—
Location	No	—	—
Sensitive Info	No	—	—
Contacts	No	—	—
User Content (audio/voice)	Yes — temporary, on-device only	No	No
Browsing History	No	—	—
Search History	No	—	—
Identifiers (device/user/advertising ID)	No	—	—
Purchases	No (processed and retained solely by Apple)	—	—
Usage Data	No	—	—
Diagnostics	No	—	—
Other Data (local progress metadata)	Yes — stored only on-device, never transmitted	No	No

18. Apple App Tracking Transparency (ATT) & Kids Category Statement

• Phonic Run does not track users across apps or websites owned by other companies, as defined by Apple's App Tracking Transparency framework. Accordingly, the app does not display an ATT consent prompt, because it performs no tracking of any kind.
• Phonic Run contains no third-party advertising SDKs, no cross-app identifiers, and no device fingerprinting.
• As an app eligible for Apple's Kids Category, Phonic Run complies with Guideline 1.3 by: containing no third-party analytics or advertising, gating all external links and purchase flows behind the Global Parental Gate (Section 12), and collecting no personal information from children.

19. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect architectural improvements, new optional features, or regulatory changes on either platform. Any modification will be published on this page with an updated "Last Updated" date, and will be reflected in the App Privacy details / Data Safety sections of the respective app store listings where required. Material changes affecting children's data practices will be clearly flagged. Continued use of the application following any modification constitutes acceptance of the updated terms.

20. Governing Law

This Privacy Policy is governed by the laws of South Australia, Australia, without prejudice to any mandatory consumer or privacy protections you may be entitled to under the law of your own country of residence (including COPPA in the United States, and any equivalent protections applicable via the Apple App Store or Google Play Store in your region).