Privacy

PRIVACY NOTICE

This Privacy Notice for TinyLearners LLC (“we,” “us,” or “our”), describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

Download and use our mobile application (TinyTrace), or any other application of ours that links to this Privacy Notice
Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at tinylearners@mvpkit.dev.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? TinyTrace is designed with privacy as a core principle. We do not collect, use, or disclose any personal information from users. All data is stored locally on your device. Learn more.
Do we process any sensitive personal information? We do not process sensitive personal information. Learn more.
Do we collect any information from third parties? We do not collect any information from third parties. Learn more.
How do we process your information? We do not process personal information as all data remains on your device. The only exception is optional iCloud sync, which uses Apple’s CloudKit service and stores data in your personal iCloud account, not on our servers. Learn more.
In what situations and with which parties do we share personal information? We do not share personal information with any third parties. Learn more.
How do we keep your information safe? Since we do not collect or store personal information on our servers, your data is protected by your device’s security features. iCloud data is protected by Apple’s security measures. Learn more.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more.
How do you exercise your rights? The easiest way to exercise your rights is by contacting us at tinylearners@mvpkit.dev. Learn more.

WHAT INFORMATION DO WE COLLECT?
HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We do not collect personal information that you provide to us.

TinyTrace is designed with privacy as a core principle. We do not collect personal information that you voluntarily provide to us. The app operates entirely offline and does not include any forms, registration, or data submission features.

Sensitive Information

We do not process sensitive information.

Application Data

In Short: We do not automatically collect device information or application data.

TinyTrace does not automatically collect:

Mobile Device Data (device ID, model, manufacturer, operating system, IP address)
Device and application identification numbers
Browser type and version
Internet service provider or mobile carrier information
Phone network information
Unique device IDs
Application usage analytics

Push Notifications

TinyTrace does not send push notifications and does not request permission to send them.

Local Data Storage

TinyTrace stores the following data only on your device using local storage (UserDefaults):

Progress Data: Lesson completion status, practice scores, and learning progress
Settings: App preferences such as difficulty level, audio settings, and hint preferences
Pencil Habit Data: Apple Pencil grip and posture metrics (when enabled by parents)

This data:

Never leaves your device (unless you enable iCloud sync)
Is not transmitted to our servers (we have none)
Is not accessible to us or any third parties
Can be deleted at any time through the app’s reset function

iCloud Sync (Optional)

If you are signed into an iCloud account on your device, TinyTrace may automatically sync progress data to your personal iCloud account using Apple’s CloudKit service. This enables:

Cross-Device Sync: Progress syncs automatically between your iPad devices signed into the same iCloud account
Backup: Progress is backed up to your iCloud account and can be restored if you reinstall the app

What Gets Synced:

Lesson completion status and step progress
Practice scores and learning progress for letters, numbers, and shapes
Glyph mastery levels and rolling averages

What Does NOT Get Synced:

App settings (difficulty level, hints, haptics)
Pencil habit metrics

iCloud Privacy:

Your Data, Your Cloud: Synced data is stored in your personal iCloud account, not on our servers
End-to-End Encryption: Data is encrypted in transit and at rest using Apple’s iCloud security
No Access by TinyTrace: We cannot access, read, or view any data stored in your iCloud account
Controlled by Apple: iCloud data is subject to Apple’s Privacy Policy and your iCloud settings

Disabling iCloud Sync: To disable iCloud sync, go to your device’s Settings app → Apple ID → iCloud → find TinyTrace and toggle it off. When disabled, progress will only be stored locally on each device.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We do not process personal information as all data remains on your device. The only exception is optional iCloud sync, which uses Apple’s CloudKit service and stores data in your personal iCloud account, not on our servers.

Since TinyTrace does not collect personal information, we do not process personal information for the purposes typically listed in privacy notices, such as:

Providing services (data remains on your device)
Requesting feedback (we do not collect feedback)
Sending marketing communications (we do not send communications)
Identifying usage trends (we do not collect usage data)
Saving or protecting vital interests (we do not have access to data that would enable this)

The only data processing that occurs is:

Local Processing: All app functionality processes data locally on your device
iCloud Sync: If enabled, progress data is synced to your personal iCloud account via Apple’s CloudKit service. This sync is handled entirely by Apple, and we have no access to this data.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

Since TinyTrace does not collect or process personal information, we do not rely on legal bases for processing personal information. All data remains on your device and is processed locally.

If you are located in the EU or UK, and if any personal information were to be processed in the future, we would rely on the following legal bases:

Consent: We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests.
Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations.
Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada, and if any personal information were to be processed in the future, we would process your information only with your express or implied consent, except in exceptional cases permitted by law.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We do not share personal information with any third parties.

TinyTrace does not share personal information with any third parties because we do not collect personal information.

The only external service used is Apple’s iCloud/CloudKit for optional sync functionality. When you enable iCloud sync:

Data is synced directly to your personal iCloud account
We do not have access to this data
Apple handles all data processing and storage according to their Privacy Policy

We do not share information in the following situations:

Business Transfers: We do not have personal information to transfer
Affiliates: We do not share information with affiliates
Business Partners: We do not share information with business partners
Offer Walls: Our application does not display offer walls or third-party advertisements

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: TinyTrace may use machine learning technologies for educational purposes, but these operate entirely on your device and do not process personal information.

TinyTrace may use machine learning and artificial intelligence technologies (collectively, “AI Products”) for the following functions:

Glyph Scoring: Core ML models may be used to evaluate handwriting quality and provide scoring feedback
Pencil Habit Analysis: Analysis of Apple Pencil usage patterns to provide coaching feedback

How We Process Your Data Using AI:

All AI processing occurs locally on your device
No data is sent to external AI services or servers
No personal information is processed by AI systems
AI models analyze only the strokes you draw within the app
Results are stored locally and never transmitted

If Apple Intelligence features are available and enabled, they operate according to Apple’s privacy policies and on-device processing standards.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We do not transfer personal information internationally because we do not collect personal information.

Since TinyTrace does not collect personal information, we do not transfer personal information internationally.

If you enable iCloud sync, your data may be stored in Apple’s iCloud servers, which may be located in countries other than your own. This transfer is handled entirely by Apple according to their Privacy Policy and data transfer agreements. We have no control over or access to this data.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We do not keep personal information because we do not collect it.

Since TinyTrace does not collect personal information, we do not retain personal information.

Data stored locally on your device remains on your device until you:

Delete it through the app’s reset function
Delete the app from your device

If you have enabled iCloud sync, your data is retained according to Apple’s iCloud data retention policies. You can delete this data at any time by disabling iCloud sync or deleting the app.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: Since we do not collect or store personal information on our servers, your data is protected by your device’s security features. iCloud data is protected by Apple’s security measures.

Since TinyTrace does not collect or store personal information on our servers, there are no server-side security measures needed. Your data is protected by:

Device Security: Your device’s built-in security features (encryption, passcodes, biometric authentication)
Local Storage: Data stored locally using iOS UserDefaults, which is protected by iOS security
No Network Transmission: Since we don’t transmit data to our servers, there’s no risk of interception during transmission

If you enable iCloud sync, your data is protected by Apple’s security measures:

End-to-end encryption for data in transit
Encryption at rest
Apple’s security infrastructure and compliance certifications

However, please note that no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. While we don’t collect data that could be compromised, you should always use secure practices with your device and iCloud account.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right:

(i) to request access and obtain a copy of your personal information
(ii) to request rectification or erasure
(iii) to restrict the processing of your personal information
(iv) if applicable, to data portability
(v) not to be subject to automated decision-making

Since TinyTrace does not collect personal information, there is no personal information for us to provide, correct, or delete. However, you can:

Delete all local app data through the app’s reset function
Delete the app from your device
Disable iCloud sync if you have it enabled

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

If you have questions or comments about your privacy rights, you may email us at tinylearners@mvpkit.dev.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. However, since TinyTrace does not track users or collect browsing data, DNT settings are not applicable to our app.

If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time. However, since we do not track users, this is not applicable to TinyTrace.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. Since TinyTrace does not collect personal information, all categories show “NO”.

Category	Examples	Collected
A. Identifiers	Contact details, real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	NO
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	NO
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation data	Device location	NO
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details, job title, work history, and professional qualifications	NO
J. Education Information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about an individual’s preferences and characteristics	NO
L. Sensitive personal Information	N/A	NO

Sources of Personal Information

We do not collect personal information from any sources.

How We Use and Share Personal Information

We do not use or share personal information because we do not collect it.

Will your information be shared with anyone else?

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, since we do not collect personal information, these rights are not applicable. These rights include:

Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling

You can delete all local app data through the app’s reset function or by deleting the app from your device.

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at tinylearners@mvpkit.dev, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Since we do not collect personal information, we cannot verify your identity against stored information. If you contact us, we will respond to confirm that we do not have any personal information to provide.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at tinylearners@mvpkit.dev. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. Since we do not collect or share personal information, we have no such information to disclose. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last Updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email at:

Email: tinylearners@mvpkit.dev

Company: TinyLearners LLC

Address: California, USA

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Since TinyTrace does not collect personal information, there is no personal information for us to review, update, or delete. However, you can:

Delete all local app data through the app’s reset function (Parent Dashboard → Settings → Reset Data)
Delete the app from your device
Disable iCloud sync if you have it enabled (Settings → Apple ID → iCloud → TinyTrace)

To request to review, update, or delete your personal information, please contact us at tinylearners@mvpkit.dev.

Children’s Privacy (COPPA Compliance)

TinyTrace is designed for children under 13 years of age. We are committed to complying with the Children’s Online Privacy Protection Act (COPPA) and all applicable laws regarding children’s privacy. We do not collect, use, or disclose any personal information from children.

TinyTrace is designed with privacy as a core principle. We believe children’s educational apps should not collect data, and we’ve built our app to prove that exceptional learning experiences don’t require surveillance.