Политика конфиденциальности

1. What is this app

This app is an Augmentative and Alternative Communication (AAC) tool that helps people communicate using on‑screen buttons and assistive input methods. This Privacy Policy explains what information the app may collect, how it is used, and what choices you have.

2. What the app does

The app allows a user or their caregiver to compose text and have it spoken aloud. It supports:

• Direct use by the person with disabilities (for example, via assistive input such as eye or switch access).
• Caregiver‑assisted use, where a caregiver operates the device on the user’s behalf.

The text composed and spoken through the app is treated as the user’s own communication.

3. Data we collect

3.1 Data stored on your device

The app may store the following information locally on your device:

• App settings and preferences (such as language, voices, or accessibility options).
• Saved custom phrases and their order.
• Basic state needed to provide the app’s features.

This information is stored on your device and is typically included in your device backups if you have them enabled. You can remove this data by deleting the app or clearing app data from your device.

3.2 Usage and analytics data

To understand how the app is used and to improve it, we may collect limited usage information, such as:

• Events when buttons are pressed (for example, which type of button was used and whether it was pressed directly or via an assistive input method).
• Events when speech is triggered (including only the length of the spoken text, not the content).
• Events when a custom phrase is saved (including only the length of the phrase, not the content).
• Events indicating that a text suggestion was shown (not the suggestion content itself).
• General information about app configuration (for example, current app language or whether certain features are supported).

The app is designed so that the actual phrases and sentences you compose and speak are not included in analytics or usage logs.

3.3 Camera and assistive input data (including TrueDepth / Face ID hardware)

If you enable hands-free control, the app uses the device's TrueDepth API (on devices with Face ID hardware) to drive on-screen selection without touch input. It may also use external assistive switches.

The app does not collect, store, transmit, or share any face data.

• The TrueDepth API output is processed entirely on the device, frame by frame, only to derive two transient UI input signals: a binary indication of which side the eyes are pointed toward (used to advance the on-screen selection between adjacent buttons), and a binary indication of mouth open/closed state (used to activate the currently selected button).
• These signals exist only for the duration of each frame and are immediately discarded. The app does not retain them, write them to disk, include them in device backups, send them to our servers, or use them for any other purpose.
• The app does not collect, store, or transmit a face map, depth map, facial geometry, ARKit blendshape values, biometric identifiers, photographs, or video. It does not perform face recognition or any other form of user identification.
• No camera, depth, sensor, or face-derived data ever leaves the device. Nothing is shared with any third party, analytics provider, or server. Because nothing is retained, there is no retention period to describe.

You can turn this feature off at any time inside the app, or by revoking the camera permission in your device's iOS settings.

3.4 Text‑to‑speech

The app converts your text into spoken audio using the device’s text‑to‑speech capabilities. The text you enter is used only to generate speech and is not stored by us as part of analytics or profiling.

3.5 AI or suggestion features

If you enable text suggestion or similar features and your device is online, the app may send the current input context (for example, a small amount of recently typed text and the selected language) to a server in order to generate suggestions.

We aim to minimise personal data in these requests by:

• Sending only what is necessary to generate the suggestion.
• Avoiding direct identifiers where possible.

When offline, no suggestion requests are sent.

4. How we use your data

We use the information described above to:

• Provide the app’s core communication and accessibility features.
• Maintain and improve the app’s performance, reliability, and usability.
• Develop new features that support communication for people with disabilities.
• Detect, prevent, or address technical issues or misuse.

We do not use your data for behaviour‑based advertising. We do not sell your personal data.

5. Legal bases (where applicable)

Depending on your location, we may rely on one or more of the following legal bases:

• Your consent (for example, when you enable analytics, text suggestions, or camera‑based features).
• The need to provide the services you request (performance of a contract).
• Our legitimate interest in improving accessibility, quality, and security of the app.

You can withdraw your consent at any time by disabling the relevant feature or changing your device settings.

6. Data sharing

We may share data with service providers who help us provide analytics, error reporting, hosting, or other necessary services. These providers are only allowed to use the data to provide services to us and must protect it appropriately.

We do not share your personal data with advertisers or unrelated third parties. We may disclose information if required by law or to protect our legal rights.

7. Data retention

We keep data only for as long as necessary for the purposes described in this policy, including to:

• Provide and improve the app.
• Comply with legal obligations.
• Resolve disputes and enforce agreements.

Data stored on your device is kept until you delete the app or clear the app data. Server‑side logs and analytics may be retained for limited periods and then deleted or anonymised.

8. Your rights and choices

Depending on your location, you may have rights to:

• Access your personal data.
• Correct inaccurate data.
• Request deletion of your data.
• Restrict or object to certain processing.
• Receive a copy of your data in a portable format.

In practice, you can exercise many choices directly:

• Enable or disable camera‑based and other assistive input features.
• Enable or disable suggestion or AI features.
• Adjust app and device privacy settings, including analytics preferences where available.
• Delete the app to remove local data.

9. Security

We take reasonable technical and organisational measures to protect the information we process, including:

• Limiting the data we collect to what is necessary for the app to function.
• Using safeguards designed to protect data in transit and at rest.
• Restricting access to data to authorised personnel and service providers.

No system is perfectly secure, but we work to protect information against unauthorised access, alteration, or disclosure.

10. International transfers

Our service providers or servers may be located in countries other than your own. Where required by law, we take steps to ensure that appropriate safeguards are in place for international transfers of personal data.

11. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will change the “Last updated” date at the top of this page. If we make significant changes, we may also provide an in‑app notice.

If you continue to use the app after the updated policy takes effect, you agree to the updated terms. If you do not agree, you should stop using the app and uninstall it.