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Cwtch Corner - Privacy Policy

Last updated January 22nd 2026

1. Introduction

Welcome to Cwtch Corner, developed by Cwtch & Code. We are committed to protecting the privacy of all users, especially children and vulnerable adults with additional support needs.

The app is designed to be a safe, supportive digital space. We comply with UK GDPR, the Children's Code (Age-Appropriate Design Code), and relevant data protection law.

2. Who We Are

  • Data Controller: Cwtch & Code
  • Developer: Carl Hendy
  • Contact: [email protected]
  • Location: United Kingdom
  • Data Protection Officer: Carl Hendy

3. Who This App Is For

Cwtch Corner is designed for:

  • Children of all ages
  • Vulnerable adults
  • Individuals with ALN, SEN, neurodivergent conditions, or learning disabilities
  • People who want a calm digital experience

There is no minimum age requirement. Parents, guardians, or carers must set up the administrator account and confirm they have parental responsibility or caring authority before creating user profiles.

4. What Data We Collect

Free Tier (local storage only)

  • User profiles (names, avatars, preferences)
  • Messages between profiles (encrypted)
  • Diary entries (encrypted)
  • App settings and theme choices
  • Approved YouTube channels (titles only, no thumbnails or watch history)
  • All data is stored locally on your device only

Premium Tier (cloud sync subscription)

  • Account email address (for sign-in)
  • Display name (optional, for Google Sign-In users)
  • All free-tier data (synced to secure cloud storage)
  • Subscription status (managed by Google Play or payment provider)

We do not collect location data, ad-tracking identifiers, browsing history, watch history, or profiling data.

5. How We Use Your Data

We use data only to provide core app features, enable premium cloud sync, manage authentication/subscriptions, and protect app security.

We do not use data for advertising, marketing, behavioral profiling, or non-essential third-party sharing.

6. Data Storage & Security

Free Tier

  • Data remains on your device
  • Messages and diary entries use AES-256 encryption
  • No cloud transfer

Premium Tier

  • Cloud data stored in Firebase Firestore (EU region)
  • Encrypted in transit (HTTPS/TLS)
  • Sensitive content encrypted before storage
  • Access protected by Firebase Authentication

Security measures include admin PIN controls, encrypted sensitive content, secure sign-in, and regular security updates.

7. Third-Party Services

  • Firebase (Google): authentication and cloud storage for premium users
  • Google Sign-In: optional sign-in method
  • Google Play Billing: subscription payment processing
  • Google Fonts: visual display only
  • YouTube API: approved channel metadata only (no watch tracking)

We do not use ad networks, marketing trackers, social integrations, or profiling analytics.

8. Your Rights (GDPR)

You and your child have rights to access, download, correct, delete, and transfer personal data, and to withdraw consent or object to processing where applicable.

For premium users, deletion removes both local and cloud data. To exercise rights, use in-app privacy tools or email [email protected].

9. Parental Rights & Controls

  • Full admin account access with PIN protection
  • Create, edit, and delete user profiles
  • Control approved YouTube channels
  • Access messages and diary entries
  • Delete account data
  • Request data on behalf of children

By creating an admin account, you confirm parental responsibility or caring authority.

10. Children's Code Compliance

Cwtch Corner follows UK Age-Appropriate Design Code principles: privacy by default, no profiling, no location tracking, no advertising, data minimization, encryption, and clear language.

11. Data Retention

  • Free tier: data remains on your device until deleted or app uninstall
  • Premium active account: data retained while account/subscription is active
  • Account deletion: local and cloud data removed immediately and permanently
  • Inactive premium accounts: data may be removed after extended inactivity where legally required

12. Data Sharing

We do not sell, rent, or share personal data with third parties. Data is shared only when required by law, when you explicitly request it, or when service providers process it under strict contracts for core app functionality.

13. Cookies & Tracking

We do not use marketing cookies, advertising cookies, tracking pixels, or analytics cookies. We use only functional local storage and essential authentication tokens for app operation.

14. Changes to This Policy

We may update this policy for legal, product, or feedback reasons. Material changes are reflected by updating the "Last updated" date and, where significant, notifying users in-app.

15. Contact Us

  • Email: [email protected]
  • Developer: Carl Hendy (Cwtch & Code)
  • Location: United Kingdom
  • ICO website: https://ico.org.uk
  • ICO helpline: 0303 123 1113

16. Summary

  • Your data is encrypted and secured.
  • Free-tier user data remains on-device.
  • Premium users can opt into EU-hosted cloud sync.
  • No advertising, tracking, or behavioral profiling.
  • Strong parental controls and transparency.
  • Designed for safety, comfort, and trust.

Thank you for trusting Cwtch & Code with your family's digital wellbeing.