Isaac AAC Privacy Policy

1. Introduction

Isaac AAC, developed by HealNeo ("we," "our," or "us"), is committed to protecting your privacy. This Privacy Policy explains our data practices for the Isaac AAC mobile application ("App").

2. Information We Collect

2.1 Local Data Storage Only

The following data is stored exclusively on your device and is never transmitted to us:

User Profiles:

• Profile names and settings (no accounts required)
• Language preferences
• Accessibility settings
• App configuration preferences

Communication Content:

• Custom words and phrases you create
• Personal vocabulary and predictive text data
• Communication board layouts and customizations
• Any images or symbols you add

Photos:

• Any photos you add within the App are stored exclusively on your device
• We never upload, access, or have any ability to view your photos
• Photos are deleted permanently when you remove them in the App or uninstall the App

2.2 Optional Email Address (Newsletter)

2.3 Onboarding Data (App Improvement)

2.4 What We Do NOT Collect

2.5 External Services

• Core communication features (vocabulary, boards, settings, photos) operate entirely offline and locally on your device
• We use an email service provider to send newsletters to users who opt in
• We may use an analytics or survey service to process anonymous, aggregated onboarding answers
• No cloud storage or backup service is used for your communication content, settings, or photos

3. How We Use Your Information

3.1 Local Device Processing

Your communication content, settings, and photos remain on your device, and we do not "use" this information in the traditional sense:

• App Functionality: Data is processed locally to provide communication features
• Personalization: Settings and preferences customize your experience on your device
• Predictive Text: Word prediction algorithms run entirely on your device
• Profile Management: Multiple profiles are managed locally without external accounts

3.2 Use of Your Email Address

• If you provide it, we use your email address solely to send you our newsletter and occasional updates about Isaac AAC
• We do not use your email address for any other purpose, and do not combine it with your on-device communication content

3.3 Use of Onboarding Data

• Anonymous, aggregated onboarding answers are used only to help us understand overall usage patterns and improve App features
• This data is not used to identify individual users

3.4 No Other Data Analysis or Processing by HealNeo

• We do not analyze, access, or process your communication content, custom vocabulary, settings, or photos
• No behavior tracking beyond the anonymous onboarding answers described in Section 2.3
• No data mining or pattern analysis on your on-device content

4. Data Storage and Security

4.1 Local Device Storage

• Local Storage: Your communication content, custom vocabulary, settings, and photos are stored exclusively on your device
• No Cloud Storage: We do not offer or use cloud storage for this data
• Device-Dependent: This data exists only on your device and is deleted when you uninstall the App
• No Backups: We do not create backups of this data (users can use device backup features)

4.2 Server Storage (Email and Onboarding Data)

• Your email address (if provided) and anonymous onboarding answers are stored on servers operated by us or our service providers
• We apply reasonable technical and organizational measures to protect this data, such as access controls and encryption in transit
• No payment or financial information is ever stored by us

4.3 Security Through Isolation (Local Data)

5. Data Sharing and Disclosure

5.1 No Sharing of Your On-Device Content

We do not collect your communication content, custom vocabulary, settings, or photos, so we have nothing of that kind to share:

• No Data Collection: We cannot share what we do not collect
• No Third-Party Access: No third parties have access to your on-device data through us

5.2 Service Providers for Email and Onboarding Data

• Email Service Provider: If you provide your email address, we share it with the third-party platform we use to send newsletters
• Analytics/Survey Provider: Anonymous, aggregated onboarding answers may be processed by a third-party analytics or survey service on our behalf
• No Marketing Partners: We do not sell or share your email address or onboarding data with third parties for their own marketing purposes
• These providers are only permitted to process data on our behalf and in accordance with our instructions

5.3 App Store Payments Only

• Payment Processing: Apple App Store and Google Play Store handle all subscription payments
• No Payment Data Access: We do not receive or store any payment information
• Platform Privacy: Payment data is subject to Apple/Google privacy policies, not ours

6. Children's Privacy (Enhanced Protection)

6.1 Privacy-First Design

Isaac AAC's privacy-by-design approach provides strong protection for children:

6.2 Guidance for Parents

• Device-Only Storage for Content: All communication content and photos remain on the family device
• Supervise the Email Field: Parents should enter their own email address, not a child's, and can unsubscribe or request deletion at any time (see Section 8)
• Simple Data Management: Uninstalling the App removes all locally stored data permanently
• If we learn that a child under 13 (or the applicable age in your region) has provided an email address without parental consent, we will delete it upon request; contact us using the details in Section 13

7. International Data Transfers

8. Your Privacy Rights

8.1 Control Over Your Local Data

Since your communication content, vocabulary, settings, and photos are stored locally on your device, you have complete control:

• Access: All your data is directly accessible through the App
• Modification: Edit any settings or content directly in the App
• Deletion: Delete data through App settings or by uninstalling the App
• Portability: Your data stays with your device

8.2 Control Over Your Email Address and Onboarding Data

• Unsubscribe: Every newsletter email includes an unsubscribe link, or you can contact us directly
• Access, Correction, and Deletion: You may request access to, correction of, or deletion of your email address by contacting us (see Section 13)
• Withdraw Consent: You may withdraw your consent to receive the newsletter at any time; this does not affect the lawfulness of processing before withdrawal
• Onboarding Data: Because onboarding answers are anonymous and not linked to your identity, we cannot retrieve or delete an individual response, but no such response can be traced back to you

8.3 GDPR & CCPA Compliance

Our largely local-only approach limits the personal data we process to your optional email address. Where we process your email address, our legal basis is your consent, which you may withdraw at any time. You may also have rights under GDPR (e.g., access, rectification, erasure, restriction, objection, and complaint to a supervisory authority) or CCPA (e.g., to know, delete, and opt out of the sale/sharing of personal information — noting that we do not sell your data). Contact us using the details in Section 13 to exercise these rights.

9. Cookies and Tracking

9.1 No Tracking Within the App

Our email service provider may use standard tools (such as open/click tracking) to measure newsletter engagement for subscribers who provide an email address. This does not affect your on-device communication content.

10. Third-Party Services

10.1 Limited Third-Party Integration

Text-to-Speech Engines:

• May use device-native TTS services
• Voice synthesis data is not stored or analyzed by us

App Stores:

• Apple App Store and Google Play Store have separate privacy policies
• Payment processing handled entirely by app stores

11. Data Retention

12. Updates to Privacy Policy

• We may update this Privacy Policy periodically
• Material changes will be communicated through the App
• Continued use after changes indicates acceptance
• You can always access the current version at isaac.healneo.eu/privacy

13. Contact Information

14. Supported Languages and Regions

Isaac AAC supports the following languages and complies with privacy laws in these regions:

• 🇺🇸 English (United States, International)
• 🇸🇰 Slovenčina (Slovakia)
• 🇨🇿 Čeština (Czech Republic)
• 🇭🇺 Magyar (Hungary)
• 🇵🇱 Polski (Poland)

Our local-only data approach ensures compliance with privacy regulations including GDPR, COPPA, and local privacy laws in all supported regions.

15. Accessibility of This Policy

This Privacy Policy is available in multiple languages and accessible formats. Contact us if you need this policy in an alternative format.

📋 Summary for Users