Privacy Policy for iDraw for Kids

1. Who we are

This Privacy Policy describes how Qualisure Software Solutions, LLC (“we,” “us,” or “our”) handles information in connection with the iDraw for Kids mobile application (the “App”). The App is a children’s educational drawing and tracing experience intended for young artists, typically ages 2–7, and is designed for distribution in Apple’s Kids category on the App Store.

Operator: Qualisure Software Solutions, LLC

2. Scope

This Policy applies only to the App and to parent-facing pages for the App hosted under qualisuress.com (such as this Privacy Policy and the Terms of Use). It does not cover Apple’s platforms or unrelated Qualisure Software Solutions, LLC properties unless those properties specifically adopt this Policy.

3. Children’s privacy (COPPA and App Store Kids category)

We designed the App for children and for parents or guardians who set it up for a child. In line with the U.S. Children’s Online Privacy Protection Act (COPPA), Apple’s App Store Kids category rules, and related guidance:

• We do not knowingly collect personal information from children through the App.
• The App does not create accounts, profiles tied to real names, or sign-in flows that ask for email, phone number, address, or payment details.
• The App does not include third-party advertising, behavioral advertising, or targeted ads.
• The App does not use third-party analytics, crash-reporting, or advertising SDKs that track children across apps or websites.
• The App does not include social features, chat, public sharing, forums, or friend finders.
• The App does not request access to the device microphone for recording, camera, photo library, contacts, location, or tracking identifiers for advertising purposes.
• Purchase flows and legal documents (Privacy Policy, Terms of Use, and Apple’s subscription interfaces) are intended for an adult and are reached behind a parental gate in the App.

A parent or guardian is expected to complete the initial age-band setup (for example, “2–3 years,” “4–5 years,” or “6–7 years”). That selection is stored only on the device and is used only to configure the learning experience—not to identify a child online.

If you believe a child has provided personal information to us outside the App (for example, by emailing us), please contact us and we will promptly delete it from our systems to the extent it is in our control.

4. Information the App stores on the device

The App is intended to operate offline with respect to your drawings and progress. To function, it stores limited data locally on the device using standard operating-system storage (such as app preferences and application support files). This includes, for example:

• Setup preferences — age band chosen by a parent or guardian, whether setup is complete, drawing input mode (finger or Apple Pencil), and mute preference.
• In-app play progress — selected on-device character/avatar, earned wearable items and unlocks, module completion and stars, chosen scene, and similar game progress.
• Drawings — vector stroke data for traces the child creates, stored as local files so rewards and accessories can show the child’s own art.
• Purchase-related status — local flags or StoreKit receipts/entitlement state used only on the device to unlock paid features after a successful Apple transaction (we do not receive payment card numbers).

This on-device information is not uploaded to Qualisure Software Solutions, LLC by the App. It remains on the device unless you delete the App, clear the App’s data, use any in-app reset feature, erase the device, or transfer the device without wiping it.

The App does not ask for the child’s real name, school, photo, government ID, exact date of birth, address, email, phone number, or precise location.

5. Information we do not collect through the App

Based on how the App is built, Qualisure Software Solutions, LLC does not, through the App:

• Require registration or an account with us
• Collect contact information, payment card information, or government identifiers
• Transmit drawings, progress, or preferences to our servers
• Use cookies or similar web tracking technologies inside the App for advertising or cross-site tracking
• Share personal information with third parties for their marketing
• Sell personal information
• Request permission to track across apps and websites for advertising (App Tracking Transparency advertising tracking)

Purchase billing is handled by Apple, not by a Qualisure payment form. See Section 8.

6. Audio and device features

The App plays coaching audio using bundled sound clips and, when a clip is unavailable, may use on-device text-to-speech provided by the operating system. Playback uses the device’s audio session so spoken instructions can be heard. The App does not record the child’s voice or continuous ambient audio for transmission to us.

Drawing uses touch and, optionally, Apple Pencil input as configured on the device. Stroke input is processed on-device to score tracing and save drawings locally.

7. Internet, Apple, and device-level processing

The App’s core drawing, progress, reward, and coaching features run on the device and do not send that content to Qualisure Software Solutions, LLC.

When a parent purchases, restores, or manages a subscription, the App uses Apple’s StoreKit / In-App Purchase system. That communication is between the device and Apple. Qualisure Software Solutions, LLC does not operate a payment server for the App and does not receive or store payment card numbers, bank account numbers, or Apple ID passwords.

Independently of the App’s own play features, Apple and your device may process limited technical and transaction information under Apple’s policies when you download or update the App from the App Store, complete an in-app purchase or free trial, restore purchases, use Family Sharing or Ask to Buy, use device backups (including iCloud Backup if enabled by the device owner), use system diagnostic or crash facilities, use parental controls (Screen Time and related tools), or use other Apple platform features. That processing is governed by Apple’s terms and privacy policy, not by this Policy, and is controlled by Apple and by settings on the device that you or a parent or guardian manage.

If future versions of the App introduce features that cause Qualisure Software Solutions, LLC to collect personal information from children online (for example optional cloud backup of drawings to our systems, accounts, or third-party analytics), we will update this Policy before such collection begins and will design that collection to comply with applicable law, including parental notice and consent requirements where required. The App’s existing Apple-processed subscription is described in this Policy now and does not wait on that future commitment.

8. Purchases and subscriptions

The App may offer paid access through Apple In-App Purchase, including an auto-renewing monthly subscription that may include a free trial period where offered in the App Store product configuration. Exact price, trial length, and renewal terms are shown by Apple in the purchase confirmation before an adult completes a purchase.

• Who pays: Purchases are intended for parents or other adults. In the App, purchase actions are protected by a parental gate so a young child cannot complete a transaction alone.
• Who processes payment: Apple processes all payments. We never receive or store credit card, debit card, bank, or Apple ID credentials through the App.
• What we store: The App may store on the device only what is needed to recognize an active entitlement (for example that a subscription is active after verification with Apple). Transaction ledgers and billing history live with Apple / on the purchaser’s Apple ID account, not on Qualisure servers.
• What is not collected by us: We do not receive a child’s personal information as part of the payment flow.
• Management and cancellation: You can view, change, or cancel the subscription through Apple’s subscription settings on the device or Apple ID account (commonly: Settings → [your name] → Subscriptions, or the App Store account subscriptions page). Cancellation stops renewal after the current paid or trial period ends, subject to Apple’s rules.
• Restore: “Restore Purchases” (or equivalent) re-checks entitlement with Apple on the device after reinstall or a new device signed into the same Apple ID.
• Family Sharing: If enabled for the product in App Store Connect and by the organising family’s settings, subscription access may be shareable with eligible family members under Apple’s Family Sharing rules. Family Sharing is governed by Apple; we do not operate family member lists or age data for that feature.

Billing disputes, refunds, and invoice copies are handled through Apple’s App Store support and purchase history tools. Legal terms for use of the paid App appear in the Terms of Use: https://qualisuress.com/idraw-for-kids/terms.

9. How local data is used

On-device data is used only to:

• Provide tracing lessons, match games, coaching audio, and rewards
• Remember preferences such as mute and pencil vs. finger drawing
• Remember progress so a child can continue where they left off
• Support parent-facing setup, parental gates, and any in-app reset of the profile on that device
• Recognise subscription / free-trial entitlement status from Apple so paid features unlock correctly

10. Sharing of information

Because the App does not collect personal information from children on our servers, we do not sell, rent, or share child app content or play data with third parties for advertising or analytics of children.

Apple processes purchase and App Store data under Apple’s policies. We do not receive a stream of child behavioural data from Apple for advertising.

We may receive information if you contact us by email (for example a parent emailing with a support question). In that case we use the information only to respond and to operate our business relationship with you, and we do not use parent emails to market to children.

We may disclose information if required by law, regulation, legal process, or governmental request, or to protect the rights, safety, and property of Qualisure Software Solutions, LLC, users, or others.

11. Data retention and deletion

Local App data remains on the device until you delete the App, clear the App’s data through device settings, use any in-app reset that removes the local profile and drawings, or erase the device. Uninstalling the App typically removes the App’s local sandboxed data, subject to how the operating system and any device backups work.

Subscription billing records are retained by Apple according to Apple’s practices. Cancelling a subscription or deleting the App does not automatically erase Apple’s purchase history.

If you contact us with personal information in an email, we keep that correspondence only as long as needed for support, legal, security, or business record purposes, then delete or de-identify it when those purposes no longer apply.

12. Security

On-device data is stored within the App’s sandbox on iOS/iPadOS and is protected by the security features of the device and operating system (such as device passcode, biometric unlock, and platform sandboxing). No method of electronic storage is 100% secure. Parents and guardians should keep the device updated and use appropriate parental controls and device security settings.

13. International users; GDPR / UK GDPR; CCPA / CPRA

Qualisure Software Solutions, LLC is based in the United States. If you use the App from another country, play data and drawings still store locally on the device under this design. Any information you choose to send us by email may be processed in the United States.

European Economic Area, United Kingdom, and similar regimes. The App is not designed to transfer children’s personal data from the App to our servers. Where EU or UK data protection law applies to limited parent correspondence we receive by email, we process that information to respond to your request and to meet legal obligations (legitimate interests / contract / legal obligation as applicable). We do not sell personal data. You may have rights to access, correct, delete, restrict, or object to certain processing, and to lodge a complaint with a supervisory authority. Contact us using Section 17 to exercise rights over information we actually hold (typically email you sent us). For Apple-held purchase data, use Apple’s privacy tools and support.

California and similar U.S. state laws (including CCPA / CPRA). We do not sell or share personal information for cross-context behavioural advertising. We do not collect personal information from children through the App for our business records. California residents may request disclosure or deletion of personal information we maintain about them (for example parent support emails). Contact us using Section 17. We will not discriminate against you for exercising privacy rights.

14. Your choices and parental controls

• Do not install the App if you do not agree with this Policy.
• Use Apple Family Sharing, Screen Time, Ask to Buy, and other parental controls to manage what children can install and purchase.
• Change mute, age band (if re-setup is available), and input preferences in the App or by resetting/reinstalling as applicable.
• Manage or cancel subscriptions in Apple’s subscription settings; restore purchases after reinstall as needed.
• Delete the App to remove its local data from the device (subject to backups).
• Contact us to request deletion of any personal information you may have emailed to us.

15. Parent-facing links and third-party interfaces

The App does not open external marketing websites or social networks for children as a play feature. Adults may, after a parental gate, open:

• This Privacy Policy (hosted by Qualisure Software Solutions, LLC)
• The Terms of Use for iDraw for Kids (hosted by Qualisure Software Solutions, LLC)
• Apple’s system purchase, subscription management, offer-code / redemption, and related App Store sheets (operated by Apple)

Those destinations are for adults managing the App, purchases, or legal documents. Content on Apple-operated sheets is governed by Apple, not by this Policy.

16. Changes to this Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above and post the updated Policy at this URL. If we make material changes that introduce collection of personal information from children online by us, we will take additional steps required by law, which may include obtaining verifiable parental consent before such collection begins.

17. Contact us

For privacy questions, parental requests (including deletion or access requests), or concerns about iDraw for Kids:

Privacy Policy URL for the App:
https://qualisuress.com/idraw-for-kids/privacy

Terms of Use URL for the App:
https://qualisuress.com/idraw-for-kids/terms

18. Summary for App Store nutrition labels

For Apple App Privacy disclosures, the current App design supports the following high-level statements (confirm against the shipping binary when submitting):

• Data Not Collected from the App by Qualisure Software Solutions, LLC for our analytics, advertising, or product personalization networks
• No Account Created with Qualisure Software Solutions, LLC
• No Third-Party Advertising
• No Linked Data to a child’s identity via our servers
• Data Used to Track You: not used for advertising tracking by us
• Purchases: handled by Apple In-App Purchase; we do not collect payment info

On-device drawings and progress are stored only for App functionality on that device and are not collected by us through the App. Apple’s handling of App Store and payment data is disclosed under Apple’s labels and Apple’s privacy policy.