Privacy Policy

1. How Your Data Is Stored & Synced

Data kept on-device or in your iCloud account only

• Imported documents, reading progress, vocabulary lists, flashcards
• Study statistics, preferences, app settings
• Curated content access history and bookmarks
• App-usage monitoring tokens (session durations, feature usage)

Backup & sync

• Bamboo Reader uses Apple CloudKit to store data in your private iCloud container
• We never receive or hold a server-side copy of your personal content
• Imported documents are stored locally and in your iCloud for sync across your devices

Local export (current and future)

• You may generate vocabulary lists, progress reports, or study materials that stay local unless you share them via iOS share-sheet
• Export functionality is provided for your convenience; you control all sharing

2. What We Do NOT Collect

• No server-side copies of your imported documents or personal study content
• No behavioral profiling for advertising or data resale
• No social-media tracking SDKs or third-party advertising networks
• No analysis of your imported content for commercial purposes
• Any future cloud features will be strictly opt-in with clear disclosure

3. Diagnostics & Analytics

Apple-supplied (always on)

• Crash reports & basic install metrics handled by Apple App Store infrastructure

Optional third-party analytics (future)

• Tools like Firebase Analytics or similar will be OFF by default
• You will see clear toggles in Settings → Privacy and must give explicit opt-in consent
• Where data are fully anonymized, we may rely on "legitimate interest" (GDPR Art 6(1)(f)) to process minimal crash data for app stability
• Learning analytics (if introduced) will be aggregated and anonymized, focusing on feature usage patterns rather than content

4. Imported Content & Document Processing

User-Imported Content

• Documents you import are processed locally on your device for dictionary lookup and learning features
• We do not analyze, copy, or transmit your imported content to our servers
• Content processing (text extraction, word segmentation) happens entirely on-device
• You retain full ownership and control of all imported materials

Curated Content

• We provide educational content that we own or license for language learning
• Usage of curated content is tracked for licensing compliance and feature improvement
• This tracking is aggregated and does not identify individual users

5. Why & Under What Legal Basis We Process Data

6. Data Security & Access

• All data encrypted in transit & at rest by Apple's infrastructure
• Optional Face ID / Touch ID lock protects local app data
• Imported documents are subject to your device's security settings
• Fuyu Labs LLC accesses data only when you explicitly request technical support and grant permission

6A. Data-Breach Notifications

In the unlikely event of a security incident affecting personal data confidentiality, integrity, or availability, we will notify affected users and—when required—regulators within:

• 72 hours (GDPR requirements)
• 30 days (California CPRA requirements)
• Other jurisdictions as legally required

7. Third-Party Services & Content

Currently Integrated:

• Apple CloudKit, FamilyControls (if applicable), App Store Payments
• Apple's on-device text processing and language APIs

Curated Content Sources:

• Educational content from licensed providers (when applicable)
• Public domain materials appropriately attributed
• User-generated content policies available upon request

Not Integrated:

• No advertising networks, data brokers, or social media SDKs
• No content analysis or text mining services
• No marketing analytics or user behavior tracking

8. Your Privacy Rights & Controls

• View, edit, delete, or export your study data at any time within the app
• Control iCloud sync in iOS Settings → Apple ID → iCloud → Bamboo Reader
• Request complete data deletion by emailing synclively@gmail.com
• Manage curated content access and download preferences in app settings

9. Data Retention & Deletion

• Personal study data remain in your iCloud until you delete them
• Imported documents are retained according to your device storage settings
• Deleting Bamboo Reader removes local data; follow Apple's steps to remove iCloud backups
• We retain zero server-side copies of personal content after app deletion
• Aggregated, anonymous analytics may be retained for service improvement

10. Children's Privacy & Age Verification

Bamboo Reader is intended for users 13 years or older. Upon first launch, users must confirm their age through a neutral verification ("I am 13 or older / I am under 13").

If "under 13" is selected, the app will not collect any personal information and will restrict functionality accordingly.

For users aged 13-16 in jurisdictions requiring parental consent, Bamboo Reader does not "sell or share" personal data under CPRA or GDPR definitions. Optional analytics features (if introduced) will require parental approval through Apple's Family Sharing system.

11. International Data Transfers

Your iCloud data may be stored in Apple data centers worldwide under Apple's international transfer mechanisms (Standard Contractual Clauses, Binding Corporate Rules, or adequacy decisions).

For any future server-side features, we will implement appropriate safeguards including Standard Contractual Clauses or adequacy decisions for international transfers.

12. Educational Use & Content Responsibility

Educational Purpose Disclaimer

• Bamboo Reader is designed as an educational language learning tool
• We do not guarantee language proficiency outcomes or educational results
• Dictionary definitions and translations are provided for reference and may contain errors

User Content Responsibility

• Users are solely responsible for ensuring they have appropriate rights to import and use content
• We do not monitor, review, or validate user-imported content for copyright compliance
• Educational fair use is the user's responsibility to determine and maintain

13. Contact Information

Fuyu Labs LLC

Primary Contact: synclively@gmail.com

General Support: synclively@gmail.com

Response Time: We aim to respond to privacy inquiries within 30 days for simple matters, up to 90 days for complex requests involving technical analysis or legal review.

14. Regional Privacy Rights

EU/EEA/UK Residents – Rights include access, rectification, erasure, data portability, processing restriction, objection, and automated decision-making protection under GDPR.

California Residents – Rights under CPRA include access, deletion, correction, portability, and opt-out of sales/sharing (though we do not sell or share personal information).

Canada & Australia – Analogous statutory privacy rights under PIPEDA and Privacy Act respectively.

EU GDPR Article 27 Representative

Upon official EU launch: synclively@gmail.com

15. CPRA 'Do Not Sell or Share' Disclosure

Current Status: Bamboo Reader does not sell or share personal information as defined by the California Consumer Privacy Act (CPRA).

Future Changes: If this practice ever changes, we will provide 30 days advance notice to California residents and add a "Do Not Sell or Share My Personal Information" toggle in app Settings.