Privacy Policy for SpinFable

Effective Date: Sep 6, 2025

SpinFable (the “App”) is operated by Eugenio Keller Puente (sole proprietor, Spain). I value your privacy and designed this App to minimize data collection. This Privacy Policy explains what data is processed, how it’s used, where it’s stored, and your rights under applicable laws (including GDPR).

1. Who is the Data Controller?

Data Controller: Eugenio Keller Puente (Autónomo, Spain).
Contact: contact@kubographics.com
Product Site: www.kubographics.com/spinfable.html

2. What Information the App Handles

SpinFable is a children’s story generator. The App itself provides the story elements (character names, settings, values/themes, images, and narration/voice). You do not need to input personal data.

• Story & Asset Data (Local): Stories, generated images, and narration audio created within the App are stored locally on your device.
• Credits (iCloud): Only your credit balance is synced privately via Apple iCloud so that you can restore credits after reinstalling.
• Microphone Permission (Optional): If you choose to narrate stories with your own voice, the App will request mic access solely for recording narration. No voice data is collected or transmitted by me.

The App does not collect analytics, advertising identifiers, usage tracking, IP addresses, device identifiers, or crash analytics.

3. Use of AI Services (OpenAI/ChatGPT)

To generate stories, images, text-to-speech (TTS) audio, and to run a safety review prompt, the App sends prompts and necessary generation parameters to OpenAI (“processor”). The prompts are constructed from App-provided elements (not from your personal data). OpenAI returns the generated content to the App.

• Purposes: Create story text and images, generate TTS audio, and perform a content safety review before display.
• Data Sent: Non-personal prompts, model parameters, and intermediate story content required to complete generation.
• No marketing/ads: The App does not send data to third parties for advertising or analytics.

4. Legal Bases for Processing (GDPR)

• Performance of a Contract / App Functionality: Processing via OpenAI and iCloud is necessary to provide the core features (story generation, TTS, credit restore).
• Legitimate Interests: Basic security and reliability measures (e.g., minimal logging by Apple systems) where applicable.
• Consent (Microphone): Access to the microphone is based on your explicit, revocable system permission.

5. Storage & Security

• Local Storage: Stories, images, and audio are stored locally on your device.
• iCloud (Credits Only): Credits are synced privately through Apple’s iCloud. Access is tied to your Apple ID.
• Encryption: Apple’s platform-level encryption and secure storage standards apply to iCloud data. Locally stored data remains on your device unless you choose to share/export it.

6. Children’s Privacy & Parental Guidance

SpinFable is designed for family-friendly content. The App does not intentionally collect personal data from children. A safety review step via AI is applied; however, parents/guardians are advised to review each story before reading it to children. If you believe a child has provided personal information inadvertently, contact me to address it.

7. Purchases & Payments

SpinFable offers in-app purchases of credits through Apple. I do not receive your payment card details; Apple processes payments under its own terms and privacy policy.

8. Data Sharing

• OpenAI (Processor): Receives non-personal prompts and intermediate content to generate stories, images, TTS, and to perform safety review.
• Apple (Platform / iCloud / App Store): Handles iCloud syncing for credits and processes payments. I do not share your data with marketers or data brokers.
• No Ads/No Analytics: The App integrates no advertising SDKs or analytics services.

9. International Data Transfers

When processors are located outside the European Economic Area (EEA), transfers rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses (SCCs). I aim to minimize data sent and avoid personal data wherever possible.

10. Data Retention

• Local Content: Remains on your device under your control and is deleted when you delete it or uninstall the App.
• Credits in iCloud: Persist until you delete the App data or disable iCloud for the App.

11. Your Rights (GDPR)

Where applicable, you have the right to access, rectify, erase, or port your data, and to object or restrict processing. Because SpinFable stores stories locally and syncs only credits via iCloud, most controls are available directly on your device (delete stories, uninstall App, disable iCloud). For requests, contact: contact@kubographics.com.

You also have the right to lodge a complaint with your local data protection authority. In Spain, this is the AEPD.

12. Cookies & Website

The App does not use cookies. The SpinFable product page (link) has no tracking/analytics cookies enabled.

13. Access Permissions

• Microphone: Optional. Used only if you choose to record narration. You can revoke this in your device settings at any time.

14. Safety Review Step

Each story undergoes an AI-based safety review prompt to help filter potentially unsuitable content. This is a best-effort feature and does not replace parental review. Parents/guardians should always check the story before reading it to children.

15. Age & Availability

SpinFable is intended for families with parental supervision. The App does not knowingly collect personal information from children under 13. If you are a parent/guardian and believe we have received such information, contact me to address it promptly.

16. Changes to this Policy

I may update this Privacy Policy to reflect changes in features or legal requirements. Material changes will be communicated in-app or via the contact details you provide (if applicable). The “Effective Date” above will always show the latest version.

17. Contact

📧 contact@kubographics.com
Data Controller: Eugenio Keller Puente (Spain)