Privacy Policy

This Privacy Policy explains what information Kammunicate (the “App”) collects, how it is used, stored, and protected. Kammunicate is an iPad application designed to support individuals with communication disabilities through augmentative and alternative communication (AAC).

Developer: Christopher Hardy
Bundle Identifier: com.sentientcaregroup.Kammunicate

1. Information We Collect

The App collects and stores the following types of information. Unless explicitly noted under the Remote Carer feature (Section 5), all data is stored locally on your device only.

1.1 Communication Content

• Drawings and handwriting: Created on the drawing canvas using Apple Pencil or touch input
• Communication cards: Cards selected from the built-in library of 150+ cards across 11+ categories
• Photos: Images captured via camera or selected from your photo library, stored locally as JPEG files
• Stickers: Visual stickers added to communication messages
• Communication history: A chronological record of all messages exchanged, including timestamps and associated media

1.2 Personalisation Data

• Avatar information: Custom avatars created for each participant
• Player names: Custom names assigned to each participant
• Role settings: Role assignments (Needs Expresser or Support Provider)
• Preference settings: App customisation choices including Easy Read mode, ambient music preferences, colour selections, and brush sizes

1.3 Machine Learning & Analytics Data

• Usage patterns: Which communication cards are used together and in what sequences
• Card effectiveness: Which suggestions are accepted or dismissed
• Contextual preferences: Time-of-day usage patterns and topic preferences
• Drawing analysis data: Automated analysis of drawings to suggest relevant communication cards
• Engagement metrics: Session duration, message frequency, and interaction patterns for the on-device Professional Learning Dashboard
• Drawing training samples: Up to 500 samples stored locally for improving drawing recognition

1.4 Technical Data

• App version information: Current version installed on your device
• Crash recovery data: Saved message drafts to restore your work after unexpected app closures
• Network status: Connectivity state monitored locally to manage the Remote Carer feature

2. How We Use Your Information

All information is used exclusively to provide and improve the App's functionality. We do not use your information for advertising, profiling, or any purpose unrelated to communication support.

2.1 Communication

• Displaying, storing, and retrieving messages between communicators and carers
• Maintaining communication history for review
• Recovering unsaved drafts if the app closes unexpectedly

2.2 Personalisation and Machine Learning

All machine learning runs entirely on your device using Apple's native frameworks:

• Smart card suggestions: On-device machine learning systems analyse usage patterns to suggest relevant communication cards
• Pattern recognition: Learning which cards work best in different contexts and times of day
• Handwriting recognition: Converting handwritten text into communication suggestions using Apple's Vision framework
• Drawing analysis: Identifying objects and intentions in drawings to suggest appropriate communication cards

2.3 Caregiver Insights

• Professional Learning Dashboard: On-device insights about communication patterns, frequently used topics, and engagement levels
• Health pattern indicators: Detecting potential health-related patterns from communication content, processed locally
• Progress tracking: Monitoring communication growth and identifying areas of focus

3. Data Storage & Security

3.1 Local Storage

• Primary storage: All core data is stored in the app's secure sandbox using Apple's UserDefaults, local file storage, and the iOS Keychain
• File protection: Sensitive files use iOS Complete File Protection
• No external databases: The App does not maintain any external databases or server infrastructure

3.2 Encryption

On-Device Encryption

• At rest: All data benefits from iOS device-level encryption
• Keychain storage: Cryptographic keys are stored in the iOS Keychain with device-only protection

Remote Carer Encryption (when enabled)

• Algorithm: AES-GCM (Advanced Encryption Standard, Galois/Counter Mode)
• Key exchange: ECDH with P256 curves
• Key derivation: HKDF-SHA256 with deterministic salt generation
• Key lifecycle: Unique keys per carer pairing, permanently deleted when unpaired

3.3 Data Retention

• Communication history: Stored until manually deleted by the user
• Engagement logs: Events older than 30 days are automatically cleared
• Machine learning models: Continuously updated; drawing training samples capped at 500
• Pairing invitations: Automatically expire after 24 hours and are single-use

4. Data Sharing & Third Parties

We do not share, sell, rent, or transmit your data to any third parties. The App does not:

• Send data to external servers operated by us or any third party
• Share information with advertisers or ad networks
• Transmit data to analytics or tracking services
• Connect to social media platforms
• Use any third-party SDKs, libraries, or tracking tools
• Contain any third-party code

4.1 Apple Services

The App uses the following Apple-provided services, governed by Apple's Privacy Policy:

5. Remote Carer Feature & CloudKit

5.1 Overview

Kammunicate includes an optional Remote Carer feature that allows a support person using the Kampanion companion app to exchange messages with the communicator. This is the only feature that transmits data beyond your local device.

5.2 How Pairing Works

• A pairing invitation is created on the Kammunicate iPad, generating a QR code and a 6-character pairing code
• The remote carer scans or enters the code in the Kampanion app
• Pairing codes expire after 24 hours and are single-use
• No email addresses, phone numbers, passwords, or account creation are required

5.3 What Data Is Synced

• Encrypted message content (drawings, card references, photos, text)
• Carer records (identifier, avatar, online status)
• Pairing invitations and device presence information

5.4 Security Measures

• End-to-end encryption: All message content encrypted with AES-GCM before storage in CloudKit
• Rate limiting: Maximum 30 messages per minute
• Key deletion: All encryption keys permanently destroyed when a carer is unpaired

5.5 Disabling

You can unpair any remote carer at any time. If you do not use this feature, no data is transmitted beyond your device.

6. Permissions We Request

All permissions are optional. The App will function without granting them, though certain features will be unavailable.

• Camera: Capture photos for messages and scan QR codes for pairing
• Photo Library: Select existing photos for communication messages
• Microphone: Record voice messages
• Apple Music: Play calming background music
• Push Notifications: Receive real-time messages from remote carers

7. Children's Privacy

Kammunicate may be used by children with communication disabilities. We take children's privacy seriously.

• No personal information collection: The App does not collect personal information requiring parental consent under COPPA
• Local processing only: All data remains on the device under the parent or guardian's control
• No online communication with strangers: The Remote Carer feature only permits communication between deliberately paired devices
• Supervision recommended: Parents or guardians should supervise the use of the App by children

8. Your Privacy Rights & Controls

Access and Review

You can access all your data directly within the App through Communication History, the Professional Learning Dashboard, and Settings.

Data Deletion

• Delete individual messages via long-press on history entries
• Delete custom avatars through the avatar management interface
• Unpair carers to delete synced data and encryption keys
• Remove the App to permanently delete all locally stored data

Right to Be Forgotten

Because the App does not store data on external servers (aside from optional CloudKit sync via your own iCloud account), deleting the App effectively exercises your right to erasure.

9. Health-Related Features

Kammunicate includes on-device health pattern detection that analyses communication content only to identify potential health-related indicators such as pain expressions or changes in engagement levels.

• The App does not access Apple HealthKit or any health records
• Health pattern indicators are inferred from communication content and processed locally
• These indicators are observational tools for caregivers and are not medical advice

10. Machine Learning Systems

Kammunicate uses complementary on-device machine learning systems running entirely on your device using Apple Core ML, including card prediction, contextual analysis, semantic grouping, drawing analysis, and real-time learning.

11. Legal Compliance

The App's privacy-first, on-device architecture supports compliance with GDPR, UK GDPR, CCPA/CPRA, COPPA, PIPEDA, and the Australian Privacy Act. Since all data processing occurs locally, many requirements related to external data processing do not apply.

12. Changes to This Policy

We may update this Privacy Policy to reflect changes in features, legal requirements, or privacy best practices. Material changes will be highlighted in App Store release notes. Your continued use of the App constitutes acceptance of the updated policy.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or your privacy rights, please contact us: