Santa Calling Privacy Policy
The short version
- Santa is a character voiced by artificial intelligence (AI). He is not a real person.
- We never record calls. Your child's voice is streamed to our AI provider only while a call is happening and is not saved by us.
- Your child's name, age, wishes and call recaps are saved only on your device. They are sent for the length of a call and are not stored on our servers.
- We do not ask for your name, email, address or phone number. We do not track you across other apps or websites.
- Free users may see non-personalised ads in the grown-ups area only, never during a call. Any purchase removes them.
- You can delete everything at any time from the app.
1. Who we are
Santa Calling is made by ADEPT LABS TECHNOLOGY COMPANY LIMITED, a company registered in Vietnam ("ADEPT Labs", "we", "us"). We are responsible for the personal information described in this policy. Contact: admin@adept-labs.com.
The app is designed to be set up and controlled by a parent or guardian. A grown-up must pass a parental gate and agree to this policy before a child can make a call. Purchases, ads, settings and recaps are only available behind the parental gate.
2. Information we handle
2.1 Information a parent enters about a child
Nickname, age, pronouns, up to three wishes, up to three good deeds and up to two gentle reminders. This is stored only on your device. When a call starts, it is sent to our server, which uses it to write Santa's instructions for that one call and passes those instructions to our AI provider. Our server does not store or log it.
2.2 Voice during a call
While a call is active, your child's voice is streamed from your device directly to our AI provider (OpenAI) so Santa can hear and reply. Audio does not pass through or get stored on our servers, and we do not record calls on your device. The AI provider also turns what is said into text so the conversation can continue and so a recap can be written (see 2.3).
2.3 Call recaps and safety checks
After a call, the text of the conversation, which was held only in the app's memory, is sent once to our server. The server asks our AI provider to write a short recap for you and to check it with an automated safety (moderation) service. If the conversation suggests your child may be unsafe or upset, the recap shows a note so you can follow up. The text is then discarded: our server does not store or log it. Only the recap is saved, and only on your device.
2.4 Account and usage information on our server
To keep track of call time and purchases, the app creates an anonymous account the first time it opens. Our server keeps:
| Information | Why |
|---|---|
| A random account ID and a secret sign-in token (we store only a one-way hash of the token; the token itself stays in your device's Keychain) | To recognise your device |
| Call records: start time, length, status (no names, audio or text) | To count minutes used and prevent abuse |
| App Store purchase records: transaction ID, product, date, expiry | To give you what you paid for and to handle refunds |
| Rewarded-ad records: ad transaction ID and date | To add bonus seconds and enforce the daily limit |
| Reports you send: reason, optional details you type, and the related call record ID | To review and fix problems |
Like any internet service, our hosting provider (Cloudflare) processes IP addresses and basic request data to deliver and protect the service.
2.5 Purchases
Payments are handled by Apple. We never see your payment details. We receive transaction information from Apple to confirm purchases.
2.6 Advertising
Free users may see ads from Google AdMob in the grown-ups area only (for example, "watch an ad for +30 seconds"). Ads are never shown on the child's screens or during calls. We configure AdMob for child-directed treatment and users under the age of consent, which turns off personalised (interest-based) advertising and limits ads to general-audience content. We do not ask for permission to track you, and the app does not access your device's advertising identifier (IDFA). AdMob is only started after a grown-up opens the purchase screen, and, in the EU, EEA, UK and Switzerland, after the consent choice required by law. AdMob may still collect limited device and network information (such as IP address and device type) to deliver ads, measure them and prevent fraud; see how Google uses information from apps that use its services. No information about your child is shared with AdMob. Any purchase removes ads.
2.7 What we do not collect
We do not collect names, email addresses, phone numbers, postal addresses, precise location, contacts, photos, or your device's advertising identifier. We do not use analytics or tracking SDKs. Crash information comes only from Apple's built-in diagnostics, if you have chosen to share them with developers.
3. How we use information
- To run calls with Santa and personalise them with the details you chose.
- To write recaps and flag possible safety concerns to you.
- To count call time, deliver purchases and rewards, and prevent fraud and abuse.
- To review reports and improve the safety of Santa's answers.
- To show non-personalised ads to free users in the grown-ups area.
We do not sell or rent personal information, we do not use it for behavioural advertising, and we do not use your family's calls to train AI models.
4. Service providers
| Provider | What it does | Information |
|---|---|---|
| OpenAI | Voice conversation, transcription, recaps, safety checks | Call audio and text, child details for that call |
| Cloudflare | Hosts our server and database | Data listed in 2.4 |
| Apple | Payments, App Store purchase records | Purchase data |
| Google (AdMob, User Messaging Platform) | Non-personalised ads and consent choices for free users | Limited device and network data, ad interactions |
We use OpenAI through its business API. Under OpenAI's API terms, data sent through the API is not used to train its models. OpenAI may keep API data for up to 30 days to detect abuse and then deletes it, unless the law requires otherwise. We may also disclose information if required by law or to protect the safety of a child or others.
5. Children's privacy (COPPA)
Santa Calling is meant to be used by children with a parent's permission and supervision. Before a child can make a call, a parent must pass the parental gate and agree to this policy. The child information we handle is limited to what is needed for the call: the details the parent enters (2.1), the child's voice during the call (2.2) and the conversation text used to write the recap (2.3). We do not let children make purchases, see ads, share information publicly or contact other people.
Parents can at any time:
- Review what Santa knows by opening a child's profile, and read every recap.
- Change or delete a child's details, delete any recap, or use Grown-ups → Delete all data.
- Stop further collection by not making more calls and deleting the app.
- Ask us to delete the server records in 2.4 by emailing us with the Support ID shown in Grown-ups → Privacy.
6. How long we keep information
| Information | Kept |
|---|---|
| Child details and recaps | On your device until you delete them or the app |
| Call audio and conversation text | Not stored by us; only for the length of the call and recap |
| Account, call, purchase and ad-reward records | While the account is in use, and up to 24 months after the last activity for accounting and refund handling; deleted within 30 days of a verified deletion request, except purchase records we must keep by law |
| Reports | Up to 12 months |
7. Your rights (including EU, EEA, UK and California)
Depending on where you live, you may have the right to access, correct, delete or export your personal information, to object to or restrict how we use it, and to withdraw consent. Email us with your Support ID and we will reply within 30 days. You can change your ad consent choice in the purchase screen. If you are in the EU, EEA or UK you may also complain to your local data protection authority.
Our legal bases under the GDPR are: performing our contract with you (calls, purchases), consent (the parent's agreement before the first call, and ad consent where required), and our legitimate interests in preventing fraud and keeping the service safe.
Your information may be processed in countries other than your own, including the United States, by the providers listed in section 4. Where required, those transfers rely on safeguards such as the European Commission's Standard Contractual Clauses.
8. Security
Connections are encrypted. The app never holds our AI provider's long-term keys; each call uses a short-lived key that can only start a call within 60 seconds. Your sign-in token is stored in the iOS Keychain and our server stores only a hash of it. No system is perfectly secure, but we limit what we collect so there is little to expose.
9. Changes
If we change this policy, we will update the date above. If a change affects how we handle children's information, we will ask for a parent's agreement again in the app before the next call.
10. Contact
ADEPT LABS TECHNOLOGY COMPANY LIMITED, Vietnam · admin@adept-labs.com