Twirly
Twirly Privacy Policy
Effective: 13 October 2026
In short: Twirly does not collect personal information from children or anyone else. Everything a child makes stays on the device. There are no ads, no analytics, no tracking, no accounts and no chat. Optional purchases are made by a grown-up through Apple.
1. Who we are
Twirly is a game for children aged 3 to 5 for iPhone and iPad, published by AUETRON (“we”). This policy explains how the Twirly app handles information. It applies to the app only; our website has its own website privacy notice.
2. Children’s privacy
Twirly is designed for young children. We do not ask for, collect, store on our servers, sell or share any personal information — no names, ages, email addresses, photos, voice recordings, location, contacts or device identifiers. The app has no sign-in, no chat, no social features and no way for a child to send anything out of the app. It contains no advertising and no third-party analytics or tracking. We designed Twirly to meet the requirements of children’s privacy laws such as the U.S. Children’s Online Privacy Protection Act (COPPA) and the EU and UK General Data Protection Regulation, and Apple’s rules for apps in the App Store Kids category, by not collecting children’s personal information at all.
3. Information stored on the device
To work, Twirly keeps a small amount of information only on your device, inside the app’s private storage. We cannot see or access it.
| What | Why |
|---|---|
| Saved looks in the Style Book (the outfit, chosen place, frames and stickers, and a small preview picture) | So a child can see and change their saved looks. |
| The outfit a child is currently working on | So play continues where it stopped. |
| Settings (music, sound effects, grown-up check before deleting, showing pack items) | To remember a parent’s choices. |
| Which optional packs the family owns | So purchased packs stay unlocked, including offline. |
Saved looks are not added to the Photos library. Like other app data, this information may be included in your device’s own iCloud or computer backup if you have backups turned on; those backups are controlled by you and Apple, not by us.
4. Purchases and Apple
Twirly can be played fully for free. Optional one-time content packs are sold as in-app purchases through Apple’s App Store. Purchases can only be started from the grown-up area, which is protected by a grown-up check, and are confirmed through Apple’s own purchase sheet.
Apple processes the purchase, payment and any refund under Apple’s Privacy Policy. We do not receive your name, Apple Account, email address or payment details. Apple tells the app on the device which packs the family is entitled to (including purchases restored on another device or shared through Family Sharing), and the app uses this only to unlock content. We may receive aggregated, non-identifying sales and download reports from Apple, as every App Store developer does.
5. Third parties
Twirly contains no third-party software development kits for advertising, analytics, crash reporting or social media, and it makes no network connections of its own. The only external service involved is Apple’s App Store and in-app purchase system, described above. The app contains no links for children; the only link (to this policy) is in the grown-up area.
6. Retention and deletion
Information on the device is kept until you delete it. You can delete all saved looks in the grown-up area (Delete all looks), delete a single look in the Style Book, or delete everything by removing the app. Purchases are kept by Apple with your Apple Account and can be restored at any time with Restore purchases.
7. Parents’ choices and rights
Because we don’t collect personal information, we hold no personal data about you or your child to access, correct or delete. You remain in control of everything stored on the device as described above. You can turn off in-app purchases entirely with Screen Time (Content & Privacy Restrictions), and use Ask to Buy with Family Sharing so a parent approves every purchase. If you have any question or concern, please contact us (see below).
8. Security
Saved data is stored in the app’s private storage, protected by iOS and iPadOS data protection. It is never transmitted by the app.
9. Changes to this policy
If we change how Twirly handles information, we will update this policy and its effective date before the change takes effect, and describe material changes in the app’s release notes. We will not start collecting personal information from children without first obtaining verifiable parental consent as required by law.
10. Contact
Our contact email address is being set up and will be published here before Twirly is released.