Jollytown Privacy Policy
The short version
- Jollytown is a Christmas and New Year countdown village for families: advent calendar, games, widgets and pretend calls with Santa and Rudolph.
- Santa is a pretend character. His answers are chosen on your device from lines we wrote, personalised with details you give him. He is not a real person.
- Jollytown has no servers of its own. Your child's voice, words, details, photos you choose and call recaps never leave your device.
- We never record calls. Speech is turned into text on the device and then discarded.
- We do not ask for your name, email, address or phone number. We do not track you across other apps or websites.
- If you allow it, we count anonymously which features are used and how long calls last, to improve the app. Never names, wishes, what was said or photos. You can turn this off at any time.
- Free users may see non-personalised ads in the grown-ups area only, never on your child's screens. Any purchase removes them.
- You can delete everything at any time from the app.
1. Who we are
Jollytown is made by ADEPT LABS TECHNOLOGY COMPANY LIMITED, a company registered in Vietnam ("ADEPT Labs", "we", "us"). 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, recaps and the parent tools below are only available behind the parental gate.
2. Information that stays on your device
Everything in this section is stored and processed only on your iPhone or iPad. We cannot see it, and it is not sent to us or to anyone else.
2.1 What a parent enters about a child
Nickname, age, pronouns, wishes, good deeds, gentle reminders, topics to avoid, "Santa's secrets" (for example a pet's name, a favourite toy, or what your child had for breakfast today; "today" secrets are forgotten the next day), good deeds reported in the "Elf report" (deleted automatically after 30 days), and an optional note for Santa's voicemail.
2.2 Your child's words during a call
Your child's voice is turned into text by Apple's speech recognition on your device. The audio is not recorded. The text is used by the app on the device to choose Santa's (or Rudolph's) next words, which are read aloud with a built-in iOS voice. On devices that support Apple Intelligence, Apple's on-device language model may write a short reaction; it runs entirely on the device (the app does not use Apple's Private Cloud Compute). The conversation text is held in the app's memory only for the length of the call and is then discarded.
2.3 Call recaps and safety notes
After a call the app writes a short recap for you on the device (for example the wishes your child mentioned). If your child said something that suggests they may be unsafe or upset, Santa encourages them to talk to a trusted grown-up and the recap shows a note, including those words, so you can follow up. Recaps are saved only on your device until you delete them.
2.4 Photos you choose
If you send a drawing or letter to Santa, or use Santa Cam, you pick or take a photo. The photo is read on the device with Apple's Vision framework (to find words, objects and colours) or combined with a drawing of Santa. The app does not save or upload the photo. For drawings and letters, only a short description you can edit (for example "your drawing of a snowman") and any wishes you confirm are kept, for 14 days. A Santa Cam picture is only saved if you choose to save or share it with the iOS share sheet.
2.5 Camera during video calls
In a video call your child sees themselves in a small window, like a real video call. The camera picture is only shown on the screen: the app has no photo, video or frame recording, and nothing is saved or sent. The app uses the position of a face in the picture (a rectangle, not an image) so the animated Santa can look towards your child. Between Christmas Day and 6 January, Santa may ask your child to hold up a favourite present: one camera frame is checked on this device by Apple's built-in image recognition to name the toy (for example "teddy bear"), and the frame is discarded straight away. It is never stored or sent.
2.6 Call time and purchases
Free daily call time, purchases and rewarded-ad bonuses are kept in a small file on the device. Purchases are made through Apple and verified on the device with Apple's StoreKit. We never see your payment details. A counter in the iOS Keychain remembers how much purchased call time has already been used, so restoring purchases after reinstalling does not hand it back.
2.7 Widgets, Live Activities and Apple Watch
The countdown widgets, Live Activities and the Apple Watch app show the countdown and seasonal content. They run on your devices and do not send anything to us.
3. Information that leaves your device
3.1 Advertising (free users, grown-ups area only)
Free users may see ads from Google AdMob in the grown-ups area only (for example, "watch an ad for +30 seconds" or a sponsored card). 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). In the EU, EEA, UK and Switzerland, ads are only requested after the consent choice required by law. AdMob may 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.
3.2 Anonymous usage statistics
To learn which parts of the app families use, the app can send anonymous usage events to Google Analytics for Firebase: for example that a call started or ended (with whether it was Santa or Rudolph, voice or video, its length in seconds and how many times the child spoke), which village place or grown-ups tab was opened, which secret-helper prompt was chosen, an age band (2-4, 5-7 or 8-12), counts such as how many wishes were entered, and App Store purchases (product and price). Google Analytics also records basic device and app information (device model, iOS version, app version, country, a random app-instance ID) and automatic events such as first open and session start.
Never sent: your child's name or exact age, wishes, secrets, good deeds, what was said, recaps, photos or any text you type. The app does not use the advertising identifier (IDFA) or the device's vendor identifier for analytics, and ad personalisation and ad-network sharing are turned off. Statistics are only collected after you accept the consent screen, are off by default in the EU, EEA, UK and Switzerland, and can be switched on or off in Grown-ups → Settings → Share anonymous usage statistics. Google keeps this data for 14 months.
3.3 Crash reports
If the app crashes, Google Firebase Crashlytics sends us a crash report: the technical stack trace, app version, device model, operating system version, free memory and disk space, and a random installation ID that is not linked to you. Crash reports never include your child's details, what was said, photos or recaps. We use them only to find and fix bugs.
3.4 Reports and support emails
If you tap "Report a problem", the app opens an email to us in your Mail app. You choose what to write and whether to send it. We use it only to answer you and fix problems, and keep it for up to 12 months.
3.5 What we do not collect
We do not collect names, email addresses (unless you email us), phone numbers, postal addresses, location, contacts, photos, audio, conversation text, or your device's advertising identifier. We do not use tracking SDKs, and we do not run any server that stores information about you.
4. Service providers
| Provider | What it does | Information |
|---|---|---|
| Apple (on your device) | Speech recognition, Santa's voice, Vision photo reading, on-device language model | Stays on the device |
| Apple | Payments and App Store purchases | Purchase data, handled by Apple |
| Google (AdMob, User Messaging Platform) | Non-personalised ads and consent choices for free users, grown-ups area only | Limited device and network data, ad interactions |
| Google (Firebase Crashlytics) | Crash reports | Technical crash and device data, random installation ID |
| Google (Analytics for Firebase) | Anonymous usage statistics, only if allowed | Feature-use events and numbers listed in 3.2, basic device data, random app-instance ID |
We may disclose information we hold (such as support emails) if required by law or to protect the safety of a child or others.
5. Children's privacy (COPPA)
Jollytown 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. Information about your child (sections 2.1 to 2.5) is processed only on your device and is not collected by us. Children cannot make purchases, see ads, share information publicly or contact other people through the app.
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 use by not making more calls, turning off the microphone, speech recognition or camera for the app in iOS Settings, or deleting the app, which removes everything the app stored.
6. How long information is kept
| Information | Kept |
|---|---|
| Child details, secrets and recaps | On your device until you delete them or the app ("today" secrets: one day) |
| Elf report good deeds | On your device, deleted automatically after 30 days |
| Drawing and letter descriptions | On your device, used for 14 days |
| Call audio, conversation text, photos, camera picture | Not recorded or saved |
| Call time and purchase records | On your device until you delete the app |
| Support emails | Up to 12 months |
| Crash reports | Up to 90 days in Firebase Crashlytics |
| Usage statistics | 14 months in Google Analytics |
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. Because your family's information stays on your device, you can review and delete it yourself in the app. For anything we hold (support emails, crash reports, usage statistics), email us and we will reply within 30 days. You can change your ad consent choice in the grown-ups area. 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 (the app and purchases), consent (the parent's agreement before the first call, and ad consent where required), consent for usage statistics where required (you can withdraw it in Settings), and our legitimate interests in fixing crashes, improving the app and preventing fraud.
Ad, crash and usage information may be processed by Google in countries other than your own, including the United States, under safeguards such as the European Commission's Standard Contractual Clauses.
8. Security
Because Jollytown has no server of its own and keeps your family's information on your device, there is very little that could be exposed. Data on the device is protected by iOS encryption and your passcode.
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