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Pomagotchi Privacy Policy

Effective: May 16, 2026 · Version 1.2 · App: Pomagotchi (iOS / iPadOS / watchOS) · Publisher: Thomas Ray Publishing LLC

0. Privacy at a Glance

• We don’t operate any servers. TRP has no Pomagotchi user account system, no login, no friend list backend.
• We don’t collect personal information about you. No name, email, phone, address, IP address, advertising ID, device ID, or location ever leaves your device on our account, unless you choose to fill in our optional Feedback form.
• We don’t sell or share your personal information. We never have, and we have no business model that would. No targeted advertising, no cross-context behavioural tracking, no data brokers, no monetisation of user data of any kind.
• No third-party SDKs. No analytics SDKs, no ad networks, no attribution, no tracking. Pomagotchi does not track you across apps or websites owned by other companies.
• AI runs on your device. Letters, mood text, sentiment, sound recognition, vision, and personality features use Apple’s on-device frameworks (Apple Foundation Models, SoundAnalysis, Vision, Natural Language, CoreML). They do not call cloud AI services. We do not use Apple’s Private Cloud Compute, ChatGPT, Gemini, Claude, or any other third-party AI.
• Your cloud saves are yours. Game progress and Pom Stasis backups live in your iCloud (Apple’s service governed by Apple’s privacy policy). We cannot read them.
• Two small cloud surfaces we do operate, both using Apple CloudKit:
  • Anonymous analytics (opt-out at any time): minimised, non-identifying counters about how the app is performing. No name, email, IP, location, pet name, or other identifier.
  • Feedback form (only when you tap “Send Feedback”): contains whatever you choose to write, and is only readable by TRP.
• Children: the app is designed to be safe for all ages and does not knowingly collect personal information from anyone, including children under 13. Section 16 explains additional protections.

1. Introduction & Scope

This Privacy Policy explains how Thomas Ray Publishing LLC (“TRP”, “we”, “us”) handles information in connection with the Pomagotchi application for iOS, iPadOS, and watchOS (the “App”), distributed worldwide through the Apple App Store.

It applies to the App and to the supporting pages on thomasraypublishing.com. It does not apply to Apple’s own services (iCloud, Game Center, the App Store, WeatherKit, MapKit, HealthKit, Apple Foundation Models, Apple Intelligence). Apple’s handling of any information collected through those services is governed by Apple’s privacy policy at https://www.apple.com/legal/privacy/.

The App is rated 4+ on the App Store. It is designed to be a mixed-audience product that is safe for users of all ages. It is not part of the Apple Kids Category.

2. Identity of the Controller / Contact

The data controller for any personal data processed in connection with the App (which is limited to what is described in Sections 11 and 12 below) is:

Thomas Ray Publishing LLC
c/o InCorp Services, Inc.
2360 Corporate Circle, Suite 400
Henderson, NV 89074-7722
United States
Email: thomasraypublishing@gmail.com
Web: thomasraypublishing.com

Privacy Officer / Contact for privacy questions: Sean Dryden, reachable at the email above. For users in Quebec, this person is also the Person Responsible for the Protection of Personal Information under Law 25.

EU representative under GDPR Article 27. TRP has not appointed an EU representative. TRP relies on the Article 27(2) exemption for processing that is occasional, does not involve large-scale processing of special categories of personal data as referred to in Article 9(1), does not include processing of personal data relating to criminal convictions and offences referred to in Article 10, and is unlikely to result in a risk to the rights and freedoms of natural persons, taking into account the nature, context, scope and purposes of the processing. TRP’s processing through Pomagotchi consists solely of (i) opt-in CloudKit feedback submissions that occur only when a user initiates a support request, and (ii) minimised CloudKit analytics records that contain no name, email, IP address, precise or coarse location, advertising identifier, device identifier, or other directly identifying data and that are treated as personal data where applicable law requires (see Section 4.3). EU and EEA users may exercise their rights under the GDPR by contacting TRP directly at the email and postal address in this Section, and we will respond within the timelines required by Article 12. We will reassess this position as the App’s usage in the EU grows or if the European Data Protection Board issues guidance that narrows the Article 27(2) exemption.

UK representative under UK GDPR Article 27. TRP has not appointed a UK representative and relies on the equivalent Article 27(2) exemption under UK GDPR for the reasons described above for the EU. UK users may exercise their rights by contacting TRP directly at the email and postal address in this Section. From 19 June 2026, under the United Kingdom Data (Use and Access) Act 2025, UK users also have the right to complain directly to the controller; we accept and respond to such complaints at the email address above and will acknowledge receipt within a reasonable period.

3. The Architecture in One Paragraph

TRP operates no servers. The App stores everything on your device by default. Optional cloud surfaces use Apple’s iCloud (which is your own iCloud account, not ours) and Apple’s CloudKit (where TRP has two small, narrowly-scoped containers: an anonymous analytics container and a private feedback container). All AI, machine-learning, vision, and audio analysis runs on your device.

4. What We Collect — By Surface

4.1 On the device (no transmission to TRP)

The vast majority of what the App processes never leaves your device:

• Your pet’s name, appearance, level, mood, inventory, in-game gems, mini-game scores, trophies, accessory state, and personality state.
• Your environment, motion, sound, and visual inputs while features that need them are active (see Section 6 — Permissions).
• AI-generated text (Paper Pom Letters, mood text), sentiment analysis output, sound classification labels, vision results, personality engine outputs.

Nothing in this list is transmitted to TRP.

4.2 In your iCloud (TRP cannot read)

With your Apple ID’s permission, the App writes to two areas of your iCloud:

• iCloud Key-Value Storage (NSUbiquitousKeyValueStore) — gameplay progress and preferences, so your Pom syncs between your iPhone, iPad, and Mac.
• GameSave cloud saves (Apple’s GameSave framework on iOS 26+, stored in your iCloud Documents) — “Pom Stasis” snapshots of your pet’s full state.

These data live in your Apple iCloud account. They are governed by Apple’s privacy policy and are protected by your Apple ID security. TRP has no ability to read them. If you sign out of iCloud, those features stop syncing.

4.3 In TRP’s CloudKit public container — minimised analytics

If you have anonymous analytics enabled (it is on by default and can be turned off at any time in Settings ► Privacy), the App writes one minimised record at most once every 24 hours to a public CloudKit database that TRP controls (iCloud.PomPet.Analytics). Each record contains:

• A per-install random deduplication ID (generated locally; not linked to your Apple ID, your name, your email, your device’s advertising ID, or any other identifier; rotated if you reinstall or reset).
• App version, iOS/iPadOS/watchOS version, device model class (e.g., “iPhone15,3”), screen size, locale, time zone offset.
• Aggregate counts: session count, days active, action counts, mini-game scores, gem totals, trophy count.
• Health signals: crash-free session rate, memory-warning counts, error summaries (counts and category codes, no message bodies, no stack traces with user content).
• Feature toggles, subscription status flag and tenure measured in days only (no payment data, no transaction ID, no receipt), in-app-purchase event counts (counts only), Watch-paired flag, widget-active flag.
• An extendedMetrics JSON blob for forward-compatible non-identifying counters.

This record does not contain your name, email, phone, address, IP address, precise or coarse location, pet name, written letter content, photo, audio, video, contacts, health data, financial data, or any other identifier that could reasonably be used to identify you. We design the analytics record to minimise the possibility of identifying you, but we recognise that pseudonymised data combined with technical fingerprints could in principle single out an individual user. We therefore treat these records as personal data where applicable law requires us to do so, including in the European Union, the European Economic Area, the United Kingdom, and any other jurisdiction whose law treats pseudonymised data as personal data. We use these records solely to understand whether the App is working and which features are used so we can fix bugs and prioritise improvements. We do not sell, share, or use them for advertising, profiling, or cross-context behavioural advertising of any kind.

Analytics records are retained for up to 13 months and then automatically purged (see Section 19). You can disable anonymous analytics in Settings ► Privacy ► Anonymous Analytics. When disabled, no record is written.

4.4 In TRP’s CloudKit private container — Feedback form only

Only when you tap Send Feedback and submit the form, the App writes a single record into a private CloudKit container that only TRP can read. The fields are exactly what you type:

• Your feedback message (free text).
• Optionally, your name.
• Optionally, your email (so we can reply).
• Optionally, a diagnostic report generated locally (app version, iOS version, recent error codes — never your name, email, contacts, location, or pet content).
• Optionally, up to three screenshots that you pick using Apple’s PhotosPicker.

If you are signed out of iCloud, the App falls back to opening Apple’s Mail composer with the same payload pre-filled, and nothing is uploaded to CloudKit.

We use feedback solely to triage bugs and respond to you. We do not use it for advertising or share it with anyone. You may request deletion of a feedback submission at any time by emailing thomasraypublishing@gmail.com. See Section 11 for the special handling that applies to feedback from users under 13.

5. What We Explicitly Do Not Collect

We do not collect, transmit, or have access to:

• Your real name, email, phone number, mailing address, or any account identifier (unless you voluntarily type them into the Feedback form).
• Your IP address (we run no servers that would see it; Apple may see it for CloudKit/iCloud, governed by Apple’s privacy policy).
• Your precise or coarse geographic location.
• Your contacts.
• Your photos or videos (we only see screenshots you pick and attach to a feedback submission).
• Audio recordings or transcripts (Sound Reactions runs entirely on-device; no audio leaves your device).
• Camera frames (Teleport AR and gesture features run entirely on-device).
• Health or fitness data (step count is read on Watch on-device only; never transmitted).
• Advertising identifier (IDFA). We do not request App Tracking Transparency permission.
• Device identifiers (we use no identifierForVendor, no identifierForAdvertising, no DeviceCheck identifier for tracking, no fingerprint).
• Financial information. All purchases go through Apple StoreKit; we receive only an on-device receipt verification result.
• Biometric identifiers, government identifiers, neural data, immigration status, sexual orientation, religious beliefs, political opinions, racial or ethnic data, trade-union membership, or any other special-category / sensitive data.
• Children’s personal information. We do not knowingly collect personal information from any user, including children under 13 (see Section 16).

6. Permissions and What Each Is Used For

The App requests the following iOS permissions only when a feature that needs them is first used. You can revoke each in iOS Settings at any time. The exact prompts shown to you are:

• Location When In Use — “Pomagotchi uses your location to bring real weather to your Pom’s world, detect places like parks and Disney parks for special encounters, and let Nearby Friends know when you’re around. Your location is processed on your device. It is never sent to TRP.” Used with Apple’s WeatherKit and MapKit. Coordinates do not leave your device on our account; Apple sees them under its own privacy policy.
• Bluetooth (optional, OFF by default) — “Pomagotchi uses Bluetooth so two phones in the same room can let their Poms meet, peer-to-peer. There is no server and no internet involved.” See Section 7.
• Microphone (optional, OFF by default) — “Pomagotchi listens with the microphone so your Pom can react to sounds, like a clap or a whistle. Audio is analysed on your device in real time. Nothing is recorded or transmitted.”
• Motion & Fitness — “Pomagotchi uses motion to detect shakes and steps, so your Pom can play and earn walk bonuses. Motion data is processed on your device and is not stored after the session.”
• Camera — “Pomagotchi uses the camera for Teleport AR (placing your Pom in your world) and to recognise hand gestures. Camera frames are processed on your device in real time and are never recorded or saved.”
• Add to Photos — “Pomagotchi can save Photo Booth pictures of your Pom to your Photos library when you tap Save.” Add-only; we cannot read your library.
• HealthKit (Watch) — “Pomagotchi reads your step count on Apple Watch so your Pom earns bonuses for walks. Step count stays on your device and is never sent to TRP or included in analytics.”
• Notifications — “Pomagotchi sends local notifications scheduled on your device. We do not operate push servers.”

Picking screenshots for Feedback uses Apple’s PhotosPicker, which does not require a Photo Library read permission and does not give the App access to anything except the screenshots you pick.

7. Nearby Friends (Bluetooth peer-to-peer)

Nearby Friends is off by default. When you turn it on, your iPhone uses Bluetooth Low Energy to advertise and discover other phones running Pomagotchi nearby. The exchange happens directly between phones; there is no server.

The payload exchanged between two phones is limited to: your Pom’s display name, variant, level, current mood tag, and a rotating ephemeral peer ID. We do not exchange your Apple ID, real name, contacts, location, IP address, or any other identifier. Friendship and “pack” records are stored locally on your device and, if iCloud sync is enabled, in your own iCloud Key-Value Storage.

You can tap Reset Pom’s Social Identity in Settings to rotate the ephemeral peer ID and clear all friendship and pack records.

8. AI and On-Device Processing

Pomagotchi uses Apple’s on-device ML frameworks:

• Apple Foundation Models (the on-device ~3-billion-parameter language model included in iOS 26) for Paper Pom Letters, mood narration, and other text generation.
• Apple Natural Language for sentiment and tagging.
• Apple SoundAnalysis for Sound Reactions.
• Apple Vision for AR placement, gesture recognition, and photo aesthetics.
• CoreML for the personality engine.

All of these run on your device. Pomagotchi does not use Apple’s Private Cloud Compute, does not send any data to ChatGPT, Gemini, Claude, or any other third-party AI service, and does not train any AI model on your data. Inputs and outputs of these models stay on your device unless you choose to share them (for example, sharing a Paper Pom Letter via iOS Share Sheet, in which case the receiving service’s policy governs).

9. iCloud Sync (your iCloud, not ours)

When you are signed in to iCloud and have iCloud Drive enabled, the App uses two Apple-provided mechanisms to keep your pet across your devices: NSUbiquitousKeyValueStore for small preferences and progress, and Apple’s GameSave framework for full save snapshots (“Pom Stasis”). These data live in your iCloud and are governed by Apple’s privacy policy. TRP has no access to them. To disable, sign out of iCloud or turn off iCloud for Pomagotchi in iOS Settings ► [your name] ► iCloud.

10. Analytics

See Section 4.3 above. Analytics can be turned off in Settings ► Privacy ► Anonymous Analytics. We rely on this signal to fix crashes and improve gameplay. We will never use it to identify you, and we have no technical means of doing so. Records are retained for up to 13 months (see Section 19).

11. Feedback Submissions

See Section 4.4 above. When you submit feedback, the information you choose to provide is processed by TRP as a data controller on the legal basis of legitimate interests (responding to your message) under GDPR Article 6(1)(f), or contract / pre-contractual measures under Article 6(1)(b) where applicable. You can request deletion at thomasraypublishing@gmail.com. Adult feedback submissions are retained for up to 24 months after the question is resolved, then deleted.

If you are under 13 in the United States. We do not knowingly accept feedback from users under 13. If you nevertheless contact us through the Feedback form, we will treat any email address you provide under the COPPA “one-time response” exception (16 CFR §312.5(c)(3)): we will use your email address solely to respond to your single inquiry, will not use it for any other purpose, will not add it to any list, will not contact you again, and will permanently delete it from our systems immediately after we reply. If we become aware that feedback was submitted by a child under 13 and contains additional personal information, we will delete the entire submission and notify a parent if a parent contact is available.

12. Subscriptions, In-App Purchases, and Promo / Offer Codes

The “Fluff Society” auto-renewable subscription and the consumable gem packs are sold by Apple through StoreKit 2. Apple processes your payment. TRP never sees your name, email, billing address, payment-method information, or transaction identifiers. The App verifies a receipt on-device only and stores a subscription-status flag locally. Anonymous analytics records the subscription status and tenure in days and counts of IAP events, but not amounts, dates of birth, or receipts.

Promotional / offer codes (currently App Store Connect promo codes, transitioning to Apple Offer Codes on 26 March 2026) are redeemed through Apple. The redemption count appears in anonymous analytics as an integer; the code itself never reaches TRP.

For payment, billing, refunds, and family-sharing questions about subscriptions, please use Apple’s standard channels (Settings ► [your name] ► Subscriptions, or reportaproblem.apple.com).

13. Apple Watch

The Pomagotchi watchOS app reads your step count via HealthKit on the Watch only, read-only, and only to award in-game walk bonuses. Step count is not transmitted to TRP and is not included in anonymous analytics.

14. Spotlight Indexing

The App donates non-sensitive items (such as your pet’s name as it appears in the app, your accessories, and trophy names) to iOS Spotlight so you can search them from the home screen. This index is stored on your device by Apple and is not transmitted to TRP. You can disable Spotlight indexing for the App in iOS Settings ► Siri & Search ► Pomagotchi.

15. Notifications

The App schedules local notifications on your device. We do not operate push servers and do not use Apple Push Notification service for marketing.

16. Children’s Privacy

Pomagotchi is rated 4+ and is intentionally designed to be safe for users of all ages. It is not part of the Apple Kids Category, which means it is intended for a mixed audience rather than aimed exclusively at children.

In line with the U.S. Children’s Online Privacy Protection Act (COPPA) and its 2025 amendments, we do not knowingly collect personal information from any user, including children under the age of 13. We collect no name, email, phone, address, biometric identifier, government identifier, audio recording, photo, video, precise geolocation, or persistent identifier from any user. The only path by which a child user could inadvertently transmit personal information to TRP is by typing it into the Feedback form; that pathway is governed by the COPPA one-time-response exception described in Section 11. If you are a parent and believe a child has provided personal information by typing it into the Feedback form, please email thomasraypublishing@gmail.com and we will delete the submission promptly.

For users in the United Kingdom, we have designed the App to take account of the matters set out in the ICO Age Appropriate Design Code (Children’s Code) as required by the UK Data (Use and Access) Act 2025: privacy-by-default, no profiling, no behavioural advertising, no nudges away from privacy-protective settings, no use of children’s data beyond what we have described above, and clear plain-language disclosure.

For users in California, Connecticut, Delaware, Maryland, Minnesota, New Jersey, New Hampshire, Oregon, and other states with minor-specific protections, we do not sell or share any personal information and do not engage in targeted advertising directed at minors (or anyone else).

17. Your Rights

17.1 We do not sell or share your personal information

Thomas Ray Publishing LLC has never sold or shared personal information of any user, for any purpose, in exchange for any consideration. We do not engage in cross-context behavioural advertising. We do not disclose personal information to third parties for their own marketing purposes. We do not use sensitive personal information for inferring characteristics. There is no “Do Not Sell or Share My Personal Information” toggle inside the App because there is nothing to disable.

17.2 Rights menu

Because we collect no personal information except what you voluntarily submit via the Feedback form, most rights requests will return “we have no information about you.” Where we do hold information you submitted, you have the following rights:

Under EU GDPR and UK GDPR: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), objection (Art. 21), the right to withdraw consent at any time without affecting prior lawful processing, the right to lodge a complaint with your national supervisory authority (in the UK, the ICO at ico.org.uk; in EU member states, the relevant DPA listed at edpb.europa.eu), and from 19 June 2026 under the UK DUAA, the right to complain directly to us.

Under CCPA/CPRA (California): the rights to know, delete, correct, opt out of sale/sharing, opt out of automated decision-making, and limit use of sensitive personal information. As stated in §17.1, we do not sell or share. Even so, you may submit a request and we will respond within 45 days.

Under Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Tennessee, Delaware, New Hampshire, New Jersey, Minnesota, Maryland, Nebraska, Rhode Island, Indiana, Kentucky (and as of 1 July 2026, Arkansas): rights to access, correct, delete, portability, and to opt out of sale, targeted advertising, and profiling. None of these activities occur in Pomagotchi.

Under Quebec Law 25: access, rectification, withdrawal of consent, portability, de-indexation, and to be informed of automated decisions. Quebec residents may request a copy of any personal information we hold about them in a structured, commonly used, machine-readable format (JSON or CSV); we will respond within 30 days as required by Law 25. Our Privacy Officer / Person Responsible for the Protection of Personal Information is Sean Dryden (thomasraypublishing@gmail.com).

Under Brazil LGPD and India DPDPA: equivalent rights of access, correction, deletion, portability, and complaint to the respective supervisory authority.

17.3 How to exercise a right

Email thomasraypublishing@gmail.com. We may need to verify your request to avoid disclosing information to the wrong person; if we have nothing on file, we may verify simply by replying to the email address you provide.

Universal opt-out / Global Privacy Control (GPC): the App makes no sale or share of personal information and does not engage in targeted advertising, so there is nothing for a GPC signal to suppress. The TRP website honours GPC signals where applicable.

18. International Transfers

TRP operates in the United States. Apple’s iCloud and CloudKit data centres are located in multiple jurisdictions; their handling of data is governed by Apple’s privacy policy and Apple’s standard contractual clauses where applicable. Where TRP receives Feedback submissions from users in the EEA, UK, Switzerland, Quebec, or other regions with cross-border-transfer rules, the transfer to the US is justified by your explicit consent in submitting the form, or by necessity for performance of a service you requested (responding to your message). We can provide further information on request.

19. Retention and Deletion Schedule

The matrix below is our written data-retention policy as required by the 2025 amendments to the U.S. COPPA Rule (16 CFR §312.10) and by GDPR Article 5(1)(e). Each row identifies the data category, where it lives, why we hold it, how long, and how it is deleted.

Data category	Where stored	Purpose	Retention	Deletion
On-device gameplay, sensors, and AI outputs	Your device (sandboxed; volatile for sensors)	Core app functionality	Until you uninstall the App; sensor data discarded each session	Uninstall the App, or iOS clears RAM at session end
iCloud Key-Value sync and GameSave saves	Your personal iCloud	Cross-device continuity	Until you delete the data through iCloud or uninstall the App and remove iCloud data	iOS Settings ► [your name] ► iCloud ► Pomagotchi; or icloud.com
Minimised analytics records	TRP CloudKit public DB	App health, bug triage, feature prioritisation	13 months from record creation	Automated server-side purge running daily; records older than 13 months are deleted unconditionally
Adult Feedback submissions (incl. optional name/email/screenshots)	TRP CloudKit private DB	Support response and bug triage	Up to 24 months after the inquiry is resolved	Manual delete by Privacy Officer or earlier on user request to thomasraypublishing@gmail.com
Feedback submissions from users under 13 (COPPA one-time-response exception)	TRP CloudKit private DB	Single response to the user’s inquiry	Deleted immediately after we reply	Manual hard-delete by Privacy Officer at ticket close, with audit log of deletion
Subscription receipts / payment data	Apple — never reaches TRP	Apple billing	Apple’s retention policies	Not applicable to TRP
Crash logs (Xcode Organizer)	Apple — never reaches TRP unless anonymised and aggregated for analytics	Stability	Apple’s retention policies	Not applicable to TRP

We do not retain children’s personal information beyond what is permitted under the COPPA one-time-response exception. We do not retain any data indefinitely under our control.

20. Security

We rely on Apple’s platform security (Secure Enclave, device encryption, Sign in with Apple iCloud security, CloudKit transport encryption) for all data in transit and at rest. TRP-side access to the CloudKit private feedback container is limited to the developer account holder and protected by Apple ID with two-factor authentication. We do not maintain any other systems that hold user information.

Breach notification. In the unlikely event of a personal data breach affecting our private CloudKit container, we will notify affected users without undue delay and report the breach to the relevant supervisory authority where required. For users in the EU/EEA and the UK, we commit to notifying the competent supervisory authority within 72 hours of becoming aware of a notifiable breach, as required by GDPR Article 33 and UK GDPR Article 33. For users in jurisdictions with other timelines (e.g., Quebec Law 25, Brazil LGPD, U.S. state breach laws), we will comply with the applicable statutory timeline.

No system is perfectly secure. If we become aware of a breach affecting personal information, we will notify affected users and relevant supervisory authorities as required by applicable law.

21. Changes to This Policy

We will post any material change to this policy at thomasraypublishing.com/pomagotchi/privacy and, where required, will surface a notice in the App at next launch before the change takes effect. The current version and effective date are shown at the top of this document.

22. Version History

Version	Effective	Summary
1.0	2026-04-15 (approx.)	Initial published policy. Establishes zero-backend architecture disclosures, on-device AI declaration, minimised analytics opt-out, COPPA one-time-response exception for Feedback, 13-month analytics retention, 72-hour breach notification commitment, Quebec 30-day portability commitment, Article 27(2) reliance, unified rights menu.
1.1	2026-05-15	Corrected Privacy Officer name (Sean Dryden); tightened analytics retention to 13 months; converted Section 19 to a structured retention matrix; added COPPA one-time-response exception for Feedback submissions; promoted “Do Not Sell or Share” statement into the TL;DR and Section 17; added 72-hour breach notification commitment; added Quebec 30-day data portability commitment.
1.2	May 16, 2026	Replaced placeholder for EU and UK Article 27 representatives with explicit Article 27(2) exemption assertion grounded in TRP’s actual processing profile (Section 2); added forward reference to the UK DUAA right to complain directly to the controller (Section 2); softened analytics-record characterisation to a defensible pseudonymisation framing that treats analytics as personal data where applicable law requires (Section 4.3).

23. Contact for Privacy Questions

Email thomasraypublishing@gmail.com with “Privacy” in the subject. We will respond within 30 days, or sooner where required by your jurisdiction’s law.

24. Jurisdiction-Specific Notes

• California residents: We do not sell or share personal information; we do not engage in cross-context behavioural advertising; we do not use sensitive personal information; we do not use automated decision-making for significant decisions; we operate no business that meets the CCPA “business” thresholds for 2026.
• Texas residents: Thomas Ray Publishing LLC qualifies as a small business under the U.S. Small Business Administration’s size standards applicable to NAICS 511210 (Software Publishers) and accordingly relies on the small-business exemption in Tex. Bus. & Com. Code § 541.002(b). We do not sell sensitive personal data in any event.
• EEA residents: TRP relies on the GDPR Article 27(2) exemption (see Section 2). Contact thomasraypublishing@gmail.com for any privacy enquiry.
• UK residents: TRP relies on the equivalent UK GDPR Article 27(2) exemption (see Section 2). From 19 June 2026, you have the right to complain directly to us. We design Pomagotchi to take account of the ICO Age Appropriate Design Code as required by the Data (Use and Access) Act 2025.
• Quebec residents: our Person Responsible for the Protection of Personal Information is Sean Dryden (thomasraypublishing@gmail.com). Data portability requests are honoured within 30 days in JSON or CSV.

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