Chapter VI · Privacy

Privacy Policy

Version 2.0.0 · Effective May 16, 2026 · Last updated May 16, 2026

1. Who we are

Thomas Ray Publishing LLC ("TRP", "we", "us", or "our") is a US-based independent software developer registered in Nevada. We publish iOS, iPadOS, macOS, and watchOS apps, illustrated books, art collections, and iMessage sticker packs. For privacy-related questions, reach us at privacy@thomasraypublishing.com. For users in Quebec, the person in charge of personal information protection under Quebec Law 25 is Sean Dryden, reachable at the same address.

2. Scope

This policy covers every Thomas Ray Publishing application distributed on the Apple App Store, the marketing website at thomasraypublishing.com, and any communications you initiate with us by email. Where an individual app has data flows that materially differ from this portfolio-wide policy, those differences are described in the per-app addenda at the bottom of this page.

3. Information we collect — and don't

We do not automatically collect personal information from you. We do not operate any servers or backend services that hold user data. Specifically:

We do not collect names, email addresses, phone numbers, or postal addresses.
We do not collect your location, contacts, calendar, health data, or browsing history.
We do not use advertising identifiers and we do not track you across apps or websites.
We do not use third-party advertising, marketing, or attribution SDKs.
We do not sell, share, rent, or trade personal information with anyone.

3.1 What is stored on your device

Our apps store data locally on your device using Apple's SwiftData, Core Data, and UserDefaults frameworks. The kinds of data stored depend on the app and are detailed in the per-app addenda below, but typically include your preferences, in-app progress, content you authored, and a local diagnostics log.

3.2 Apple services we rely on

The only external services TRP apps use are Apple's own frameworks. Apple's handling of any data routed through these services is governed by the Apple Privacy Policy.

App Store & StoreKit 2. Purchases are processed by Apple. Apple is the controller for payment information, billing address, and Apple Account identifier; TRP receives only the anonymized transaction information Apple provides (transaction IDs, product identifiers, subscription state). We never see your payment details.
CloudKit / iCloud. If you enable iCloud sync, your app data is stored in your iCloud private database. Apple acts as our processor, but Apple cannot read the contents of records in your private database. We do not have access to your iCloud account or its contents. Signing out of iCloud (or disabling iCloud for the app) stops syncing; your local data remains on the device.
Apple Foundation Models / Apple Intelligence. When an app uses on-device generative AI, your prompts and the model's responses are processed entirely on your device using Apple's built-in language model. Your prompts and the generated text are not sent to TRP, to Apple, or to any third party. Apple has stated that user prompts and interactions are not used to train its foundation models.
WeatherKit, MapKit, ARKit, HealthKit, CoreMotion, EventKit, Vision, Speech, Translation. Where used by a specific app, queries and on-device processing run within Apple's frameworks. Anything sent to Apple's servers (e.g., a WeatherKit weather lookup or a MapKit point-of-interest query) is governed by Apple's privacy policy; TRP does not receive or store those results.
Game Center. Where used, leaderboard scores and achievements are submitted to Apple's Game Center. Apple manages your Game Center identity and profile. We do not access your Game Center identity beyond what Apple exposes for leaderboard and achievement functionality.
Anonymous analytics via CloudKit. Some apps send anonymous usage counts to a CloudKit public database we operate. These reports contain no personally identifiable information; details and the opt-out path are in each app's addendum.
Crash reporting via Apple. We do not collect crash reports directly. If you have enabled "Share with App Developers" in iOS Settings > Privacy & Security > Analytics & Improvements, Apple may provide us with aggregated, anonymized crash logs and performance metrics. These reports do not include personal identifiers. You can disable this at any time in iOS Settings.

3.3 No third-party AI services

No TRP app transmits user data to third-party LLM providers (OpenAI, Anthropic, Google, etc.). All generative AI features run entirely on-device using Apple Foundation Models. If a TRP app ever introduces a third-party AI provider in a user-facing flow, this policy and the in-app paywall will be updated to name the provider and obtain explicit consent before any transmission, as required by Apple App Review Guideline 5.1.2(i).

3.4 No third-party SDKs

TRP apps do not integrate third-party advertising, analytics, attribution, marketing, or tracking SDKs. The privacy manifest (PrivacyInfo.xcprivacy) for every app declares NSPrivacyTracking = false and an empty NSPrivacyTrackingDomains array.

4. Sources of data (CCPA)

To the limited extent any personal information enters our possession, it comes from one of two sources: (a) information you voluntarily provide when emailing us or submitting the in-app feedback form (your name and email address, only if you choose to provide them); (b) the anonymized transaction and subscription information Apple provides in connection with App Store purchases.

5. Why we process information — legal bases (EU/UK)

For users in the EU, UK, and other GDPR-aligned jurisdictions, the legal bases under GDPR Article 6 for any processing we perform are:

Contract (Art. 6(1)(b)). The dominant basis. Delivering the app you downloaded, processing the purchase you initiated, and operating the optional iCloud sync you enabled.
Consent (Art. 6(1)(a)). Where an optional feature genuinely transmits data off-device (e.g., anonymous analytics opt-out toggles, or sending us your name/email through the feedback form). Consent is freely given, specific, informed, unambiguous, and revocable.
Legal obligation (Art. 6(1)(c)). Retaining transaction records as required by tax law.
Legitimate interests (Art. 6(1)(f)). Narrow uses such as detecting fraudulent in-app purchase activity. We do not rely on legitimate interests for any novel data flows.

6. Sharing and recipients

We do not sell, share, rent, or trade personal information with third parties. We have no third-party analytics, advertising, or marketing SDKs in our apps. The only "recipients" of any data routed through our apps are Apple's own services (App Store, StoreKit, iCloud, CloudKit, Game Center, Foundation Models) acting under Apple's standard terms, as described in §3.2. We do not disclose personal information to third parties for targeted advertising under any state privacy law.

7. International transfers

TRP is in the United States. If you are outside the US, by using our apps your data is processed in the US. For users in the EU, UK, and Switzerland, transfers rely on Apple's safeguards as the underlying service provider, including Apple's Standard Contractual Clauses and adherence to the EU-US Data Privacy Framework where applicable. We do not separately transfer your data to any other international destination.

8. Retention

Data stored on your device is retained until you delete it or uninstall the app. We do not hold copies on our servers because we do not have servers that process your data. Email correspondence and feedback-form submissions are retained for as long as needed to respond to your request and then deleted, typically within 12 months. Anonymous analytics records contain no personal identifiers and are retained as long as they remain useful for product improvement.

9. Security

Data on your device is protected by Apple's app sandbox and the device's file-system encryption, which is tied to your device passcode. Data in iCloud private databases is encrypted in transit and at rest under Apple's controls. We follow Apple's secure-coding guidance, use Swift's memory-safe types by default, and harden subscription receipt and entitlement checks via StoreKit 2. No system is perfectly secure; we encourage you to keep your device's operating system up to date.

10. Your rights

10.1 If you are in the EU, UK, EEA, or Switzerland

Under the EU GDPR and UK GDPR, you have the right to:

Access the personal data we hold about you.
Rectify inaccurate data.
Erase your data ("right to be forgotten").
Restrict our processing of your data.
Port your data to another service in a structured, commonly used, machine-readable format.
Object to processing based on legitimate interests.
Withdraw consent at any time where consent is the legal basis.
Not be subject to a decision based solely on automated processing, including profiling (we do not perform such processing).
Lodge a complaint with your supervisory authority — in the UK, the Information Commissioner's Office (ICO); in the EU, your national data-protection authority.

Because our apps store your data on your own device and in your own iCloud account, the right to access is largely satisfied by the device itself. Where you need our help, email privacy@thomasraypublishing.com and we will respond within 30 days.

10.2 If you are in California (CCPA / CPRA)

Under the California Consumer Privacy Act as amended by the CPRA, you have the right to:

Know what categories of personal information we collect, the sources, the business purposes, and the categories of third parties to whom we disclose it (the answer for nearly all categories is: we do not collect it; see §3).
Delete personal information we have collected about you.
Correct inaccurate personal information.
Opt out of the "sale" or "sharing" of your personal information — we do not sell or share personal information, and we have no "Do Not Sell or Share My Personal Information" link because there is nothing to opt out of.
Limit our use of sensitive personal information — we do not collect any sensitive personal information.
Non-discrimination for exercising any of these rights.
Designate an authorized agent to submit requests on your behalf.

To exercise these rights, email privacy@thomasraypublishing.com. We respond within 45 days, extendable by 45 days where reasonably necessary.

10.3 If you are in another US state with a comprehensive privacy law

Residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and Washington have rights similar to the California rights above under their respective state laws. We honor Global Privacy Control (GPC) signals on our marketing website.

10.4 If you are in Quebec, Brazil, India, or another jurisdiction with comparable protections

You retain the access, rectification, deletion, and portability rights granted by Quebec Law 25, Brazil's LGPD, India's DPDPA, and analogous regimes. Direct requests to the email above. For Quebec, our person in charge of personal information protection is Sean Dryden.

11. Children's privacy

Our apps are general-audience entertainment and productivity products. They are not directed to children under 13 within the meaning of the US Children's Online Privacy Protection Act (COPPA), as amended by the 2025 FTC COPPA Rule Amendments. We do not knowingly collect personal information from children under 13. Because our apps do not collect personal information from anyone, no COPPA-triggering data ever enters our possession. Where an app is "likely to be accessed" by minors under the UK Age Appropriate Design Code or the California Age-Appropriate Design Code, we maintain privacy-by-default settings, do not include behavioral advertising or tracking, and do not deploy nudge techniques toward weaker privacy choices.

If you believe a child has provided personal information to us through email or the in-app feedback form, contact kids-privacy@thomasraypublishing.com and we will delete it promptly.

12. Cookies and similar technologies

Our apps do not use cookies. Our marketing website sets no non-essential cookies and uses no advertising, marketing, or analytics pixels. Because we set only strictly necessary cookies (if any), no cookie banner is required under GDPR/ePrivacy or CCPA. If we ever introduce analytics on the marketing site, it will be a cookieless option (e.g., Plausible, Fathom, or Cloudflare Web Analytics) and this policy will be updated.

13. Automated decision-making

We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on you. Recommendation features inside the apps (e.g., suggested actions in Pomagotchi, suggested expense categories in Colophon) are advisory only and run entirely on-device.

14. Right to lodge a complaint

If you believe we have violated your privacy rights, please contact us first so we can resolve the issue. You also have the right to lodge a complaint with the supervisory authority for your jurisdiction — for example, the UK ICO (ico.org.uk), the California Privacy Protection Agency (cppa.ca.gov), the Quebec Commission d'accès à l'information (cai.gouv.qc.ca), or your national EU data-protection authority.

15. Changes to this policy

We may update this policy as our apps evolve or as regulations change. Material changes will be announced in-app at the next launch and in the changelog below. The version number and effective date at the top of this page reflect the current text.

Change log. v2.0.0 (May 16, 2026): Full overhaul against the TRP Privacy Policy & App Privacy Standards Reference. Consolidated three per-app policies into a single portfolio policy with per-app addenda. Added plain-language summary, GDPR rights enumeration, US state-law rights, Quebec/LGPD/DPDPA notes, Apple Foundation Models language, no-third-party-AI commitment, privacy manifest disclosure.

16. Contact

Thomas Ray Publishing LLC
InCorp Services, Inc.
2360 Corporate Circle, Suite 400
Henderson, NV 89074-7722
Privacy: privacy@thomasraypublishing.com
General: thomasraypublishing@gmail.com
Web: thomasraypublishing.com

Per-App Addendum: Pomagotchi

Effective May 16, 2026

Pomagotchi is a virtual Pomeranian companion app for iOS, iPadOS, watchOS, and macOS. This addendum supplements the portfolio policy above with Pomagotchi-specific data flows.

Data stored on your device

Your pet's name, stats, age, personality, and progress.
Mini-game high scores, trophy achievements, and XP/level/badge data.
Dog-show competition entries, results, qualifications, season progress, and prestige count.
Pom Coin balance, purchased items, and the Show Wardrobe and Closet contents.
Accessory ownership, equipped accessories, and seasonal expiry dates.
Redeemed promotional-code hashes (one-way hashed; not reversible to the original code).
App preferences (sound, haptics, notifications, AI dialogue, iCloud sync, analytics).
Local diagnostic logs (event counts and session info).
Photos saved within the Photo Album and exported Trading Card images.

Location services

With your permission, Pomagotchi uses your device's location to detect your environment (home, café, gym, beach, downtown, library, train, airplane, etc.) so your pet can react to where you are. Location data is processed and stored entirely on your device and is never transmitted to TRP. The app queries Apple's MapKit for nearby points of interest to recognize your surroundings; those queries are sent to Apple's servers and are governed by Apple's privacy policy. Venue names returned by MapKit are used on-device only to personalize dialogue, status messages, and dream stories. The app also uses GPS speed and altitude (processed on-device) to detect transit modes. Location is sent to Apple's WeatherKit for current weather conditions. Revoke location access any time in Settings.

Camera, AR, and photos

The Teleport (AR) feature uses your device camera to place your pet in augmented reality. Camera data is processed in real time on-device and is never recorded or transmitted. The Photo Booth feature saves screenshots to the app's private storage; you can optionally export them to your Photo Library.

Motion and activity

Pomagotchi uses CoreMotion to detect shakes for playful interactions and to count daily steps for walk bonuses. All motion and pedometer data is processed entirely on your device and never leaves it. On Apple Watch, the companion app reads your step count from HealthKit (with your permission) to trigger walk bonuses; this data also stays on-device.

iCloud sync (default ON)

Pomagotchi syncs your pet's progress, saved poms, coin balance, trophies, leveling data, competition data, and show wardrobe items across your Apple devices using Apple's iCloud Key-Value Storage. Your data is stored in your personal iCloud account; we cannot access it. Toggle iCloud Sync off in Settings to stop future syncing.

Game Center

Pomagotchi integrates with Apple Game Center for leaderboards and achievements. Your scores and achievement progress are submitted to Apple's Game Center and may be visible to other Game Center users depending on your Game Center privacy settings.

On-device AI (Apple Foundation Models)

On supported devices, Pomagotchi uses Apple's Foundation Models framework to generate personalized dialogue, dream stories, journal entries, and notification messages for your pet. All AI processing happens entirely on your device using Apple's built-in language model; no text is sent to TRP, to Apple, or to any third party. AI dialogue features can be disabled in Settings.

On-device translation

When your device language is not English, Pomagotchi can translate AI-generated dialogue, status messages, dream stories, and care tips into your language using Apple's Translation framework. All translation happens on-device using downloaded language models.

Notifications

With your permission, Pomagotchi sends local notifications about your pet's needs. Notifications are scheduled entirely on-device; no push-notification servers are involved. Notification content is personalized based on your pet's personality, current weather, environment, and on-device behavioral history. All behavioral data and timing models remain on-device.

Anonymous analytics (default ON)

Pomagotchi sends an anonymous usage report to our secure cloud database (Apple CloudKit) at most once every 24 hours. Reports include: app version, iOS version, device model, screen dimensions, language/locale, anonymous session count, days since first launch, days active in the last 7 and 30 days, pet age, pet variant, aggregated action counts, game play counts and recent scores, error summaries, feature toggles, subscription status and tenure, in-app purchase event counts, promo codes redeemed, daily streak, trophy count, crash-free session rate, memory warning counts, whether an Apple Watch is paired, and whether widget data is active.

Reports do NOT include: your name, Apple ID, email, location, pet name, IP address, or any other personally identifiable information. Each install is assigned a random identifier for deduplication only. Disable anytime in Settings under "Share Anonymous Analytics."

Required-reason APIs

Pomagotchi's PrivacyInfo.xcprivacy declares NSPrivacyAccessedAPICategoryUserDefaults (CA92.1), NSPrivacyAccessedAPICategoryFileTimestamp (C617.1), NSPrivacyAccessedAPICategoryDiskSpace (E174.1), and NSPrivacyAccessedAPICategorySystemBootTime (35F9.1). NSPrivacyTracking is false.

Per-App Addendum: The Device — Cosmic Pyramid

Effective May 16, 2026

The Device is a mystical entertainment app for iOS. This addendum supplements the portfolio policy above with Device-specific data flows.

Data stored on your device

Daily prediction count (resets each day) and purchased prediction balance.
Total lifetime prediction count and in-app purchase transaction IDs (for deduplication).
Saved prediction images and reading history (stored as files, capped at 50 readings).
Cached daily horoscope message and recent prediction values (for diversity tracking).
User preferences (sound, haptics, notifications, Enhanced Awareness).
Optional birth date — stored locally to personalize readings through zodiac and numerology calculations; never transmitted.
Streak and milestone tracking; subscription status and redemption code activation date.
Widget data (shared via App Group for home-screen widget display).
Local diagnostic logs.

Location and weather

The Device may optionally request your location to retrieve local weather conditions via WeatherKit. The permission is optional — deny it and the app functions normally. When granted, your location is sent only to Apple's WeatherKit; weather is used to flavor prediction narratives; your location is never stored, logged, or transmitted to TRP.

On-device AI (Apple Foundation Models)

The Device uses Apple's on-device Foundation Models extensively to personalize your experience: creative prediction options, narrative intros, reading summaries, mystical reasons for lucky numbers, peril prompts, personalized notification messages, enhanced Siri responses, and reflective commentary on past readings. All AI processing occurs entirely on your device. No prompts, inputs, or outputs are transmitted to any external server. AI Predictions can be disabled in Settings.

Saved prediction images

When you save a prediction reading, an image is rendered and stored in the app's local Documents directory. Sharing through the iOS share sheet is handled entirely by the operating system; TRP does not have access to shared images or their destinations.

Notifications, Siri, Live Activities, widget

Local notifications, Siri Shortcuts, Live Activities, and the home-screen widget all run entirely on-device. No notification data, voice data, or intent data is transmitted to TRP or any third party.

Anonymous analytics (default ON)

The Device sends an anonymous usage report to Apple's CloudKit at most once every 24 hours. Reports include: app version, iOS version, device model, screen dimensions, language/locale, anonymous session count, total readings count, current and longest streaks, subscription and redemption status, purchased prediction count, feature toggle states, AI model availability, engagement counts, onboarding status, free readings remaining, purchase event count, attunement completion rate, average reading interval, most frequent prediction category, device language, sound cache performance, AI generation speed, days since install, session duration, paywall views, time-of-day usage patterns, Apple Watch companion app usage, and error summaries.

Reports do NOT include: your name, Apple ID, email, location, IP address, or any other personally identifiable information. Each install is assigned a random identifier for deduplication only. Disable anytime in Settings under "Share Anonymous Analytics."

Required-reason APIs

The Device's PrivacyInfo.xcprivacy declares NSPrivacyAccessedAPICategoryUserDefaults (CA92.1), NSPrivacyAccessedAPICategoryFileTimestamp (C617.1), NSPrivacyAccessedAPICategoryDiskSpace (E174.1), and NSPrivacyAccessedAPICategorySystemBootTime (35F9.1). NSPrivacyTracking is false.

Per-App Addendum: Colophon

Effective May 16, 2026

Colophon is a business-management application for independent publishers, authors, and small creative businesses (iOS, iPadOS, macOS). This addendum supplements the portfolio policy above with Colophon-specific data flows.

Data stored on your device

Expense records (merchant, amount, date, category, notes, receipt images).
Mileage trip logs (origin, destination, distance, purpose).
Business documents (files, tags, categories, expiration dates).
Business activities and calendar-event references.
Journal entries (text, voice transcriptions, attendees, action items).
Book titles and royalty records from publishing platforms.
Revenue tracking data by book and platform.
Funding-account records (display name, institution name, optional last-four digits, payment-method type).
Capital contributions and tax-basis calculations.
App preferences and local diagnostic logs.

Funding accounts and financial data

Colophon does not connect to any bank, access account balances, or process financial transactions. Funding-account records store only a display name, institution name, optional last-four digits, and payment-method type. Capital-contribution and tax-basis calculations run entirely on your device.

Location services

With your permission, Colophon uses your device's location for mileage-trip detection and address-based distance calculations. Location data is processed and stored entirely on-device; it is used only for mileage logging and IRS deduction calculations.

iCloud sync

Colophon syncs your business data across your Apple devices using Apple's NSPersistentCloudKitContainer. Your data is stored in your iCloud private database, encrypted, and not accessible to us. Sync covers expenses, trips, documents, activities, journal entries, royalty records, and funding-account data.

Calendar integration

With your permission, Colophon reads events from Apple Calendar (via EventKit) to link business activities to calendar entries. Calendar data is read and cached on-device. Colophon may create new events when you explicitly request it; it does not modify or delete existing events without your action.

Camera, photos, OCR

Colophon uses your camera to capture receipt images and Apple's Vision framework to perform on-device OCR for merchant, amount, and date. All image processing happens entirely on-device.

Voice recording and transcription

The Voice-to-Journal feature uses Apple's Speech framework to transcribe voice recordings on-device. Audio is not stored permanently unless you save the transcription as a journal entry.

On-device AI (Apple Foundation Models)

Colophon uses Apple's on-device Vision, NaturalLanguage, and Foundation Models for receipt OCR, expense categorization, journal entity extraction, and natural-language business queries. All AI processing happens entirely on-device. No prompts, inputs, or outputs are transmitted.

Anonymous analytics (default OFF — opt-in)

Unlike Pomagotchi and The Device, Colophon's anonymous analytics are disabled by default and require your explicit opt-in. When enabled, the app sends an anonymous usage report to Apple's CloudKit at most once every 24 hours. Reports include: app version, iOS/macOS version, device model, screen dimensions, language/locale, anonymous session count, feature usage counts (number of expenses, trips, documents, journal entries), entity counts, sync health status, subscription status, and crash-free session rate.

Reports do NOT include: your name, Apple ID, email, location, business data, financial figures, merchant names, document contents, IP address, or any other personally identifiable information. Each install is assigned a random identifier for deduplication only. Enable or disable in Settings under "Share Anonymous Analytics."

Required-reason APIs

Colophon's PrivacyInfo.xcprivacy declares NSPrivacyAccessedAPICategoryUserDefaults (CA92.1), NSPrivacyAccessedAPICategoryFileTimestamp (C617.1 and DDA9.1 for receipt-image timestamp display), NSPrivacyAccessedAPICategoryDiskSpace (E174.1), and NSPrivacyAccessedAPICategorySystemBootTime (35F9.1). NSPrivacyTracking is false.