SpheraH Privacy Principles

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Our approach to privacy and security for Taming the Inner Dragon is guided by the following core principles:

• Safety First: We are committed to creating a secure and supportive digital environment for children to explore their emotions.

• Data Minimization: We collect only the minimum data necessary to provide a meaningful and personalized experience.

• Sensitive Data Protection: We recognize that emotional regulation data is sensitive and treat it with heightened care and security.

• No Sale of Data: We never sell personal information to third parties.

• Ad-Free Experience: We do not use advertising or behavioral tracking for monetization.

• Ethical Design: We do not use manipulative design patterns (“dark patterns”) to increase engagement.

• Youth Protection: We are designed to comply with applicable children’s privacy laws, including COPPA and relevant global standards.

1. Introduction

SpheraH Ltd. ("SpheraH", "we", "us", or "our") is committed to protecting the privacy of children and their families.

This Privacy Policy explains how we collect, use, store, and protect information in connection with:

• The Taming the Inner Dragon mobile application

• The SpheraH website
  (collectively, the "Service")

2. Important Medical Disclaimer

Taming the Inner Dragon is designed to support emotional resilience and regulation.
It is not a replacement for professional therapy, clinical diagnosis, or medical treatment.

3. Information We Collect

We follow a strict data minimization approach.

3.1 Information Provided by Parents/Guardians

• Account Information: Parent email address and child’s birth month/year

• Parental Consent Data: Email verification and parental gate interactions

• Subscription Data: Managed by third-party platforms (e.g., Apple App Store, Google Play). We do not store payment details.

3.2 Information Generated Within the App

• Progress Data: Activities used (e.g., breathing exercises, regulation tools)

• Emotional Check-ins: Emoji or structured selections describing feelings

👉 We do not collect:

• Free-text inputs from children

• Full names, addresses, or school information

3.3 Information Collected Automatically

• Device Information: Device type, OS version

• Usage Data: Feature usage patterns (non-identifiable where possible)

4. Sensitive Emotional Data

We recognize that emotional check-ins may reflect sensitive information.

This data is:

• Used only to support the child’s experience

• Never used for advertising

• Never sold

• Stored securely with restricted access

5. How We Use Information

We use collected data to:

• Support Emotional Growth: Personalize content and recommendations

• Improve the Service: Analyze aggregated and de-identified data

• Communicate with Parents: Provide updates, support, and account-related notices

6. Legal Basis for Processing (GDPR)

Where applicable, we rely on:

• Parental Consent (primary basis)

• Performance of the Service

• Legitimate Interest (for improving the app using de-identified data)

7. Special Protection for Children (Ages 4–10)

We implement enhanced safeguards:

• Parental Consent Required before account activation

• Limited Data Collection by design

• No Behavioral Advertising

• No Social Sharing Features

• Internal Use Only for any service providers

8. How Information Is Shared

We do not share personal or emotional data for marketing.

We only share data:

• With Consent: e.g., exporting reports to a parent, teacher, or therapist

• With Service Providers: Contractually bound partners (e.g., hosting, analytics)

• For Legal Obligations: When required by law

9. Data Retention

We retain personal data only as long as necessary to provide the Service.

• Active accounts: Data retained while account is in use

• Inactive accounts: Data may be deleted after [12–24 months] of inactivity

• Parents may request deletion at any time

10. Data Storage and International Transfers

Data may be stored and processed on secure servers located in jurisdictions such as:

• [Insert: e.g., EU / United States / Israel]

We implement appropriate safeguards for international data transfers in accordance with applicable laws.

11. Your Rights and Choices

Parents/guardians have the right to:

• Access: Review collected data

• Correction: Request updates

• Deletion: Request full data deletion

• Portability: Request a summary of child progress data

• Withdraw Consent: At any time

To exercise these rights, contact us at:
📧 [Insert Support Email]

12. Account Deletion

You may delete your account through the app or by contacting us.
Upon deletion, all associated personal and emotional data will be removed, subject to legal obligations.

13. Security

We implement industry-standard security measures, including:

• Encryption in transit (TLS) and at rest

• Access controls and role-based permissions

• Secure cloud infrastructure providers

• Ongoing monitoring and security practices

14. Data Breach Response

In the unlikely event of a data breach, we will notify affected users and relevant authorities as required by applicable law.

15. Verifiable Parental Consent & Account Creation

Insert this after your "Information from Children" section to explain exactly how you ensure a parent is in control.

Verifiable Parental Consent To comply with the U.S. Children’s Online Privacy Protection Act (COPPA) and international regulations, SpheraH requires verifiable parental consent before a child under the age of 13 can access certain features of "Taming the Inner Dragon." We use a "Parental Gate" and email verification process designed to ensure that the person granting consent is indeed the child’s parent or legal guardian. We do not condition a child’s participation in any activity on the disclosure of more personal information than is reasonably necessary.

16. Mandatory Technical Collection Notice

Insert this near your "Information We Get Automatically" section to provide the "delete the app" legal shield.

Notice Regarding Automatic Collection Our App and Website use technology to automatically collect certain technical information (such as IP addresses, device identifiers, and usage logs) necessary to provide a stable and secure experience. This data is used solely for internal operations and to improve the emotional regulation tools we provide. By downloading, registering with, or using "Taming the Inner Dragon," you agree to this automatic collection of technical data. If you do not agree with these practices, you should not download the App or continue to use our Website.

17. Third-Party Platforms & App Stores

Insert this to clarify where your responsibility ends and Apple/Google begins.

Third-Party App Store Collection "Taming the Inner Dragon" is distributed through third-party platforms such as the Apple App Store and Google Play Store. When you purchase or download the App, these third parties may collect account-related information, device identifiers, or payment details according to their own privacy policies. SpheraH does not control, and is not responsible for, the tracking technologies or data practices of these third-party platforms. We encourage you to review their respective privacy policies before downloading.

18. Successor in Business (Mergers & Acquisitions)

Insert this at the end of your "How Information is Shared" section.

Business Transfers and Successors In the event that SpheraH is involved in a merger, acquisition, reorganization, or sale of assets, your information—including any data provided for "Taming the Inner Dragon"—may be transferred as part of that transaction. We will notify you via the email address associated with your account or through a prominent notice on our website at least 30 days before any such transfer takes place, outlining your choices regarding your data at that time.

19. Updates to This Policy

We may update this Privacy Policy from time to time.
We will notify parents of significant changes via email or within the app.

20. Contact Information

SpheraH Ltd.
kibbutz Bror-Hayil 210
Israel

📧 Support: spherahealth@spherah.com