Privacy Policy (EU Alpha Version)

Effective Date: January 24, 2026

Data Controller: OctyByte UG

Contact Email: info@octybyte.,om

Address: Gruener Weg 32, Cologne, Germany

1. Introduction

This Privacy Policy explains how FlowLexia handles data during our closed alpha testing phase in the European Union. This app is designed for children under 12 and includes a Supervisor Mode for parents or authorized professionals (e.g., therapists).

2. Legal Basis for Processing (GDPR Art. 6 & 9)

We process data based on Explicit Consent provided by the holder of parental responsibility. Because our app involves progress monitoring that may be used in a therapeutic context, we treat this as "Special Category Data" under GDPR Article 9, ensuring the highest level of technical protection.

3. Data We Collect & How We Use It

We follow the principle of Data Minimization. We only collect what is strictly necessary for the app to function:

• Fantasy Nicknames: Chosen by the user to avoid storing legal names.

• Progress Logs: Information regarding game interactions and milestones for therapy/supervision.

• Supervisor Credentials: A local password set by the parent/professional to protect the supervisor dashboard.

4. 100% Local Storage & Encryption

No data is transmitted to our servers. All information, including nicknames and progress logs, is stored locally on your device in an encrypted database.

• We do not use cloud backups.

• We do not use advertising identifiers (AAID) or tracking SDKs.

5. Supervisor & Professional Access

The app includes a password-protected dashboard. This allows a Parent or an authorized Professional (Therapist) to review progress. The Parent is the "Primary Controller" of the device and is responsible for authorizing access to this dashboard.

6. Data Retention & Deletion (Your Rights)

Under the GDPR, you have the right to access, rectify, or erase your data.

• Deletion: Because all data is stored locally, you can exercise your "Right to be Forgotten" by uninstalling the app or clearing the app’s data in your Android settings. This action permanently deletes all stored progress and nicknames.

• Access: You can view all stored data at any time through the Supervisor Dashboard.

7. Third-Party Processors

In this Alpha version:

• No Third Parties: We do not share data with any third-party analytics, advertisers, or service providers.

8. Complaints

If you have concerns about our data practices, you have the right to lodge a complaint with your local Data Protection Authority (DPA) within the EU.