Privacy Policy

Formal Privacy Policy

Last Updated: November 2025

1. Introduction

Deer Santa App (a Working Labs LLC app, "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains our practices regarding the collection, use, and disclosure of information when you use our mobile application.

2. Information We Collect

Short answer: Minimal technical data only.

Deer Santa collects the following limited information:

• Technical Performance Data: We collect CPU usage, memory usage, and crash reports through iOS system APIs. This data is used solely to diagnose technical issues, improve app stability, and fix bugs. This data is anonymous and cannot be used to identify individual users.
• Optional Parent Email: If you voluntarily provide a parent email address, we use it exclusively for customer support communications. This is completely optional and not required for any app functionality.

All content created within the application, including wishlists, letters, photos, and notes, is stored locally on your device and is never transmitted to our servers or any third-party services.

3. How We Use Information

We use the collected information for the following purposes:

• Technical Performance Data: To identify and fix crashes, optimize app performance, and improve overall stability
• Optional Parent Email: To respond to support requests and communicate about technical issues if you contact us

We do not use any information for advertising, marketing, behavioral tracking, or any purpose beyond maintaining app functionality. Your wishlist content, letters, and other personal content remain exclusively under your control on your device.

4. Data Sharing and Third Parties

We do not share, sell, rent, or trade any user information with third parties. The minimal technical data we collect is used exclusively for internal app improvement purposes. There are no third-party analytics, advertising networks, or marketing data processors integrated into our application.

Browse Online Stores Feature: Deer Santa includes an optional "Browse Online Stores" feature that allows users to view products from third-party retailers (such as Amazon, Target, and others) to help create wishlists. When using this feature:

• You are accessing these retailers' websites through in-app web browsing
• We maintain a curated list of family-friendly retailers that users can access through the app. View the complete list of allowed stores
• These retailers have their own privacy policies, tracking, and advertising practices that apply when you visit their sites
• We attempt to extract product information for wishlist purposes, but this feature may not work on all sites or items and may only partially extract information
• We offer no warranty of any kind regarding this feature's functionality or accuracy
• For children under 13, the app presents a Parent Gate challenge that an adult must complete before the child can use the browsing feature, ensuring parental awareness and supervision
• We do not collect or track what items you view or add to wishlists from these stores
• This feature is completely optional—users can create wishlists without using it

5. File Sharing

Deer Santa allows users to share wishlists using your device's native file sharing capabilities (such as AirDrop, Messages, Email, etc.). When you share a wishlist:

• A file is created locally on your device containing your wishlist data
• This file is shared directly from your device to the recipient(s) you choose
• We do not facilitate, monitor, or have access to these sharing transactions
• The sharing process uses your device's operating system capabilities, subject to Apple's privacy policies

6. Children's Privacy (COPPA Compliance)

Deer Santa is designed to be safe for users of all ages, including children under 13. We comply with the Children's Online Privacy Protection Act (COPPA) by:

• Collecting only minimal technical performance data that is anonymous and cannot identify individual users
• Not collecting any personal information from children
• Using a Parent Gate challenge before children under 13 can access the "Browse Online Stores" feature, ensuring a parent or guardian is present when children access third-party retailers with their own privacy policies
• Keeping all wishlist and letter content stored locally on the device under parental control

7. Data Security

We take reasonable measures to protect the minimal technical data we collect. The technical performance data collected through iOS system APIs is transmitted and stored securely. Since wishlist and letter content remains on your device, the security of that information is determined by your device's security settings and practices. We recommend:

• Using a strong device passcode or biometric authentication
• Keeping your device's operating system updated
• Being cautious when sharing wishlists with others
• Regularly backing up your device to prevent data loss

8. Data Retention

Technical performance data is retained only as long as necessary to diagnose and resolve app issues, typically no longer than 90 days. Optional parent email addresses are retained until you request deletion. Wishlist and letter content stored on your device remains there until you delete it within the app or uninstall the application.

9. Advertising

Deer Santa does not display any advertisements or use any advertising networks within the app itself. We do not generate revenue from user data or advertising. However, when using the optional "Browse Online Stores" feature, you may encounter advertisements on third-party retailer websites, which are subject to those retailers' own advertising policies.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be reflected on this page with an updated "Last Updated" date. Our commitment to minimal data collection and not collecting personal information will remain unchanged. Continued use of the application after any changes constitutes acceptance of the updated Privacy Policy.

11. Your Rights

You have the following rights regarding your data:

• Access: You may request information about the technical performance data we collect (available upon request)
• Deletion: You may request deletion of any optional parent email provided to us
• Local Data Control: You maintain complete control over wishlist and letter content, which you can delete at any time by removing items within the app or uninstalling the application

To exercise these rights, please contact us through our contact page.

12. International Users

Deer Santa is launching in the USA, we are working on adding support for other countries. The minimal technical performance data we collect may be transmitted to and stored on servers in the United States. By using the app, you consent to this transfer. Because we do not collect personal information beyond optional email addresses, cross-border data transfer concerns are minimal.

13. Contact Information

If you have any questions about this Privacy Policy or our privacy practices, please contact us through our contact page.

14. California Privacy Rights

For California residents: Under the California Consumer Privacy Act (CCPA), you have certain rights regarding your personal information. The minimal technical performance data we collect is anonymous and cannot be used to identify you. If you provide an optional parent email, you have the right to request deletion of that information. We do not sell personal information.

15. European Union Users (GDPR)

For users in the European Union: We respect all rights granted under the General Data Protection Regulation (GDPR). The technical performance data we collect is processed for the legitimate interest of maintaining app functionality and stability. This data is anonymous and does not constitute personal data under GDPR. Optional parent email addresses, if provided, are processed with your consent for customer support purposes. You have the right to access, rectify, erase, restrict processing, and data portability regarding any email address you provide.

This privacy policy is designed to be transparent and easy to understand. If you have any questions, please don't hesitate to contact us.