ScrollKeeper privacy policy.

1. Who we are

This Privacy Policy applies to the iOS app ScrollKeeper, a single-player Bible-knowledge trivia game published by Kraft Digital Limited, a New Zealand company. We are based in New Zealand, so this policy is governed primarily by the Privacy Act 2020 (NZ) and its Information Privacy Principles (IPPs), including IPP 3A (in force 1 May 2026). We also address the requirements of Australia, the United States, the European Economic Area, and the United Kingdom in section 6.

2. Our core commitment: we collect no personal data

ScrollKeeper does not collect, transmit, store, or share any personal data. This is a true description of how the App works, not a generic disclaimer. Specifically, the App:

• does not collect your name, email address, phone number, or any contact information;
• does not collect your device identifier, advertising identifier (IDFA), IP address, or any persistent identifier;
• does not use analytics software, crash-reporting tools, or any third-party SDK;
• does not use cookies, tracking pixels, or fingerprinting;
• does not collect location data;
• does not have user accounts, login, or registration;
• does not allow user-generated content, chat, or social features;
• does not display advertisements of any kind;
• makes no network connections for gameplay and works entirely offline;
• contains no external links except to our own website and to this policy and the Terms of Use.

This is reflected in the App's Apple Privacy Manifest, which declares no tracking and no collected data types.

Because we collect no personal data, most standard obligations under privacy law (such as access rights, correction rights, retention schedules, and breach notification) do not arise in practice. We explain this for each region in section 6.

3. Information stored on your device

To make the game work, the App saves the following only on your device, using Apple's standard on-device storage (iOS UserDefaults):

• your selected hero and game progress (levels, stars, streaks, completed worlds);
• in-game token balances and unlocked achievements;
• your settings (such as sound and haptics preferences) and which one-time tips you have seen;
• a local record that an in-app purchase has been unlocked.

This information never leaves your device, is not accessible to us, and is removed if you delete the App. We cannot see it or recover it for you. If you have iCloud Backup switched on, iOS may include this on-device data in your device backup; that backup is managed by Apple under Apple's own privacy policy, not by us.

4. In-app purchases and Apple's role

ScrollKeeper offers one optional in-app purchase, "The Full Journey", a one-time non-consumable purchase that unlocks all content and all heroes. Cosmetic frames can also be unlocked using in-game tokens earned through play (tokens cannot be bought with real money).

All payments are processed by Apple through the App Store. We never receive, see, access, or store your payment-card details, billing address, or any financial information. Apple may collect and process your account and payment information when you make a purchase; that processing is governed by Apple's Privacy Policy at https://www.apple.com/legal/privacy/. We receive only anonymised, aggregate sales reports from Apple (for example, total units sold by region), which do not identify you.

You can restore a previous purchase at any time using Restore Purchases in the App, which asks Apple to confirm your entitlement using your Apple Account. We do not see your Apple Account. Refunds are handled solely by Apple (see the Terms of Use).

5. Children's privacy

ScrollKeeper is rated 4+ and is suitable for all ages, including children under 13.

Because the App collects no personal data from anyone, it collects no personal data from children. We do not knowingly solicit, collect, use, or disclose personal information from children or anyone else.

Parents and guardians: you do not need to take any action to protect your child's privacy when they use ScrollKeeper. The App shows no advertisements, has no chat or social features, and sends no data off the device. The only way a child can incur a charge is through an in-app purchase, so we recommend using Apple's Screen Time / parental controls to manage purchase permissions. If you believe your child has somehow provided personal information through the App (for example, through a bug), contact us at hello@kraftdigital.co.nz and we will investigate and take prompt corrective action.

6. How this applies in your region

New Zealand (Privacy Act 2020). The Act and its Information Privacy Principles (IPPs 1 to 13, including IPP 3A on indirect collection, in force 1 May 2026) govern how agencies collect, use, store, and disclose personal information. Because we collect no personal information, the IPPs impose no substantive data-handling obligations on us in connection with the App. If we ever introduce a feature that collects personal information, we will update this policy and comply with the direct and indirect collection notice requirements before that feature is released.

Australia (Privacy Act 1988 and the Australian Privacy Principles). The APPs govern entities that handle personal information. As we handle no personal information in connection with the App, the APPs do not arise in practice, regardless of any small-business threshold.

United States (COPPA and CCPA/CPRA). COPPA applies to child-directed services that collect personal information from children under 13. Because ScrollKeeper collects no personal information from anyone, including no persistent identifiers, device IDs, IP addresses, geolocation, or behavioural data, COPPA's notice, consent, and deletion obligations are not triggered. This is a permanent design choice, not merely a statement. Under the CCPA/CPRA, we do not collect, sell, or share personal information, so the associated California rights have no practical content here, and we do not sell personal information.

European Economic Area (GDPR). The GDPR applies where personal data is processed. We process no personal data from App users, so the GDPR's obligations (lawful basis, data-subject rights, records, DPO appointment) do not apply to the App. The children's provisions in Article 8 concern consent for processing a child's data; as we do not process data or rely on consent, Article 8 does not apply.

United Kingdom (UK GDPR, Data Protection Act 2018, and the ICO Age Appropriate Design Code). Like the EU GDPR, the UK GDPR applies where personal data is processed; we process none. The ICO's Children's Code applies to services likely to be accessed by children that process personal data; because we process none, its data-protection design standards do not apply. Even so, the App's design already reflects the Code's spirit: no profiling, no tracking, no geolocation, no nudge techniques, no targeted advertising, and privacy-protective defaults throughout.

7. Third-party services

We integrate no third-party SDKs, analytics services, advertising networks, or social plugins. The App is distributed through the Apple App Store, and Apple's platform may collect certain data about your device and App Store usage as part of its normal operations, governed by Apple's Privacy Policy. The only external links in the App point to our own website and to this policy and the Terms of Use.

8. Security

Although we collect no personal data, we keep the App's design simple and privacy-protective. The strongest safeguard is data minimisation: not collecting personal data, not transmitting gameplay data, and not embedding analytics, advertising, or tracking. Game data stored in iOS UserDefaults is protected by iOS sandboxing and device security. We encourage you to keep your device and its operating system up to date.

9. Data retention

We hold no personal data, so we have no retention schedule to publish. Game progress and settings stored on your device are kept until you delete the App or clear its data, which is entirely under your control.

10. Your rights

Because we hold no personal data about you, there is nothing for us to access, correct, delete, or export. If you contact us to make such a request, we will confirm this position in writing within a reasonable time (we aim for 10 business days). If you believe we have inadvertently collected personal information about you, contact us at hello@kraftdigital.co.nz and we will investigate promptly and take any steps required by law.

11. Account deletion

ScrollKeeper has no user accounts, so there is nothing to delete on our side. To remove all App data from your device, uninstall the App. Apple's guideline requiring apps with accounts to offer in-app account deletion does not apply because ScrollKeeper has no accounts.

12. Changes to this policy

If our data practices ever change in a way that involves collecting personal information, we will update this policy before the change takes effect and, where required, obtain any consent (including parental consent) needed at that time. We will update the effective date above and, where appropriate, note the change in the App's release notes. The current version always governs.

13. Contact

Questions about this policy, or requests relating to privacy, can be sent to our Privacy Officer:

Kraft Digital Limited (trading as Kraft Digital). Privacy Officer. Email: hello@kraftdigital.co.nz. Website: https://kraftdigital.co.nz. New Zealand Company Number 8596826.

We aim to respond within 10 business days.

This Privacy Policy is provided in good faith and is not legal advice.