🎁 2. PRIVACY POLICY

Last Updated: Novemeber, 2025

This Privacy Policy describes how Santa Magic | Smart Way AI ("we," "us") collects, uses, and protects your information when you use our website and mobile applications ("Services").

By using Santa Magic, you agree to the practices described below.

1. Information We Collect

1.1 Parent Account Information (Required)

  • Email address
  • Password
  • Device information
  • IP address
  • Purchase history (no payment data)

1.2 Child Profile Information (Optional)

Only entered by a parent:

  • First name
  • Age range
  • Wishlist items
  • "Nice deeds" notes

We do not collect:

  • Full names
  • Birthdates
  • Contact information
  • School or location data

1.3 Uploaded Media

Parents may upload:

  • Photos
  • Videos
  • Letters (typed or recorded)
  • Images of gifts
  • Living room photos for Santa sightings

We store these until the parent deletes them.

We may also perform a bulk deletion prior to the 2026 holiday season.

We do not use uploaded media:

  • For AI training
  • For advertising
  • For any purpose besides generating the experience

1.4 Santa Interaction Data

We collect:

  • Text transcripts of live or generated interactions

We do not collect:

  • Audio or video of children during interactions
  • Video recordings of live interactions

1.5 Analytics & Tracking

We may use:

  • Firebase
  • Mixpanel
  • App store analytics
  • Standard device data (IP, device model, OS)

This is used to improve performance, safety, and user experience.

2. How We Use Your Information

We use data to:

  • Provide and personalize Santa experiences
  • Generate AI-assisted content
  • Display your stored videos and letters
  • Maintain safety and prevent misuse
  • Process credit purchases
  • Improve app performance and reliability

We do not sell or share your data with advertisers or third parties.

3. AI Service Providers

We use AI technologies from:

  • OpenAI
  • Google
  • HeyGen

These services may process:

  • Text (wishlists, transcripts)
  • Images you upload (to generate effects or videos)

We restrict all processing to experience generation only.

4. Children's Privacy (COPPA)

  • Only parents may create accounts.
  • Children cannot access the app without supervision.
  • We collect child profile data only from parents, and only minimal details.
  • Parents may delete child data at any time.

This structure ensures COPPA compliance.

5. Legal Basis for Processing (GDPR – for international visitors)

If you are in the EU/UK, we process data under the following bases:

  • Performance of a contract (providing Santa experiences)
  • Legitimate interest (security, analytics)
  • Consent (when uploading optional media)

6. Data Retention

  • User-uploaded media: until the parent deletes it
  • AI transcripts: retained to improve safety/quality
  • Account data: retained while account is active
  • Potential data purge before 2026 holiday season

You may request deletion at any time.

7. Data Rights

You may request:

  • Access to your data
  • Correction
  • Export
  • Deletion
  • Removal of child profiles

To submit a request:

📩 SantaSupport@SantaMagic.com

8. Data Security

We use:

  • Encrypted databases
  • Access controls
  • Limited staff access
  • Industry-standard cloud storage protections

No system is 100% secure, but we take serious precautions.

9. International Transfers

Your data may be processed in the U.S. or by our cloud/AI partners.

We use legal safeguards such as SCCs where required.

10. Changes to This Policy

We may update this Privacy Policy as needed.

We will notify users of material changes.

11. Contact

Smart Way AI — Santa Magic

1221 103rd Pl SW Unit A

Everett, WA 98204

📩 SantaSupport@SantaMagic.com