PRIVACY POLICY

1. IDENTITY OF THE DATA CONTROLLER

Scroll+ is an elite digital reading platform developed solo by Xenit and operated by OWL APP LTD. Our mission is to combine world-class privacy with immersive gamified education. For company details, visit owl-app.com.

Company Information: Scroll+ is developed by Xenit and operated by OWL APP LTD. For company details, visit owl-app.com.

2. DATA LOCALITY & COLLECTION

We adhere to a Local-First philosophy. Most data stays on your device, and we only collect minimal information for elite gamification features:

• Authentication: Secure Google Sign-In for synchronized progression across your devices.
• Activity: Real-time Nova, Title, and Streak metrics for global leaderboard competition.
• Zero-Cloud File Policy: We do NOT collect, scan, or store your book files. PDF and Markdown processing happens 100% locally using our proprietary device-side engine.

3. PERMISSIONS

The app requests the following system permissions:

• Storage: To read locally stored PDF/Markdown documents.
• Brightness: To enable our E-Ink simulator and eye-protection features.

4. SECURITY

All data synced with our servers is encrypted during transit and stored securely on protected infrastructure. We do not sell user data to third parties.

6. GDPR RIGHTS (EU USERS)

If you are located in the European Economic Area (EEA), you have certain data protection rights under GDPR. You have the right to: (a) Access, correct, or update your personal information; (b) Request deletion of your personal data; (c) Object to processing of your personal data; (d) Data portability; (e) Withdraw consent. To exercise these rights, please contact us at [email protected].

7. KVKK RIGHTS (TURKISH USERS)

If you are located in Turkey, you have certain data protection rights under KVKK (Law on Protection of Personal Data). You have the right to: (a) Learn whether your data is processed; (b) Request information about your data; (c) Request correction or deletion; (d) Object to processing; (e) Data portability; (f) Withdraw consent. To exercise these rights, please contact us at [email protected].

9. DATA RETENTION

We retain your personal data only as long as necessary to provide our services and comply with legal obligations. Account data is retained until you delete your account. Upon deletion, all personal data is permanently removed from our servers within 30 days, except as required by law.

8. CHILDREN'S PRIVACY

Reading Features (Offline): The core reading functionality of Scroll+ (viewing PDF and EPUB files) does not require an account and can be used by anyone, including children of any age under parental supervision. No personal data is collected for offline reading. Online Features: Account-based features (leaderboards, progress sync, Nova points) require users to be at least 13 years old, or have verifiable parental/guardian consent as required by COPPA and similar laws. We do not knowingly collect personal information from children under 13 without parental consent. Parents who believe their child has created an account without consent may contact us at [email protected] to request account deletion.

10. THIRD-PARTY SERVICES

Our app uses the following third-party services: Google Sign-In: For user authentication (data processed according to Google's privacy policy); Google Play Services: For app functionality (data processed according to Google's privacy policy). These services may collect and process data according to their own privacy policies.

11. COOKIES AND TRACKING

We use cookies and similar technologies to: (a) keep you signed in; (b) analyze app usage; (c) improve our services. You can manage cookie preferences through your device settings. Google Analytics is used for anonymous usage statistics. For details on cookie usage, see our <a href="/cookies">Cookie Policy</a>.

12. CHANGES TO THIS POLICY

We may update this privacy policy from time to time. We will notify users of significant changes via: (a) in-app notification; (b) email; (c) website notice. Continued use of the app after changes constitutes acceptance of the updated policy.

5. CONTACT

Contact: For any privacy-related inquiries, please contact OWL APP LTD at [email protected].