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Keyboard Extension (working title) — Privacy Policy

Version 1.0 · Effective 10 August 2026 · https://sunwardliving.sg/privacy/keyboard/

A keyboard sees everything you type. That is exactly why this one is built to leave what you type on your device, and why this policy is specific rather than generic.

This application has not been released. It is in development and has not been submitted to App Store review. This policy is published in advance so that it can be reviewed alongside the app. It will be re-examined before submission, and if the app changes in any way that affects this document, the version number and effective date above will change with it.

The short version

  • You do not need to grant Full Access. The keyboard is fully functional with Full Access switched off, which is how iOS installs it by default.
  • It works with no network connection. Typing does not depend on reaching a server, so nothing needs to leave your phone in order for the keyboard to work.
  • What you type is not sent to us. We operate no server that receives your keystrokes, and we have no copy of anything you have typed.
  • Data about your use of the keyboard is used only to make the keyboard better at being a keyboard — never to profile you and never for advertising.
  • There is no account. No sign-up, no email address, no phone number.

This summary is here for readability. The sections below are the operative terms.

Who we are

This application is developed and published by:

SUNWARD LIVING PTE. LTD. UEN 202541995R 33 Ubi Avenue 3, #08-43 Vertex, Singapore 408868 contact@sunwardliving.sg Telephone: to be published

We are a private limited company incorporated in Singapore on 19 September 2025 and we are the organisation responsible for personal data handled in connection with this application, within the meaning of Singapore's Personal Data Protection Act 2012 ("PDPA").

What this policy covers

This policy covers the iOS keyboard extension currently under development by SUNWARD LIVING PTE. LTD. and its companion app — the app you install from the App Store, which contains the keyboard's settings and help pages. It does not cover any other application, and it does not cover the apps in which you use the keyboard. When you type into another company's app, that app receives the text you produce and its own privacy policy applies to what it then does with it.

Full Access — the important part

iOS treats third-party keyboards with deliberate suspicion. When you add one, it is installed without "Full Access", and in that state the operating system itself prevents the keyboard extension from reaching the network or passing data to its containing app. It is a sandbox enforced by iOS, not a promise made by us.

The keyboard is designed to be complete with Full Access switched off. Ordinary typing, corrections, layouts and settings all work in that state. We do not withhold basic functionality in order to push you into granting the permission.

If a future feature genuinely cannot work inside that sandbox, then: it will be optional; the app will explain plainly what the feature does and why it needs the permission, at the moment it asks; declining will leave normal typing untouched; and this policy will be updated to describe exactly what data that feature involves before the feature ships.

You can check or change the setting at any time in Settings › General › Keyboard › Keyboards on your device, and you can remove the keyboard there as well.

What the keyboard handles, and what we receive

Keystrokes

The characters you type are processed on your device, in the moment, to do the thing you are typing — place a character, offer a correction, complete a word. They are not transmitted to us. We have no keystroke logs because we operate nothing that could receive them.

Local typing data on your device

To be useful, a keyboard needs a small amount of memory: the words you have taught it, layout and language preferences, and similar settings. Where the keyboard keeps such data, it is stored in the app's own storage on your device, under the protection iOS provides. It stays there. Deleting the app deletes it.

Passwords and sensitive fields

The keyboard does not treat secure text fields as a source of data. Text entered into password fields is not learned, retained or added to any local dictionary.

Analytics

The app does not embed third-party analytics or advertising software development kits. If you have chosen, in iOS Settings, to share analytics with app developers, Apple may provide us with its own aggregated and anonymised crash and usage reports. Those come from Apple, describe the app rather than you, and do not contain what you typed. You control that setting in Settings › Privacy & Security › Analytics & Improvements.

How data is used

Apple's App Review Guideline 4.4.1 requires that a keyboard extension collect user activity only to enhance the functionality of the keyboard extension itself. We build to that rule, and state it here as our own commitment: any data the keyboard handles is used solely to

  • insert, correct and predict text as you type;
  • remember your keyboard settings and the words you have taught it;
  • diagnose faults in the keyboard, using the aggregated reports described above.

It is not used for anything else — not to determine who you are, what you are interested in, or what should be advertised to you.

What we never do

The following are not part of this application and will not be introduced without a new version of this policy and a clear notice in the app:

  • We do not build advertising or behavioural profiles of you.
  • We do not display advertising in the app.
  • We do not sell, rent or trade personal data to anyone, for any purpose.
  • We do not share personal data with data brokers, marketing networks or analytics networks.
  • We do not use personal data to track you across other companies' apps or websites, and we do not ask for permission to do so.
  • We do not use what you type to train models on our systems, because what you type does not reach our systems.

Disclosure to others

We do not disclose personal data to third parties. The narrow exceptions, none of which involve routine operation of the app, are: where we are required to do so by Singapore law or by a lawful order of a court or regulator; and where it is necessary to protect our legal rights. If a disclosure of this kind is ever made, it will be limited to what we actually hold — which, by design, is very little.

Retention

We do not hold your typing data, so there is nothing for us to retain or to delete on your behalf. Data the app stores locally on your device remains until you clear it in the app's settings or delete the app. Correspondence you send us by email is kept only as long as needed to deal with the matter and to meet our record-keeping obligations.

Security

Because the keyboard keeps data on your device rather than sending it to us, its security rests principally on the protections iOS provides: app sandboxing, the keyboard extension sandbox described above, and device encryption. We recommend keeping a passcode set and iOS up to date.

No method of storage or transmission is perfectly secure. We aim to keep the number of places your data could be exposed as small as possible, which is why the design keeps data on your device rather than accumulating it on a server.

Transfers outside Singapore

Section 26 of the PDPA restricts the transfer of personal data out of Singapore. Because this application does not send your personal data to us or to any third party, there is no such transfer to disclose. If that ever changes, this policy will be updated to identify the recipient, the country and the protection applied, before the change takes effect.

Children

This application is a general-purpose utility. It is not directed at children, and we do not knowingly collect personal data from children. Because the app does not ask for an account, a name, an email address or a date of birth, we hold no information from which a user's age could be determined.

Your rights under the PDPA

Under the PDPA you may ask us:

  • For access — whether we hold personal data about you, what it is, and how it has been used or disclosed in the past year.
  • For correction — to correct an error or omission in personal data we hold about you.
  • To withdraw consent — to stop using or disclosing your personal data for a purpose you previously agreed to. We will tell you the likely consequences before the withdrawal takes effect.

Send any of these requests to dpo@sunwardliving.sg. We will respond as soon as reasonably possible and, in any event, within the timeframes set by the PDPA.

In practice, most requests will get a short answer: the app is built so that we do not receive your data in the first place, and we can only produce what we actually hold. Data stored by the app on your device is under your control — deleting the app removes it.

Data Protection Officer

Section 11(3) of the PDPA requires an organisation to designate at least one individual as its Data Protection Officer and to make that person's business contact information available to the public.

Data Protection Officer SUNWARD LIVING PTE. LTD. 33 Ubi Avenue 3, #08-43 Vertex, Singapore 408868 dpo@sunwardliving.sg

This address reaches the individual designated as our Data Protection Officer. Access requests, correction requests and any other data protection matter can be sent here directly.

If you are not satisfied with our response, you may raise the matter with Singapore's Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.

Changes to this policy

If we change this policy we will update the version number and effective date at the top of this page. Material changes — anything that would newly permit the collection, use or disclosure of personal data — will also be surfaced in the app itself, and, where the PDPA requires it, we will ask for your consent before the change applies to you.

Because the URL of this page is quoted in the app's App Store listing, we keep the URL stable across product name changes. The address of this page will not move.

Version history

  • Version 1.0 — 10 August 2026 — first publication, ahead of the app's submission for App Store review.

Contact

Questions about this policy, about what the app does with data, or about anything else on this site:

SUNWARD LIVING PTE. LTD. UEN 202541995R 33 Ubi Avenue 3, #08-43 Vertex, Singapore 408868 contact@sunwardliving.sg Telephone: to be published