Privacy Policy
Introduction
This Privacy Policy explains how Appycron Interactive e.K. (“Appycron”, “we”, “us”) collects, uses, and shares personal data when you use the ColoredAI app (the “App”) and the services behind it (together, the “Service”). In short:
- ColoredAI has no accounts and no sign-in. We do not know your name or e-mail address.
- Photos and ideas you submit are used only to create your coloring page and are not used to train AI models.
- We do not sell personal data. The only third-party SDK besides purchases is Meta’s, for measuring our ads. Identifiable ad measurement happens only with your permission.
- Your pages and coloring progress stay on your device and, if iCloud is turned on, in your own iCloud account.
If you do not agree with this Privacy Policy, please do not use the Service. Capitalized terms not defined here have the meaning given in our Terms of Use.
1. Who We Are and How to Contact Us
Appycron Interactive e.K., Germany, is the controller of the personal data described in this Privacy Policy. Company details are in the Impressum. For any privacy question or request, write to coloredai@appycron.com.
2. Personal Data We Collect
a) Data you provide
- Photos and ideas. The photo you choose or the text you type when you create a page (“Input”).
- Support messages. Anything you send us by e-mail, including your e-mail address.
b) Data collected automatically
- Purchase and subscription data. An anonymous identifier created when you first use the App, your subscription status and renewal date, and your App Store country. We never receive your payment details.
- Usage data. The number of pages you create per day and the technical size of each request, linked to the anonymous identifier.
- Device signals for the free trial and abuse prevention. A DeviceCheck token and, where enabled, an App Attest assertion issued by Apple. Neither identifies you to us.
- Technical data. IP address and basic request data seen by our server while it handles a request.
- Advertising measurement. Meta’s SDK in the App reports app installs and app opens to Meta, together with basic device information (such as device model, operating system, language, and time zone), your IP address, and an identifier Meta creates for the App. The SDK may also send crash reports about itself. With your permission in the App Tracking Transparency prompt, Apple’s advertising identifier is included, and our subscription provider reports subscription events (start, renewal, cancellation) to Meta together with the advertising identifier, the app’s vendor identifier, and your IP address, so we can see which of our ads on Facebook and Instagram bring people to the App. If you decline, the SDK’s reports contain no advertising identifier and are marked as not permitted for tracking, and Meta may use them only in limited, aggregated form to measure ads, together with Apple’s non-identifying attribution. Your photos, ideas, and pages are never shared with Meta. You can withdraw permission at any time in iOS Settings › Privacy & Security › Tracking.
- Photo search. The words you type in the in-app photo search are sent to our server, which asks Unsplash on your behalf. Results are cached by search term, not by person, for up to 7 days.
We do not collect your name, e-mail address, contacts, or location inside the App.
3. How We Process Your Photos and Ideas
When you create a page, your Input is sent over an encrypted connection to our server and from there to OpenAI, whose image model draws the coloring page (the “Output”). This happens only when you tap Generate and only to create that page.
- Retention. Our server deletes your Input as soon as the request has finished. The Output is kept in private storage, under the anonymous identifier, so the App can collect it, and is deleted automatically within one day. After that the Output is stored only on your device and, if iCloud is turned on, in your own iCloud account.
- No training. We do not use your Input or Output to train or improve AI models. OpenAI processes API content as our processor and does not use it to train its models; its retention is described in its API data usage policy.
- No face recognition. We do not extract, store, or compare facial features.
- People in your photos. If a photo shows other people, you are responsible for having their permission before submitting it.
4. Purposes and Legal Bases
Under the GDPR we process personal data for the following purposes:
- To provide the Service, in particular to create your pages and run your subscription. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
- To apply the fair-use limit and monitor costs by counting pages per day. Legal basis: our legitimate interest in running a fair and sustainable service (Art. 6(1)(f) GDPR).
- To prevent abuse, including granting the free trial once per device and verifying that requests come from a genuine copy of the App. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
- To respond to your requests when you contact us. Legal basis: performance of a contract or legitimate interest.
- To measure our advertising on Meta platforms, as described in section 2b. Legal basis: your consent (Art. 6(1)(a) GDPR), given through the tracking prompt. For the limited reports without the advertising identifier that the SDK sends when you have not given permission: our legitimate interest in measuring our advertising (Art. 6(1)(f) GDPR).
- To comply with legal obligations, such as tax and accounting rules. Legal basis: Art. 6(1)(c) GDPR.
5. Who We Share Data With
We share personal data only with service providers who process it on our behalf and under our instructions:
- OpenAI (United States): generates the coloring pages from your Input.
- Our hosting provider, Cloudflare: runs our server.
- RevenueCat (United States): manages subscriptions.
- Apple: App Store purchases, DeviceCheck, and App Attest. Apple acts as an independent controller for App Store transactions.
- Unsplash: receives your search words through our server if you use the in-app photo search, and your device’s IP address when the App loads photos from Unsplash.
- Apple iCloud: if iCloud is turned on, your pages sync through your own private iCloud account. We cannot access that data.
- Meta Platforms (Ireland / United States): ad measurement as described in section 2b; identifiable measurement only with your permission. For this measurement Meta is a joint controller with us under its controller addendum.
We may also disclose data if required by law or to protect our rights, and in connection with a sale or transfer of our business. We do not sell personal data.
6. International Transfers
Some providers are located in the United States. Where data leaves the European Economic Area, we rely on the EU-US Data Privacy Framework for certified providers and otherwise on the European Commission’s Standard Contractual Clauses.
7. Data Retention
- Input on our server: deleted when the request has finished. Output on our server: deleted automatically within one day.
- Photo search results cached by search term: up to 7 days.
- Purchase, subscription, and usage data: while your anonymous identifier is in use, and up to 12 months after your last page.
- Support messages: as long as needed to handle your request, and as required by law.
- Pages and coloring progress: on your device, and in your iCloud account if iCloud is turned on, until you delete them.
8. Your Rights
Under the GDPR you have the right to access, correct, delete, or receive a copy of your personal data, to restrict or object to processing based on our legitimate interests, and to lodge a complaint with a data protection authority. To exercise these rights, e-mail coloredai@appycron.com and include the approximate date and the App Store receipt of your purchase, since we hold no other way to identify your records. We respond within one month.
9. Children
The Service is not directed to children under 16, and we do not knowingly collect personal data from them. If you believe a child has submitted a photo, contact us and we will delete it.
10. Security
All traffic between the App, our server, and our providers is encrypted. We keep the data we hold to the minimum needed to run the Service. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
11. Third-Party Links and Services
The App may link to third-party websites and services, such as Apple’s subscription settings or Unsplash. Their privacy practices are governed by their own policies.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The date at the top shows the latest version. If a change materially affects your rights, we will inform you in the App before it takes effect.