Coloristo — Privacy Policy
Last updated: October 19, 2026 · Effective: October 19, 2026
Coloristo ("Coloristo", "we", "us") builds an iPhone app that turns your photos into digital coloring pages you can color on your device. This Privacy Policy explains what we collect, why, how long we keep it, and the choices and rights you have. It applies to the Coloristo app and our website.
Coloristo is operated by Relle Limited, a company registered in Cyprus (company number HE 426487), registered office: Andrea Zakou 2, 2nd floor, Flat/Office 202, 2404 Egkomi, Nicosia, Cyprus; contact address: Dimofontos 39, 3rd Floor, Office 301, 1075 Nicosia, Cyprus. Relle Limited is the controller of your personal data. You can contact us at support@coloristo.org.
Short version: we collect the minimum we need. Your photos are used only to make your coloring pages. We never sell your personal information, and we never use your photos to train third-party AI models unless you explicitly opt in.
1. Information we collect
A. Photos and content you provide
- Photos you upload, the coloring pages generated from them, and your colored artwork.
- Artwork and comments you choose to publish in the public gallery.
- Photos may contain images of faces. On your device, the app detects faces, people and animals in your photo (using Apple's Vision technology) to prepare the coloring page, and only the number of faces found (not images) is included in our analytics. We do not perform facial recognition, identity matching, or biometric identification, and we do not create or store faceprints or other biometric identifiers.
- Optional feedback, support messages and any images you attach to them.
B. Account information (if you create an account)
- Email address and name, if you share them when signing in, and a profile image if you provide one.
- Sign in with Apple (and email, for accounts created in earlier versions of the app). If you use Sign in with Apple with "Hide My Email", we only ever see the relay address. We use your email only for service messages (for example, password reset) and to reply to you.
C. Purchase information
- Subscription status, plan type, trial eligibility, renewal and cancellation events, provided to us by Apple and our subscription-management provider. We never receive your card number or full billing details — Apple processes all payments.
D. Device and usage information
- Device model, iOS version, app version, language, region, time zone, approximate location (country and city derived from your IP address), crash and performance diagnostics.
- Feature usage events (for example: onboarding steps completed, a photo converted, a page opened), so we can improve the app.
- An app-generated pseudonymous identifier and, where applicable, the Apple IDFV. We only access the IDFA for advertising measurement if you grant App Tracking Transparency permission.
- A device check token from Apple (DeviceCheck), which lets us remember, without identifying you, whether a device has already used its free photo conversion.
E. Notifications
- Push token, if you allow notifications.
We do not knowingly collect precise location, contacts, health data, or biometric identifiers.
2. How we use information
| Purpose | Data used |
|---|---|
| Convert your photo into a coloring page | Uploaded photo, device info |
| Sync your coloring progress and favorites across your devices | Coloring progress, favorites, account ID |
| Show artwork you publish in the public gallery | Artwork image, comments, account ID |
| Limit free use to one photo conversion per device | Device check token (Apple DeviceCheck) |
| Provide and manage subscriptions, trials and restores | Purchase and account data |
| Customer support | Contact details, support messages, diagnostics |
| App reliability, crash fixing, security and fraud prevention | Device, diagnostic, usage data |
| Product improvement and A/B testing of onboarding and pricing | Aggregated/pseudonymous usage data |
| Optional push reminders | Push token |
| Install attribution and marketing measurement | App usage and purchase events linked to your anonymous user number, device information; advertising identifier only with your ATT consent |
Legal bases where GDPR/UK GDPR applies: performance of a contract (providing the app and subscription), legitimate interests (security, product improvement), consent (notifications, marketing, tracking), and legal obligations.
3. How photo processing works
When you upload a photo, it is transmitted over an encrypted connection to our server, which passes it to Google (Vertex AI). Google, acting as our processor, converts it into line art, and the result is returned to your device.
- Photos are encrypted in transit (TLS).
- Under Google Cloud's terms, Google does not use your photos to train its models.
- You can delete the coloring pages you created in the app at any time.
4. Sharing your information
We share personal information only with service providers who process it on our behalf, under contract, for the purposes above:
- Google: turning photos into coloring pages (Vertex AI); analytics, crash reporting and app configuration (Firebase Analytics, Crashlytics, Remote Config); storage of analytics data (BigQuery)
- Amplitude: product analytics
- AppsFlyer: attribution and marketing measurement. The AppsFlyer SDK runs whether or not you grant App Tracking Transparency permission and receives app usage events linked to your anonymous user number, together with device information, your IP address and the vendor identifier (IDFV) used for attribution. It receives your advertising identifier (IDFA) only if you grant permission
- RevenueCat: subscription management and receipt validation; Apple: payments, Sign in with Apple, push notifications and DeviceCheck
- Meta: advertising measurement, only with your App Tracking Transparency permission and through AppsFlyer (see below)
- Cloud hosting and storage, email delivery and customer-support providers
We may also disclose information if required by law, to enforce our Terms, or to protect the rights and safety of users, and in connection with a merger or acquisition (you will be notified).
We do not sell your personal information. If you grant App Tracking Transparency permission, we share your advertising identifier and a limited set of events (app opened, trial started, subscription purchased) with an advertising partner (Meta) through AppsFlyer to measure the performance of our ads. Without your permission, no events are forwarded to Meta. Under some US state laws, including the California Consumer Privacy Act (CCPA/CPRA), this may be considered "sharing". You can withdraw your permission at any time in iOS Settings → Privacy & Security → Tracking.
5. Data retention
- Photos you send for conversion: transmitted to our server and to Google only to create your coloring page.
- Coloring pages created from your photos: stored on your device.
- Coloring progress and favorites: stored on our servers and synced across devices signed in to the same account. This includes previews of your colored pages, editing history, favorites and pinned pages. They stay linked to an anonymous profile number after you delete your account and are not removed automatically. To have them removed, email support@coloristo.org.
- Published artwork and comments: stored on our servers and visible to other users. They stay in the gallery without your name after you delete your account. To have them removed, email support@coloristo.org.
- Account deletion: when you delete your account in the app, we immediately anonymise your profile, delete personal details (such as your name, sign-in details and date of birth) and your profile picture, and delete your subscription record at RevenueCat shortly afterwards.
- Purchase records: retained as long as legally required for tax and accounting.
- Diagnostics and analytics: pseudonymous, retained for up to 24 months. On request, we ask our analytics providers to delete your data; the time this takes follows the policies of those services.
6. Your choices and rights
You can, at any time:
- Delete the coloring pages you created in the app.
- Delete your account in the app (Settings → Delete account) or by emailing support@coloristo.org. Section 5 explains what is deleted and what remains.
- Turn notifications and photo-library access on or off in iOS Settings.
- Withdraw ATT tracking permission in iOS Settings → Privacy & Security → Tracking.
Depending on where you live, you may also have the right to access, correct, delete, restrict or object to processing, port your data, and — for California residents — to know what we collect, to delete, to correct, to opt out of sale/sharing (we do not sell personal information; to stop sharing for advertising measurement, withdraw App Tracking Transparency permission in iOS Settings), and not to be discriminated against for exercising these rights. Nevada, Virginia, Colorado, Connecticut, Texas and other US state residents have comparable rights.
To exercise any right, email support@coloristo.org. We verify requests using the email associated with your account and respond within the time required by applicable law. You may use an authorised agent where the law allows.
7. Children
Coloristo is not directed to children under 13, and we do not knowingly collect personal information from them. If you believe a child has provided us information, contact support@coloristo.org and we will delete it. Users under 18 should have a parent or guardian's permission before making in-app purchases.
8. Security
We use encryption in transit, access controls, least-privilege internal access, logging, and regular review of our providers. No system is perfectly secure; if a breach affects your personal information, we will notify you and the relevant regulators as required by law.
9. International transfers
We may process and store your data in the European Union (our servers are in Finland) and in other countries where our service providers operate, including the United States. Where data is transferred out of the EEA, the UK or Switzerland, we rely on safeguards offered by those providers, such as Standard Contractual Clauses.
10. User-generated content, conduct and reporting
We have zero tolerance for objectionable content and abusive behaviour. Prohibited content includes anything unlawful, sexually explicit, exploitative of minors, hateful, discriminatory, violent, harassing or invasive of another person's privacy. Prohibited behaviour includes harassment, threats, stalking, impersonation and spam.
Report content or users in the app (Report on any shared item) or at support@coloristo.org. We review reports within 24 hours and may remove content, suspend or permanently terminate accounts.
11. Changes to this policy
We may update this Privacy Policy. Material changes will be announced in the app or by email before they take effect, and the "Last updated" date will change.
12. Contact
Privacy questions or requests: support@coloristo.org
Relle Limited, a company registered in Cyprus (company number HE 426487), registered office: Andrea Zakou 2, 2nd floor, Flat/Office 202, 2404 Egkomi, Nicosia, Cyprus; contact address: Dimofontos 39, 3rd Floor, Office 301, 1075 Nicosia, Cyprus.