PRIVACY POLICY (COLOR RING)

Last Updated: 28 October 2026

This Privacy Policy (“Policy”) explains what information we collect when you use the Color Ring mobile application (the “App”) and related services (together, the “Service”), why we collect it, who we share it with and what choices you have.

In short:

You can color pictures without an account. Your artworks are saved on your device and, if iCloud is turned on, in your own iCloud Drive.
If you create an account, we keep your email address, your public profile (nickname, description, photo) and the works, likes, comments and follows you publish, so that the community features work.
Works you publish to the community feed or contests are public to other users together with your nickname and profile photo. Before a work is published, it is checked automatically by an AI moderation service.
The free version shows ads. Ads are personalised only if you allow tracking in the iOS prompt. Premium removes ads.
We never see your payment card details: purchases are processed by Apple.
We do not sell your personal data for money.
Accounts and the community are for users aged 13 and over (see Section 12).

1. WHO WE ARE (DATA CONTROLLER)

The Service is operated by:

MARTIN GREY LLP

A limited liability partnership registered in England and Wales
Company Number: OC457668
Registered Office: First Floor Office 3 Hornton Place, London, W8 4LZ, United Kingdom

MARTIN GREY LLP (“we”, “us”, “our”) is the controller of your personal data under the UK GDPR and, where it applies, the EU GDPR.

UK Data Protection Registration (ICO): MARTIN GREY LLP is registered with the UK Information Commissioner’s Office (ICO) as a data protection fee payer. Registration reference: ZC047721.

Privacy contact: [email protected]

This Policy should be read together with our Terms of Use.

2. SCOPE

2.1 This Policy applies to information we process:

(a) when you use the App, with or without an account;
(b) when you publish works, comment, like, follow or take part in contests and challenges;
(c) when you contact support or send feedback from the App;
(d) when you receive our notifications or emails.

2.2 This Policy does not apply to third-party websites, apps or services that you open from the App (for example, Apple, Google or social networks). Their own privacy policies apply.

3. INFORMATION WE COLLECT

3.1 If you use the App without an account

(a) Artworks and progress. The pictures you color, your progress and app settings are stored on your device. If iCloud Drive is turned on for the App, they are also stored in your own iCloud account, which Apple operates. We do not have access to your iCloud.
(b) App identifier. The App creates a random identifier on your device to tell installations apart.
(c) Purchases. See Section 3.4.
(d) Ads and analytics. See Sections 3.5 and 3.6.

3.2 If you create an account

(a) Sign-in data. Your email address and password, or your Apple ID (Sign in with Apple) or Google account (Sign in with Google). With Sign in with Apple, Apple may give us a private relay email address instead of your real one. Passwords are stored by our sign-in provider in hashed form; we never see them. For accounts created in earlier versions of the App, the old hashed password is removed from our database when the account moves to the current sign-in system.
(b) Public profile. Your nickname, the profile description and the profile photo you choose to add. You can take the photo with the camera or pick it from your library; only the photo you choose is uploaded.
(c) Community activity. The works you publish to the community feed, contests and challenges; your likes, comments and replies; the users you follow and who follow you; repaint invitations you send and receive; and counters derived from this activity (for example, number of publications, likes and followers, and weekly or monthly leaderboards).
(d) Notification settings and token. If you allow notifications, the push token of your device and your choices about which notifications you want to receive (likes, comments, followers, contests, Art School, repaint invitations, challenges).
(e) Language. The language you use in the App, so that we can show you content and notifications in that language.

3.3 Support and feedback

If you send a bug report, suggestion or review from the App or by email, we receive your message and, to help us answer and fix problems: your email address and nickname (if you are signed in), your account ID, the App language, whether you have Premium and when it expires, the App version, the device model and iOS version, and simple counters (how many times you opened the App and how many works and likes you have).

3.4 Purchases (Apple and RevenueCat)

Subscriptions and in-app purchases are processed by Apple. We never receive your payment card or other payment details. Our subscription management provider, RevenueCat, receives from Apple and stores the information needed to give you Premium: an anonymous purchaser ID, the product you bought, purchase and expiry dates, trial status, transaction identifiers, your country or currency and price.

3.5 Advertising

The free version of the App shows ads through the Clever Ads Solutions (CAS) mediation platform, which selects ads from ad networks such as Google AdMob, AppLovin, Meta Audience Network, Unity Ads, ironSource, Liftoff (Vungle), Mintegral, InMobi, Chartboost, Digital Turbine (DT Exchange) and Yango Ads. To deliver and measure ads, these companies may receive device and network information: IP address, device model, operating system, language, time zone, approximate location derived from the IP address, ad interactions, and identifiers.

(a) If you allow tracking in the iOS “Allow to track” prompt (App Tracking Transparency), the advertising identifier (IDFA) of your device is available to the App and ad partners may use it, together with data they hold about you, to show you personalised ads and measure them across apps.
(b) If you do not allow tracking, the IDFA is not shared. Ads are still shown, but they are not personalised based on your activity in other companies’ apps and websites. Ad networks may still use non-identifying device data and Apple’s privacy-preserving SKAdNetwork attribution for delivery, frequency limits, fraud prevention and measurement.
(c) Some ads are interactive and may ask to use the device motion sensors.
(d) Premium subscribers do not see ads.

You can change your tracking choice at any time in iOS Settings > Privacy & Security > Tracking.

3.6 Analytics and app measurement (Meta)

The App includes the Meta (Facebook) SDK, which automatically records app events such as installs, App launches and purchases, together with device information, to help us measure our advertising campaigns and understand how the App is used. If you allow tracking, the SDK may also use the IDFA; if you do not, it receives information without the IDFA. Meta acts as our processor for some of this data and as an independent controller for other uses, as described in Meta’s own policies.

We also receive aggregated, non-identifying statistics and crash reports from Apple, if you have chosen to share analytics with app developers in iOS Settings.

Product analytics (PostHog). We use PostHog (PostHog Inc., data stored in the European Union) to understand how the App is used: which screens are opened, which pictures are colored and published, searches, contest participation, subscription status and purchases. If you are signed in, these events are linked to your account ID, email and nickname so that we can improve the App and help you with support requests. PostHog acts as our processor, does not use the IDFA and does not use the data for advertising.

3.7 Automatic moderation of published works (AI processing)

When you publish a work to the community or a contest, the image is first sent to OpenAI’s image analysis service to check that it meets our community rules (for example, no sexual content, nudity, graphic violence, self-harm or hate). The result is a simple “allowed / not allowed” decision with a short reason. If a work is not allowed, it is not published and you can try another image. We keep a record of each check: the result, the reason, the AI model used, the time, a technical fingerprint (hash) of the image, its size and type, and the email address of your account. OpenAI processes this data on our behalf and, under its API terms, does not use it to train its models.

This check does not have legal or similarly significant effects on you: it only decides whether a picture appears in the community. If you think a work was rejected by mistake, write to us and a person will review it.

3.8 Device permissions

The App asks for these permissions only when you use a related feature, and you can change them in iOS Settings:

(a) Camera and Photos: to take or pick a photo for your profile, or to turn a photo into a sketch to color, and to save your works to your photo library. Photos you turn into sketches are processed on your device; only the profile photo and the works you choose to publish are uploaded.
(b) Notifications: see Section 3.2(d). Some reminders (for example, about your trial or offers) are scheduled on your device.
(c) Media library: if requested, used on your device only to play music.
(d) Tracking: see Section 3.5.

3.9 SharePlay

If you color together with someone through SharePlay in FaceTime, your drawing actions are exchanged between the participants through Apple’s SharePlay service. We do not receive or store the content of SharePlay sessions.

3.10 What we do not collect

We do not collect your precise location, contacts, health data or the contents of your photo library beyond the photos you choose. We do not knowingly collect sensitive data (such as health, religion or political opinions); please do not include it in your profile, works or comments.

4. HOW WE USE INFORMATION AND OUR LEGAL BASES

Provide the App, your account, sign-in, cloud storage of your published works, community features, contests and leaderboards. Legal basis: performance of our contract with you (the Terms of Use).
Give you Premium and manage subscriptions and purchases. Legal basis: contract; legal obligation (tax and accounting records).
Send push notifications you have allowed (likes, comments, followers, contests, Art School, challenges). Legal basis: your consent, which you can withdraw in iOS Settings or in the App’s notification settings.
Automatically check works before publication, review reports, remove content and suspend accounts that break our rules. Legal basis: our legitimate interest in keeping the community safe, and our legal obligations.
Show ads in the free version and measure them. Legal basis: for non-personalised ads, our legitimate interest in funding a free version; for personalised ads and tracking, your consent (the iOS tracking permission and, where required, other consent).
Measure our marketing campaigns and improve the App (Meta SDK, Apple statistics). Legal basis: our legitimate interest; where tracking is involved, your consent.
Answer support requests and feedback. Legal basis: contract and our legitimate interest.
Run contests and deliver prizes. Legal basis: contract (the contest rules).
Prevent fraud and abuse, protect our rights, comply with the law. Legal basis: legitimate interests; legal obligation.

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

5. WHAT OTHER USERS CAN SEE

(a) Public: your nickname, profile photo and description; the works you publish; your likes and comments; your number of publications, likes, followers and followings; your followers and the users you follow; your place in leaderboards and contest results.
(b) Not public: your email address, your sign-in method, your purchases and your unpublished works.

Anyone who uses the App can see public content, and other users may take screenshots of it. Think carefully before publishing, and do not use your real full name or include personal information about yourself or others in your nickname, description, works or comments.

We share personal data only as described below. Our service providers process data on our behalf under contracts that require them to protect it and to use it only to provide their services to us.

Convex: Backend database and server functions (accounts, profiles, community content, settings) (United States).
Cloudflare (R2): Storage and delivery of published images (assets.colorring.app) (global network).
Clerk: Sign-in, account management, verification and password-reset emails, profile photo storage (United States).
Apple: App Store purchases, Sign in with Apple, push notifications (APNs), iCloud, SharePlay (United States).
Google: Sign in with Google (if you use it) (United States).
RevenueCat: Subscription and purchase management (United States).
OpenAI: Automatic moderation of images before publication (United States).
Resend: Delivery of support and feedback messages from the App to our support inbox (United States).
Clever Ads Solutions and its ad network partners (Section 3.5): Ads in the free version (various countries).
Meta Platforms: App events and advertising measurement (Section 3.6) (United States / Ireland).

We may also disclose information:

(a) if the law, a court or a public authority requires it;
(b) to investigate or prevent fraud, abuse, security issues or illegal activity, or to protect the rights, property and safety of our users, us or others;
(c) as part of a merger, acquisition, reorganisation or sale of our business, in which case this Policy will continue to protect your data.

We do not sell personal data for money. However, if you allow tracking, the sharing of identifiers with ad partners for personalised advertising may count as “sharing” or “targeted advertising” under some US state laws. See Section 11.

7. INTERNATIONAL TRANSFERS

We are based in the United Kingdom, and most of our providers process data in the United States or in other countries. When personal data from the United Kingdom, the European Economic Area or Switzerland is transferred to a country without an adequacy decision, we rely on the safeguards recognised by law, such as the European Commission’s Standard Contractual Clauses with the UK International Data Transfer Addendum, or the provider’s certification under the EU-U.S. Data Privacy Framework and its UK extension.

8. HOW LONG WE KEEP DATA

(a) Data on your device and in your iCloud: until you delete it or the App. We do not control your iCloud.
(b) Account, profile and community content: while your account exists. When you delete a work, comment or like, it is removed from the community. When your account is deleted, we delete your profile and the content you published from our systems within 30 days; copies in our providers’ backups are removed in their normal backup cycle.
(c) Push tokens: until you sign out, turn off notifications, or the token stops working.
(d) Moderation records: for up to 12 months after the check, or longer if needed to deal with a specific complaint or legal claim.
(e) Support correspondence: up to 2 years after the last message.
(f) Purchase records: as long as required by tax and accounting laws.
(g) Contest and prize data: as long as needed to run the contest, deliver prizes and meet legal obligations.

We may keep information in anonymised or aggregated form that no longer identifies you.

9. SECURITY

Data is encrypted in transit and stored by our providers with industry-standard protection. Access to account data is checked by our server on every request. Passwords are stored only in hashed form by our sign-in provider. No system is completely secure; if a personal data breach affects you, we will inform you and the regulator where the law requires it. Please keep your password private and protect access to your device.

10. YOUR CHOICES AND RIGHTS

10.1 Choices in the App and in iOS

(a) Edit your nickname, description and photo in your profile; delete works and comments you published.
(b) Turn notifications on or off in the App’s notification settings or in iOS Settings > Notifications.
(c) Allow or stop tracking in iOS Settings > Privacy & Security > Tracking.
(d) Turn camera and photo access on or off in iOS Settings.
(e) Buy Premium to stop seeing ads.

10.2 Deleting your account

You can ask us to delete your account and all its data at any time by writing to [email protected] from the email address linked to your account (or telling us the account email if you use Sign in with Apple with a private relay address). We will confirm when it is done. Deleting the App or your account does not cancel an App Store subscription: manage it in iOS Settings > your name > Subscriptions.

10.3 Your rights

Depending on where you live, you may have the right to:

(a) access your personal data and get a copy of it;
(b) correct it;
(c) delete it;
(d) restrict or object to its processing, including processing based on our legitimate interests;
(e) data portability;
(f) withdraw your consent at any time, without affecting processing that took place before.

To use your rights, write to [email protected]. We may ask you to confirm that the account is yours. We will answer within one month (this can be extended where the law allows).

11. REGIONAL INFORMATION

United Kingdom, EEA and Switzerland. You can complain to the UK Information Commissioner’s Office (ico.org.uk) or to the data protection authority where you live or work, although we would appreciate the chance to deal with your concern first.

United States (including California). Residents of California and other states with privacy laws may have the right to know what personal data we collect, use and disclose; to access, correct and delete it; to obtain a copy; and to opt out of “sale”, “sharing” or targeted advertising. The categories of personal data we collect are described in Section 3 (identifiers, account and profile information, user content, commercial information about purchases, internet and app activity, approximate location derived from IP address, and inferences used for ads), their sources in Section 3, purposes in Section 4 and recipients in Section 6. We do not sell personal data for money. To opt out of sharing for targeted advertising, do not allow tracking (or turn it off in iOS Settings > Privacy & Security > Tracking) or write to us. We do not knowingly sell or share the personal data of consumers under 16. We will not discriminate against you for using your rights. You may use an authorised agent; we may ask them for proof of authorisation.

Other countries. If local law gives you additional rights, contact us and we will respect them.

12. CHILDREN

12.1 Color Ring is a general-audience app. Anyone can color pictures without an account. Creating an account, publishing works, commenting and taking part in contests are only for users aged 13 or over. If you are under 18 (or under the age of majority where you live), you need the permission of a parent or guardian to create an account. In some countries (for example, some EEA countries), the age at which you can consent to the processing of your data online is higher than 13, up to 16; if you are under that age, a parent or guardian must agree.

12.2 We do not knowingly collect personal data from children under 13 (or under the applicable age of digital consent) without verified parental consent. If we learn that we have done so, we will delete the account and the data.

12.3 If you are a parent or guardian and believe your child has created an account or given us personal data, write to [email protected]. You can ask us to review, delete or stop collecting your child’s information.

12.4 Advice for younger users and families: use a nickname instead of a real name, do not post photos of yourself or other people, never share your address, school or phone number, and tell a trusted adult if something in the community makes you uncomfortable. Parents can limit in-app purchases and tracking through Apple’s Screen Time and Family Sharing settings.

13. CONTESTS AND PROMOTIONS

When you take part in a contest or challenge, your entry is published with your nickname and photo, and the results (including the number of likes) are public. If you win a prize, we may ask for the information needed to deliver it (for example, your name, postal address and phone number for a physical prize). We use this information only to verify eligibility and deliver the prize, and share it only with the delivery service. Some contests may have additional rules shown in the App.

14. CHANGES TO THIS POLICY

We may update this Policy from time to time, for example when we add features or providers. We will publish the new version in the App with a new “Last Updated” date. If a change is material, we will tell you in the App before it takes effect and, where the law requires, ask for your consent.

15. CONTACT

If you have questions, requests or complaints about this Policy or our data practices, contact us:

Email: [email protected]

Operator: MARTIN GREY LLP (Company Number OC457668)

Registered Office: First Floor Office 3 Hornton Place, London, W8 4LZ, United Kingdom