# Privacy Policy – ColoringFriends

Effective: October 2025

## 1. Controller

ColoringFriends – Owner: Oliver Demuth

Am Kirchenberg 9, 2132 Hörersdorf, Austria

Email: hello@coloringfriends.com

This Policy explains how we process personal data when using our mobile app “ColoringFriends” and – where applicable – our website at https://coloringfriends.com.

## 2. Categories of data

– Device and usage data: device model, OS, language, app version, anonymous usage events (e.g., app launch), logs (timestamps, crash/errors).

– Push notification token (FCM token): to deliver push notifications.

– Account data (only if you sign in): UID (Apple/Google), basic profile (e.g., name/email if provided by the provider).

– Favorites/downloads:

– without sign‑in: stored locally on your device (no server sync).

– with sign‑in: synced to the cloud (e.g., linked to your account).

– In‑app purchases/subscriptions: handled solely by Apple App Store / Google Play. We do not receive full payment data; we only store subscription status/entitlements.

## 3. Purposes and legal bases (GDPR)

– Providing the app, core features (Art. 6(1)(b) GDPR): technical operation, content display/management, favorites/history (local/cloud).

– Push notifications (Art. 6(1)(a) GDPR – consent): themed notifications; you can withdraw consent anytime in system settings.

– Security and abuse prevention (Art. 6(1)(f) GDPR): App Check/integrity, stability, diagnostics.

– Contract performance for subscriptions (Art. 6(1)(b) GDPR): entitlement management, restore purchases.

## 4. Recipients / processors

– Google Firebase (Google LLC): Cloud Firestore (database), Firebase Storage (files), Firebase Cloud Messaging (push), App Check (integrity).

– Apple / Google: billing for in‑app purchases/subscriptions under their terms.

– Hosting/service providers: where required for operation/support.

Appropriate data processing agreements/Standard Contractual Clauses apply.

## 5. International transfers

Data may be transferred to third countries (notably the US) in the context of Firebase/Google. Such transfers rely on appropriate safeguards (notably EU Standard Contractual Clauses). Additional safeguards (e.g., encryption) are used where feasible.

## 6. Storage duration

– Local data (no sign‑in): only on your device until you uninstall/clear app data.

– Cloud data (with sign‑in): until account deletion or withdrawal/deletion request; statutory retention remains unaffected.

– Logs/diagnostics: retained for a reasonable period for stability/security.

## 7. Your rights

Subject to legal conditions, you have the right to access, rectify, erase, restrict processing, data portability, object, and withdraw consent.

To exercise these rights, contact: hello@coloringfriends.com.

You may lodge a complaint with a supervisory authority (e.g., Austrian Data Protection Authority, Barichgasse 40‑42, 1030 Vienna).

## 8. Security

We implement appropriate technical and organizational measures (e.g., access controls, transport encryption). No system is perfectly secure; please protect your device and access credentials.

## 9. Children

Our app is not specifically directed at children under 13. If we learn of unlawfully collected data, we will delete it promptly.

## 10. Changes

We may update this Policy (e.g., for new features/providers). The current version applies as published in the app/website. We will inform you appropriately about material changes.

## 11. Contact / Imprint

ColoringFriends – Oliver Demuth

Am Kirchenberg 9, 2132 Hörersdorf, Austria

Email: hello@coloringfriends.com

VAT: ATU 64617409 – Chamber: WKO Mistelbach