Privacy Policy

Last updated: October 9, 2026

ColorU (“ColorU”, “we”, or “us”) operates the ColorU mobile application (the “Service”). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use. We collect several different types of information for various purposes to provide and improve our Service to you.

Please read the following carefully and make sure you fully understand this Privacy Policy. If you have any concerns about providing information to us or it being used as described in this Privacy Policy, please discontinue and avoid using our Services.

1. What Information Do We Collect?

The personal data we collect will depend on the circumstances and the Services you are using. We collect data in three ways: (a) data you provide to us; (b) data we collect automatically; and (c) data we collect from other sources. We do not knowingly collect (d) special categories of information.

A. Data You Provide To Us

• Contact information (such as name and email address)
• Your messages to the Services (such as chat logs and player support tickets)
• Other data you choose to provide us when you contact us (through the Services, social media, email or any other channels)
• Profile information, such as name, social media account information, and profile image
• Payment information, including payment card numbers or other third-party payment information (such as PayPal) where required for the purpose of payment

B. Data We Collect Automatically

• Data and analytics about your use of our Services (e.g., your game progress, the date and time you used a Service, session length, features you have used, your in-app purchase history, your interaction with advertisements)
• Usage information regarding your use of the Services and any other User Content that you generate through or upload to our Services
• Device information (such as your IP address, IMEI, advertising ID, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, screen resolution, and operating system)
• Location data, including approximate location based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS)
• Data about your use of the Services, such as gameplay data and your interactions with other players inside the Services
• Cookies and similar technologies used to personalize Services, analyze use, target advertisements, and prevent fraud. You can disable cookies in your browser settings, but some parts of the Services may not function properly

Note that we do not use such data to learn a person’s true identity or contact details, but mostly to understand how our users typically use and interact with our Services, so that we can maintain and improve them.

C. Data We Collect From Other Sources

We may receive information from other sources, such as:

• Third-Party Services: Advertising partners, data providers, and analytics providers.
  • Third-party tools: If you choose to link a third-party tool with the Services (such as Facebook, Google, or Apple), we may receive basic profile information (e.g., user ID, username, gender, picture, email, friends playing the same game). We do not get access to or store your logins or passwords.
• Third-party platforms: In-app purchases are processed by platforms (e.g., Apple App Store, Google Play, Amazon Appstore). We do not collect or store financial data like credit card or bank account details. We may receive limited non-financial data relating to the purchase status.
• Advertising partners: Non-personal information concerning campaign performance and fraud prevention data.
• Other Sources: Publicly available sources.

D. No Special Categories Of Information

We do not request or intend to collect any “special categories of information” such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic/biometric data, health data, or sex life/sexual orientation. Please be cautious when sharing this information about yourself or others.

2. How We Use Your Data

We use your information to improve, support, and administer the Service, allow you to use its functionalities, and fulfill and enforce our Terms of Service.

A. To Make Our Services Work

• Allow you to use our Services
• Facilitate, operate, provide, and maintain our Services
• Verify and confirm payments in our Services
• Provide and deliver in-app products and services you request
• Send you Service-related communications
• Respond to your comments and questions and provide player support

B. To Make Our Services More Suitable For Our Players

• Develop and improve the Services and player experience
• Manage our relationship with you
• Provide social features as part of the Services
• Customize your Services experience
• Provide you with our offers in the Services
• Send you related information, such as updates, security alerts, and support messages
• Enable you to communicate with other players
• Show you contextual advertisements in our Services
• Cross-promote our Services across our portfolio

C. To Serve You Advertising

• Serve generic non-personalized advertisements or personalized advertising experiences
• Track advertising campaign performance and prevent fraud

We retain your information as long as the application is installed on your mobile device or as needed to provide you service. If you remove the application, we will delete your information, preserving only necessary copies to comply with legal obligations, resolve disputes, and enforce agreements.

3. How We Share Your Data

A. Other Players And Users

Social features are a core component of our Services. Other players may see your profile data, in-game activities, and messages you post.

B. Service Providers and Business Partners

We share personal information categories with service providers and business partners to perform operations (hosting, analytics, customer care, marketing, advertising). We share data only under a valid legal basis or data processing agreement.

4. AI Data Processing and Third-Party Sharing

When you use our AI-powered features (such as “Turn any photo into a coloring page”), we process user-provided content to deliver the requested results under the following terms:

• Selected Content Only: We process only the specific photo that you explicitly choose and upload for AI generation. We do not automatically scan, access, or upload your entire photo library or camera roll.
• Face Data & Visual Content: If the selected photo contains human faces, image data is used strictly to generate the requested coloring page or artistic effect. We do not extract biometric identifiers, facial landmarks, or facial embeddings for identification, tracking, profiling, or facial recognition purposes.
• Third-Party AI Service Provider: Photos are securely transferred to and processed by our trusted third-party AI infrastructure provider, ByteDance / Volcano Engine. We do not sell, rent, or share your photo or face data with unauthorized third parties.
• Equal Protection Commitment: Our third-party AI provider is contractually bound to process data solely to provide requested AI generation services and maintain privacy standards equivalent to this policy.
• Data Retention & Deletion: Uploaded photos and processed image data are used temporarily during generation and automatically deleted from temporary processing servers after completion. We do not retain copies or use photos to train public/separate AI models.

5. International Data Transfers

Our Services are global. Data may be transferred to and processed in countries other than your resident country. We ensure adequate safeguards (such as European Commission Standard Contractual Clauses) are in place.

6. Your Rights

Subject to applicable laws, you have the following rights:

• Right to Access: You can request free-of-charge information regarding:
  • Whether your personal data is collected, used, disclosed, or sold;
  • Categories of personal data collected in the preceding 12 months;
  • Categories of sources from which personal data is collected;
  • Business or commercial purposes for collecting/selling personal data;
  • Disclosure or sale details of your personal data (if any).
• Right to Rectification: Request correction of inaccurate personal data.
• Right to Erasure: Request deletion of personal data where no compelling reason exists for continued processing.
• Right to Data Portability: Request transfer of your personal data.
• Right to Object/Restrict: Object to or restrict data processing (note: this may impact Service availability or quality).
• Automated Decision-Making: Right not to be subject to decisions based solely on automated processing/profiling.
• Lodge a Complaint: Right to file a complaint with a data protection supervisory authority.

7. Opt-Out Of Personalized Advertising

You can opt out of personalized advertising on mobile devices via device privacy settings:

Apple Devices (iOS 14 and later):

1. Open Settings
2. Select Privacy & Security
3. Select Tracking and disable “Allow Apps to Request to Track”

Apple Devices (iOS 13 and older):

1. Open Settings
2. Select Privacy
3. Select Advertising and enable "Limit Ad Tracking"

Opting out means third-party ad networks will display contextual ads not tailored to your interests, which may result in less relevant advertising.

8. Security And Storage

We deploy reasonable measures to protect information against loss, theft, misuse, and unauthorized access. However, no data storage or transmission over the Internet can be guaranteed 100% secure.

9. Your Rights And Options

You may request correction, deletion, or restriction of your personal data by contacting our Data Protection Officer as detailed in the "CONTACT US" section. We may require identity verification (e.g., purchase receipt or linking email) before fulfilling requests.

10. Changes

We may update this Privacy Policy periodically. Material changes will be notified via reasonable efforts (e.g., in-game notices or push notifications). We encourage regular review of this policy.

11. CONTACT US

For questions or data requests, contact us via in-app support (“Contact Us”) or email at reayoutech2022@gmail.com.