Privacy Policy

Effective date: February 8, 2026
Last updated: September 24, 2026

1. Data Controller

AF10 S.r.l., Viale Zara 133, 20159 Milano, Italia. Contact: af10srl@gmail.com.

2. Data We Collect

• Account and profile data: email address (for login), username, display name, bio, and profile image. If you sign in with Google, we receive your Google account email and basic profile information (name and profile picture) as permitted by Google Sign-In.
• User content: photos and videos you upload, captions, hashtags, mentions, comments, likes, follows, bookmarks, direct messages, and related metadata (for example book title, author, coloring medium, and brand fields you add to posts).
• Usage and engagement data: post view tracking (we record when you view a post, stored as unique per-user views server-side); first-party aggregate app metrics stored in Supabase such as authenticated app opens, top-level section visits, and daily counts of core actions; and usage analytics collected through Firebase Analytics (for example screen views, sessions, and feature usage), which you can turn off in the app at any time.
• Advertising and consent data: consent choices collected through Google's User Messaging Platform (including IAB TCF consent signals in regions where they apply), Apple App Tracking Transparency status on iOS, ad request and response metadata, advertiser and campaign metadata made available through the ad SDKs, in-feed ad delivery events, ad reports submitted from the app, and first-party house ad impression/click events. To improve contextual relevance and brand safety, the app may provide Google AdMob with up to four public Colora post-page URLs surrounding an ad slot as neighboring-content signals. We do not add captions, usernames, Colora user IDs, or private-content URLs directly to this mapping. Where permitted by your consent choices and, on iOS, Apple's tracking permission, advertising SDKs may also process device-level advertising identifiers: Apple's IDFA on iOS, or Google's Advertising ID on Android. House ad metrics are measured without using these identifiers.
• Device and technical data: IP address, user-agent, and timestamps (for security, rate limiting, and fraud prevention); device model, operating system version, app version, and crash/error reports collected by Firebase Crashlytics; and network-level data collected by our CDN and security providers (for example Cloudflare).
• Moderation and safety data: reports, enforcement actions, moderation results, and audit logs. Posts, captions, comments, and other content you submit in Colora community features may be checked by automated moderation systems and, where needed, human reviewers to detect spam, abuse, misuse, and violations of our rules.
• Local device storage: The app stores an authentication token securely on your device — in the iOS Keychain on iOS, and on Android in encrypted app storage protected by a key held in the Android Keystore; recent search history in local device storage (automatically cleared after 7 days); and cached images on device (up to approximately 50 MB in memory and 200 MB on disk) using standard platform caching mechanisms.
• Purchase and subscription data (iOS only): in-app purchases are currently available only in the iOS app. If you buy Colora Premium or a coloring book, we receive from Apple and our purchase infrastructure provider (RevenueCat) the product identifier, purchase, renewal, trial and expiration dates, subscription status, price and currency, App Store transaction identifiers and receipt-validation data, and a RevenueCat app user identifier linked to your Colora account. Payment itself is handled by Apple: we never receive your card or bank details.
• App attribution (iOS only): AppsFlyer measures installs, app sessions, registration, section visits, paywall views, checkout, trial starts, completed purchases, and content-creation event counts. Data may include an AppsFlyer installation identifier, the vendor identifier (IDFV), the request IP address, device and network information, product identifiers, event times, and consent signals. RevenueCat can send purchase, trial, renewal and subscription-lifecycle events, prices, currencies, and associated purchase and app-user identifiers to AppsFlyer, together with the same device attributes. Apple's advertising identifier (IDFA) is added only if you allow tracking in Apple's App Tracking Transparency prompt. Turning off Share Usage Analytics in the app stops this measurement and requests removal of these attributes. We do not add emails, usernames, captions, messages, or search text to AppsFlyer events.
• Support communications: messages you send to support.

3. Purposes and Legal Bases

• Provide the service (contract): create accounts, authenticate users, display feeds and profiles, enable posting and interactions, deliver direct messages, and track content engagement (post views).
• Security and abuse prevention (legitimate interests / legal obligations): detect spam, fraud, malicious activity, and policy violations; moderate content using automated AI systems and human review; rate limiting; and manage access tokens securely.
• Copyright and legal compliance (legal obligation / legitimate interests): handle DMCA notices and counter-notices, preserve evidence, and enforce repeat infringer policy.
• Purchases and entitlements (contract): validate App Store purchases, unlock Premium features and purchased books, keep your access in sync across devices, restore purchases, remind you before a free trial converts (a local notification on your device), and handle billing questions, refunds and disputes.
• Operate and improve the service (legitimate interests): diagnose outages, fix bugs, measure broad feature usage through first-party aggregate metrics, collect crash reports, and improve performance.
• Usage analytics (legitimate interest, or consent where required): we use Firebase Analytics to understand screen usage, sessions, and feature flows so we can make product decisions. It is on by default and does not use device advertising identifiers (Apple's IDFA or vendor identifier IDFV on iOS, Google's Advertising ID on Android) or ad personalization signals; where a consent message is required (for example in the EEA and the UK), analytics starts only after you accept it. You can turn it off at any time from Settings > Analytics.
• App marketing measurement (iOS only): we use AppsFlyer to attribute installs and conversions to advertising, measure campaign performance, and share selected conversion events with Meta Ads. We rely on our legitimate interest in measuring the advertising that funds Colora; you can object at any time from Settings > Analytics > Share Usage Analytics, which stops this measurement. Without Apple's tracking permission the measurement is aggregated and privacy-preserving (Meta Aggregated Event Measurement and Apple's SKAdNetwork); Apple's tracking permission, which we ask for only after you have seen the app, controls access to the IDFA.
• Sponsored content and consent management (consent / legitimate interests, depending on jurisdiction): show in-feed native ads and Colora first-party promotions, manage privacy choices for advertising, cap ad frequency, determine whether ads should be personalized or non-personalized, measure fill and delivery quality, prevent ad fraud/abuse, and investigate ad reports submitted through the app.

4. Retention

We retain personal data only as long as necessary for service operations, legal obligations, dispute resolution, and security/audit purposes. We may retain limited moderation metadata, such as outcomes, timestamps, enforcement decisions, and audit logs, as needed for safety, dispute handling, and legal compliance.

5. Sharing

We share data with:

• Service providers (processors): providers that help us operate Colora, including:
  • Firebase (Google) — authentication, usage analytics (Firebase Analytics, without advertising identifiers; can be turned off in the app), push notifications (Firebase Cloud Messaging), and crash reporting (Crashlytics), on both iOS and Android;
  • Google AdMob, Google User Messaging Platform, and Meta Audience Network — ad serving, mediation, privacy messaging, fraud prevention, frequency management, contextual relevance and brand safety (including public neighboring post-page URLs provided to AdMob), and measurement for sponsored content shown inside feed surfaces, on both iOS and Android (Meta Audience Network currently on iOS only);
  • Google Sign-In (Google) — federated authentication;
  • RevenueCat — in-app purchase infrastructure (iOS only): App Store receipt validation, subscription status and entitlement management, aggregate purchase analytics, and the AppsFlyer attribution connection described above;
  • AppsFlyer — iOS installation attribution, campaign measurement and conversion reporting, including selected event postbacks to Meta Ads;
  • Apple — payment processing for purchases made through the App Store (iOS only), under Apple's own terms and privacy policy;
  • Supabase — database hosting and serverless functions;
  • Cloudflare — content delivery, image storage (R2), web application security, and CAPTCHA (Turnstile);
  • Bunny.net — video hosting and streaming for user-uploaded video content;
  • OpenAI — automated moderation of text and images for policy compliance. Requests are routed through our secure proxy. We do not intentionally include direct profile identifiers such as your username or email in moderation requests, although the content you submit may itself contain personal information.
  These providers process data on our behalf under contractual terms.
• Apple (refund requests, iOS only): when you ask Apple for a refund of an in-app purchase, Apple may ask us about that purchase. With the consent you give in our Terms of Service, we share with Apple, through RevenueCat, whether the purchase was delivered, how much of the subscription period had been used, and our preference on the refund. We do not share your email, username or content. Apple decides on the refund under its own terms. You can withdraw this consent at any time by writing to af10srl@gmail.com.
• Meta Ads: selected iOS install, session, registration, checkout, trial and purchase events, event values and applicable attribution identifiers may be shared through AppsFlyer for campaign measurement and optimization, subject to applicable privacy choices. Meta processes advertising data under its own privacy terms.
• Other users: your public profile and content you choose to share are visible to other users according to product features. Direct messages are visible only to participants.
• Legal recipients: we may share information with rights holders, users, and authorities as required by law (including DMCA processing and subpoenas/court orders).

6. International Transfers

Where data is transferred internationally, we apply appropriate safeguards as required by applicable law.

7. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, object to processing of, restrict, or request portability of your personal data. To exercise any of these rights, contact us at af10srl@gmail.com. We will respond within the timeframe required by applicable law.

You can turn Firebase Analytics and, on iOS, AppsFlyer measurement off or on at any time from Settings > Analytics > Share Usage Analytics inside the app. Turning this setting off stops AppsFlyer SDK collection and requests removal of attribution identifiers and partner sharing for subsequent RevenueCat events; it does not cancel purchases or delete previously collected records. You can revisit ad privacy choices from Settings > Privacy & Ads on both platforms. On iOS, you can change Apple's tracking permission from the iOS Settings app after Apple's ATT prompt has been shown. On Android, advertising consent is managed through Google's consent framework (UMP/TCF) shown in the app where required, and you can reset or delete your Google Advertising ID from the Android system settings. If you decline tracking or withdraw advertising consent, you may still see ads, but they may be less relevant and may be served without identifier-based personalization where permitted by law. Minimal first-party aggregate metrics used to operate the service (such as authenticated app opens and top-level section visits) are separate from this analytics setting.

8. Account Deletion

You can delete your account directly from within the Colora app by navigating to Settings > Delete Account. The deletion process requires re-authentication for security. Upon deletion, your profile, posts, media files, and associated data are permanently removed from our systems.

You may also request account deletion by emailing af10srl@gmail.com.

Some data may be retained after deletion where required for legal compliance, security, fraud prevention, or dispute resolution (for example, DMCA records and moderation audit logs). Any retained data is kept only as long as legally required and is not used for other purposes.

9. Children

Colora is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child has provided personal data to Colora, please contact us at af10srl@gmail.com and we will take steps to delete that information. Users between 13 and the age of majority in their jurisdiction should have parental or guardian consent to use the service.

10. Security

We use technical and organizational controls to protect personal data, including access controls, logging, and abuse prevention.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes are effective when posted. The “Last updated” date at the top reflects the latest version. We encourage you to review this policy periodically.