Holy
Color (“we,” “us” or “our”) takes
your privacy seriously. This Privacy policy (“Privacy policy”) explains our
data protection policy and describes the types of information we may process
when you use one or more of our mobile applications (the “App”, “our App”) and
explains how we and some of the companies we cooperate processing that
information.
When we refer to personal data (or personal information) we mean
any information of any kind relating to an identified or identifiable natural
person.
It is a natural person who can be identified directly or
indirectly, in particular by reference to an identification number or to one or
more factors specific to his or her physical, physiological, mental, economic,
cultural or social status.
Our Privacy policy applies to all users, and others who access the
App (“Users”).
For the purposes of the GDPR, we are the data controller.
How We Use Your Information
We use your information for the following purposes:
- To provide and improve the Holy Color experience.
- To communicate with you regarding updates, promotions, or
support.
- To analyze app performance and user interactions to enhance
functionality.
- To ensure compliance with legal obligations and protect against
misuse of our services.
Sharing Your Information
We do not sell, trade, or otherwise transfer your personal
information to outside parties, except in the following cases:
- Service Providers: We may share information with trusted
third-party service providers to help operate our app (e.g., hosting services,
analytics providers).
- Legal Requirements: We may disclose your information if required
by law, regulation, or governmental request.
Data Security
We implement a variety of security measures to protect your
personal information. However, please note that no method of transmission over
the Internet is completely secure, and we cannot guarantee absolute security.
PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION
REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN
YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE
BOUND BY THESE TERMS. BY ACCESSING OR USING THE APP, YOU AGREE TO PROCESSING OF
YOUR PERSONAL DATA WHICH IS PROVIDED TO US IN LINE WITH THE TERMS OF THIS
PRIVACY POLICY.
There are two general categories of information we can process.
Information that you submit
We ask for and collect the following personal information about
you when you use the App. This information is necessary for the adequate
performance of the contract between you and us. Without such information it is
impossible to provide complete functionality of the App all perform the
requested services.
Authorization and/or Account Information. When you sign up for an
account, we require certain information such as your email address or Facebook
ID or Google ID – depending on the App settings.
Content Information, i.e. photos, pictures, video and audio files,
documents and other data that you upload using the App.
Personal Information which you may fill in by yourself when the
App is designed for tracking your info, storing your records and/or managing
them for your convenience and upon your explicit request.
Information That Is Processed Automatically
When you use the App, some information about your device and your
user behaviour may be processed automatically. This information is generally
non-personal, and we may access it only in aggregated form. We process this
information on the ground of our legitimate interest in improving our App and giving
our users the best experience. Otherwise we may not be able to provide you with
all the requested services and features of the App.
We use third-party automatic data processing technologies (such as
Google and Facebook) to analyse certain information sent by your device or our
App. Automatic data processing technologies (advertising or analytics tools)
provide us with the data described below. We do not control, supervise or
respond for how the third parties providing your information process your personal
data, and any information request regarding the disclosure of your personal
information to us should be directed to such third parties.
What data may be processed:
Advertisers / Advertising ID, device make and model, mobile web
browser type and version, IP address, MAC address and IMEI, account information
(email etc), the device’s operating system’s make and version, locale
information, MCC (Mobile Country Code) information, location and related data,
cookies and similar technologies.
Processing information through automatic data processing
technologies we use starts automatically when you start using the App.
The App may use automated processing of your personal data,
including profiling which means any form of automated processing of personal
data consisting of the use of personal data to evaluate certain personal
aspects relating to you, in particular to analyse or predict aspects concerning
your personal preferences, interests, behaviour, location or movements.
Our mission is to constantly improve our App and provide you with
new experiences. As part of this mission, we use your information for the
following purposes, In general our mission;
(a) To make our service available. We use information that you
submit and information that is processed automatically to provide you with all
requested services.
(b) To improve, test and monitor the effectiveness of our App. We
use information that is processed automatically to better understand user
behaviour and trends, detect potential outages and technical issues, to
operate, protect, improve, and optimize our App.
(c) To provide you with interest-based (behavioural) advertising
or other targeted content. We may use information that is processed
automatically for marketing purposes (to show ads that may be of interest to
you based on your preferences). We provide personalized content and information
to you, which can include online ads or other forms of marketing.
(d) To communicate with you. We use the information we have to
communicate with you through newsletters, i.e. to send you marketing
notifications, receive your feedback about our App experience, and let you know
about our policies and terms. We also use your information to respond to you
when you contact us.
(e) To prevent fraud and spam, to enforce of law. We really want
our App to be free of spam and fraudulent content so that you feel safe and
free. We may use your information to prevent, detect, and investigate fraud,
security breaches, potentially prohibited or illegal activities, protect our
trademarks and enforce our Terms of Use.
If any new purposes for processing your personal data arise, we
will let you know we start to process information on that other purpose by
introducing the corresponding changes to this Privacy policy.
We will share your information with third parties only in the ways
that are described in this Privacy Policy.
We collect the following categories of your personal information
and may share it to third parties: identifiers, commercial information,
internet or other electronic network activity information, geolocation data,
and inferences drawn from these categories.
We will not rent or sell your personal data to third parties, but
we may share your information from tools like cookies, log files, and device
identifiers and location data, with third-party organizations that provide
automatic data processing technologies for the App. We do not control or
influence these third parties’ tracking technologies or how they may be used.
We may also share certain information such as cookie data with
third-party advertising partners. This information allows third-party ad
networks, inter alia, to deliver targeted advertisements that they believe will
be of most interest to you.
We may use one or more of the following third-party advertising
services and analytics tools: Adjust; AdMob; Apple SearchAds; AppsFlyer;
Facebook; Firebase; Flurry; Unity: Fabric; Google AdWords; ironSource; Mopub;
Appcalibre ; OneSignal ; Kochava ; Applovin; Inmobi; Ogury, Startapp. In case
you want to learn more about the services and privacy options please consult
their websites and privacy policies.
Our App may use certain third-party service providers like Amazon
Web Services (AWS) to enhance user experience. Use of third-party services may
require us to submit your personal information to their servers that provide
automatic data processing technologies for the App.
Our App may contain links to third-party websites/services or you
may access the App from a third-party site. We are not responsible for the
privacy practices or the content of these third-party sites or services linked
to or from our App, including the information or content contained within them.
We may disclose your personal information if it needed for
objective reasons, due to public interest or in other unforeseen circumstances:
– as required by law;
– when we believe in good faith that disclosure is necessary to
protect our rights, protect your safety or the safety of others, investigate
fraud, or respond to a government request;
– if we are involved in a merger, acquisition, or sale of all or a
portion of its assets, you will be notified via email and/or a prominent notice
in our App of any change in ownership or uses of your personal information, as
well as any choices you may have regarding your personal information.
We work in the international space and provide our App to our
Users around the world.
We and third-party organizations that provide automatic data
processing technologies for the App or our third-party advertising partners may
transfer the automatically processed information across borders and from your
country or jurisdiction to other countries or jurisdictions around the world.
If you are located in the European Union, US or other regions with
laws governing data processing that may differ from England & Wales law,
please note that we may transfer information, including personal information,
to a country and jurisdiction that does not have the same data protection laws
as in your jurisdiction.
This means that your personal information can be transferred to a
third country, a territory or one or more specified sectors within that third
country, or to the international organization where data protection and
confidentiality regulations may not provide the same level of protection of a
personal data as your country does.
We try to make sure that the recipient of any personal data
provides a proper protection of the personal data received, in accordance with
the current legislation on the protection of such information. By using the
App, you agree that we may transfer your personal data to any third country, a
territory or one or more specified sectors within that third country, or to the
international organization.
For the purposes of data storage, we recourse to the services of
the hosting organizations. We take your privacy seriously and, therefore,
encrypt your personal data before sending it to the hosting organizations for
the purposes of its storage. Please note that we cooperate only with those
hosting organizations that have passed our security and reliability check.
We generally retain your personal information for as long as is necessary
for the performance of the contract between you and us and to comply with our
legal obligations. If you no longer want us to use your information that we
physically access and store, you can request that we erase your personal
information and close your account.
However, some data may still be stored for a certain time period
if information is necessary to comply with legal obligation (taxation,
accounting, audit) or in order to maintain safety and data backup settings,
prevent fraud or other malicious acts.
For the data we store and access you are entitled to address us
regarding the following issues:
Data Access and Portability. You can request copies of your
personal information held by us.
Change or Correct Data. Where you cannot update data by yourself
through your account, you have the right to ask us to correct change, update or
rectify your data.
Data Retention and Deletion. We generally retain data for as long
as your account is in existence or as needed to provide the App. However,
specific retention times can vary based on context of the processing we perform
and on our legal obligations. You have the right to ask us to delete all or
some of the personal data we hold about you. If you have an account, you can also
delete your account at any time. We may need to retain some of your personal
data even after you have closed your account if reasonably necessary to comply
with our legal obligations, or where we have a legitimate interest in doing so
(e.g. to prevent fraud and abuse and maintain and enhance security).
Restriction of Processing. Under certain circumstances, you may
have the right to limit the ways in which we use your personal information.
Please bear in mind that we ensure the above mentioned rights only
with respect to the information that you submit.
When your personal information that is processed automatically you
may object to such processing in some circumstances. Where your personal
information is processed for direct marketing purposes, you may ask to cease
processing your data for these direct marketing purposes. In order to exercise
your right please contact the third party services listed in the Section IV of
this Privacy Policy to learn how you can object to processing your data. Most
of them have clear instructions on their privacy pages, functional API or other
options.
Please note that you can opt-out of marketing tracking by emailing
the developer account.
The security of your personal information is important to us. We
follow generally accepted industry standards to protect the personal
information submitted to us, both during transmission and once we receive it.
We take reasonable and appropriate measures to protect personal
information from loss, misuse and unauthorized access, disclosure, alteration
and destruction, taking into account the risks involved in the processing and
the nature of the personal information.
We implement appropriate technical and organizational measures,
which are designed to implement data-protection principles, such as data
minimization, in an effective manner and to integrate the necessary safeguards
into the processing. We seek your personal data to be encrypted with proper and
strong encryption algorithms, including hashing where possible.
Unfortunately, no method of transmission over the Internet, or
method of electronic storage, is 100% secure. We do our best to protect your
personal data, nevertheless, we cannot guarantee its absolute security. In the
event that your personal information is compromised as a breach of security, we
will promptly notify you in compliance with applicable law.
Our App is not intended for children under the age of 18.
Therefore, we do not knowingly collect or solicit any personal information from
children under 18. No one under age 18 may provide any personal information to
the App. If you are under 18, do not use or provide any information on this App
or through any of its features. Do not provide any information about yourself,
including your email address. If we learn that we have collected personal
information from a child under age 18 without verification of parental consent,
we will erase that information as quickly as possible. If you believe that we
might have any information from or about a child under 18, please contact us.
This Privacy policy may change from time to time.
Whenever we change this Privacy policy, we will post those changes
to this Privacy policy and other places that we consider appropriate.
Additional forms of notice of modifications or updates as appropriate under the
circumstances may be provided to you.
If you have any questions about this Privacy Policy,
please feel free to contact us at this email: admin@coloringgameapp.com