Privacy Policy

1. Information We Collect

1.1 Purchase and Account Information

When you purchase the Software through our authorized payment processors or Merchant of Record (MoR) providers, they provide us with limited information related to your order, such as:

• Your email address
• Country or region
• Order ID, product, and pricing details
• License information (for example, plan type, renewal status)

We do not receive or store your full payment card details. Payment processing is handled by our third-party payment processors.

1.2 License and Activation Information

To operate our license system and prevent abuse, we may process:

• License keys and related metadata
• Hashed or anonymized device identifiers
• Basic activation logs (timestamps, IP region, license status, error codes)

We avoid storing raw hardware identifiers where possible and prefer hashed or pseudonymous values.

Specifically, activation transmits your license key, a generated device identifier, and your device's host name (which may contain a personal name if you named your computer after yourself) to our license server. License data is stored locally in your operating system's secure credential store.

1.3 Technical and Server Logs

When you access our website or license server, we may automatically log:

• IP address (or IP region)
• Browser/user agent
• Referrer (if any)
• Pages or endpoints requested
• Timestamps and basic error logs

We use this information to keep the service secure, debug issues, and understand basic usage patterns (e.g., which endpoints are failing).

1.4 Content and Files

Our goal is that your creative content (images, sketches, PDFs, video files, etc.) stays on your own device.

• The desktop Software is designed to process your images and projects locally.
• We do not upload your project files, images, or creative content to our servers, other than what is technically necessary if you choose to use certain cloud/online features (if any are introduced later).

If in the future we introduce optional cloud features that require uploading content, we will clearly explain this and update this Policy.

How AI generation handles your content — entirely on your device in Local AI mode, or sent to a provider you choose in API mode — is described in AI Processing below.

1.5 Communication and Support

If you contact us by email or support form, we may collect:

• Your name (if provided)
• Email address
• Message contents and attachments

We use this information only to respond to your inquiries and maintain a record of support conversations.

2. How We Use Your Information

We use the information we collect for:

• Processing purchases and issuing licenses
• Validating and managing software licenses
• Providing customer support and answering questions
• Operating and securing our website and license server
• Understanding basic usage patterns to improve the product
• Measuring the performance of our TikTok ads and helping TikTok show our ads to relevant audiences, only with your separate Advertising consent (see Section 3.4)
• Complying with legal and tax obligations (for example, financial record-keeping)

We do not sell your personal information for money.

If you enable advertising cookies, the TikTok Pixel and the TikTok Events API disclose limited identifiers to TikTok for ad measurement and targeted advertising. Under some US state privacy laws (for example, the California Consumer Privacy Act as amended by the CPRA) this may be considered "sharing" of personal information for cross-context behavioral advertising, or "targeted advertising". It happens only with your Advertising consent, and you can opt out at any time (see Section 6).

3. Data Sharing and Third Parties

3.1 Payment Processing

We use third-party payment processors or Merchant of Record (MoR) providers to handle payments, tax/VAT, and invoicing. These providers process your payment details and share order-related information with us (such as your email and country). For more details, please see the privacy policy of the applicable payment processor displayed during checkout.

3.2 Hosting and Infrastructure

We may use trusted service providers to host our website and license server, such as:

• Cloudflare Pages or similar hosting providers
• DNS / CDN and security services
• License validation (Cloudflare Workers)

These providers may process IP addresses and technical data as part of normal web hosting and security.

3.3 Email Delivery

We use third-party email providers to send transactional emails, such as order confirmations, license emails, and important product updates. These providers process your email address and email contents to deliver messages.

3.4 Analytics and Advertising Measurement

We use Google Analytics 4 (GA4) and Microsoft Clarity to understand general usage trends (for example, number of visits, most viewed pages, and user behavior). Microsoft Clarity records session replays including mouse movements, clicks, and scroll data; sensitive fields are automatically masked. These analytics tools are only activated after you provide your consent. For full details, see our Cookie Policy.

Only if you give our separate Advertising consent, we also use the TikTok Pixel to measure which of our TikTok ads lead to visits, trial sign-ups, and purchases, and to help TikTok show our ads to people likely to find them useful. With that consent (and, for events about a trial, your Analytics consent as well), our servers may also report the same events (trial sign-up, first activation of a trial license, and purchase) to TikTok through the TikTok Events API. The identifiers we share are limited to the TikTok click ID, the TikTok browser cookie ID, and SHA-256 hashed values of your email address and our anonymous journey ID. We never share your name, license key, or payment details with TikTok. You can withdraw Advertising consent at any time via Cookie Settings; this stops the pixel and cancels any trial-related events that have not been sent yet. TikTok's processing is described in the TikTok Privacy Policy.

3.5 AI Providers (API Mode)

If you enable API mode, the third-party AI provider you configure (for example, OpenAI, Google, Anthropic, Stability AI, or a custom endpoint) processes the prompts and images you send, using your own API key and under that provider's own privacy policy. This is a direct connection from your device; we do not receive or store this content. Local AI mode uses no third-party AI provider.

3.6 Legal Requirements

We may disclose information if required by law, regulation, or valid legal process, or to protect our rights, property, or safety.

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

4. Data Security

We take reasonable technical and organizational measures to help protect your information, including:

• HTTPS/TLS encryption for data in transit
• Access controls for administrative accounts
• Minimizing the amount of personal data we store
• Using hashed or pseudonymous identifiers where practical

However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security, but we aim to follow sensible best practices for a small software vendor.

5. Data Retention

We generally retain information for as long as necessary to:

• Provide and support your license (for example, to verify past purchases)
• Maintain accurate financial and tax records (often up to 7 years)
• Resolve disputes and enforce our agreements

Advertising data is kept for shorter periods: the TikTok click identifier is stored in your browser's local storage for up to 28 days; TikTok click and cookie identifiers stored with a trial record are deleted 30 days after the trial is issued; and server-side advertising events are delivered or discarded within 7 days, with their identifiers deleted as soon as delivery completes, fails, or is cancelled.

If you request deletion of your personal information, we will remove or anonymize data where feasible, except where we are legally required to keep certain records (for example, invoice data).

6. Your Rights

Depending on where you live and which laws apply, you may have rights such as:

• Access: request a copy of personal data we hold about you
• Rectification: ask us to correct inaccurate or incomplete data
• Deletion: request deletion of certain personal data ("right to be forgotten")
• Restriction: request that we limit certain types of processing
• Objection: object to specific uses of your data, where applicable
• Portability: receive certain data in a structured format
• Opt-out of sharing and targeted advertising: stop the disclosure of your data to TikTok for advertising
• Withdrawal of consent: withdraw analytics or advertising consent at any time, without affecting processing carried out before the withdrawal

To opt out of sharing and targeted advertising, use "Your Privacy Choices" or "Cookie Settings" in the website footer and turn Advertising off. We also honor the Global Privacy Control (GPC) signal: while your browser sends it, "Accept All" does not enable advertising cookies. Opting out takes effect immediately for the browser you use and cancels trial-related events that have not yet been sent to TikTok. We will not treat you differently, for example by charging a different price or offering a different license, because you exercised any of these rights.

We will handle such requests in line with applicable data protection laws.

To exercise these rights, contact us at: [email protected]
We may need to verify your identity before acting on your request.

7. Cookies and Tracking

Our website uses cookies in the following categories:

• Strictly Necessary Cookies: Essential for the website to function properly, such as security and session management. These cannot be disabled.
• Analytics Cookies: We use Google Analytics 4 and Microsoft Clarity to analyze traffic patterns and user behavior. These cookies are only activated after you provide your consent via our cookie consent banner.
• Advertising Cookies: We use the TikTok Pixel to measure our TikTok ads. These cookies are only activated after you enable the separate Advertising category in our cookie consent banner.

Advertising cookies are never set without your Advertising consent. For a complete list of cookies, their purposes, and how to manage your preferences, please see our Cookie Policy.

8. Children's Privacy

Our website and Software are not intended for children under 16. We do not knowingly collect personal information from children.

If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to remove it.

9. International Data Transfers

We are based in the Republic of Korea, and the providers we work with process data outside Korea and possibly outside your own country. The table below lists each overseas recipient, what is transferred, why, and the legal basis. Transfers that are necessary to provide the website, the trial, or your license happen without separate consent, as permitted by Article 28-8 of the Korean Personal Information Protection Act; analytics and advertising transfers happen only with the consent you give in our cookie banner, and you can refuse or withdraw that consent at any time without any effect on your ability to use the website or the Software.

Refusing or withdrawing consent for a transfer: use Cookie Settings in the website footer, or contact us at [email protected]. Refusal has no effect other than that the related analytics or advertising data is not collected or transferred. We rely on these providers' documented safeguards (for example, standard contractual clauses, certifications, or equivalent measures) and applicable data protection laws to protect your information.

10. AI Processing

10.1 Local AI

In Local AI mode, image and text generation runs entirely on your device. Prompts, images, and outputs are not transmitted to us or to any third party.

10.2 API Mode

When you route a task to a cloud provider, your prompts, reference images, and related text are sent directly from your device to the provider you configured (OpenAI, Google, Anthropic, Stability AI, or a custom endpoint), using your own API key and subject to that provider's privacy policy. We do not receive, store, or process this content.

10.3 AI Model Downloads

Downloading the local AI models contacts huggingface.co and/or cdn.coloringbook.dev. These requests carry standard technical metadata (IP address, user agent) but no personal content.

11. Desktop Application Telemetry

The desktop application itself contains no analytics, telemetry, or crash-reporting instrumentation. The analytics described in this policy apply to our websites only.

License activation is the exception to keep in mind: when the application activates a license, it contacts our license server, which records the activation. If you gave consent on our website when you requested a trial, the first activation of that trial may be reported to Google Analytics and, if you also gave Advertising consent, to TikTok, as described in Section 3.4. No information about your projects, prompts, images, or usage inside the application is included.

12. Microsoft Store

If you install the application from the Microsoft Store, Microsoft may process installation and usage data under the Microsoft Privacy Statement, independently of this policy.

13. Notice at Collection (California and Other U.S. States)

This section is provided for residents of California and other U.S. states with similar laws, to the extent those laws apply to us. It summarizes, at or before the point of collection, the categories of personal information we collect, why, whether we sell or share them, and how long we keep them. We do not collect sensitive personal information as defined by those laws, and we do not sell personal information for money.

"Sharing" means disclosing personal information to a third party for cross-context behavioral advertising. We share only with TikTok, only with your Advertising consent, and you can opt out at any time using "Your Privacy Choices" in the website footer (see Section 6). We also honor the Global Privacy Control signal as an opt-out. We do not knowingly sell or share the personal information of consumers under 16.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date and, where appropriate, provide additional notice (for example, via email or through the Software).

Your continued use of the website or Software after changes take effect constitutes acceptance of the updated Policy.

15. Contact Us

If you have questions or concerns about this Privacy Policy, or if you wish to exercise your data rights, please contact: