Privacy Policy

EMPIRE GAMES SRL ("Empire Games", "we", "us", or "our") respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how information is collected, used, processed, and shared when you use Color Zen: Paint Coloring Book (the "App"), including its coloring, photo-to-coloring, artificial intelligence ("AI"), subscription, analytics, and notification features.

By using the App, you acknowledge the practices described in this Privacy Policy.

1. Who We Are

For purposes of applicable data protection laws, including the General Data Protection Regulation ("GDPR"), EMPIRE GAMES SRL is the data controller for personal information processed under this Privacy Policy, except where a third-party service acts as an independent controller.

2. No Account Required

Color Zen does not currently require you to create an account, register, provide your name, or provide an email address in order to use the App.

We may receive personal information if you voluntarily provide it to us, for example when you contact us for support, send feedback, report a technical problem, or submit a privacy request.

3. Information We May Collect

Depending on how you use the App, we and our service providers may process the following categories of information.

a. Photos and Images

Certain optional features allow you to select photographs or images from your Photo Library, capture photographs using your device camera, and transform photographs or images into coloring pages using AI.

The App will request access to your Camera and/or Photo Library only where required for features you choose to use and subject to Apple's permission controls. We do not access your entire photo library for unrelated purposes.

When you choose to use an AI feature, the selected image may be transmitted temporarily from your device to our servers and/or third-party AI processing providers in order to create the requested coloring page. The selected image is used for the purpose of processing your request and providing the AI feature.

We do not use imported photographs for advertising, behavioral profiling, facial recognition, or biometric identification. We do not intentionally use photographs submitted through the App to train our own AI models.

Images submitted for AI processing are transmitted temporarily as necessary to perform the requested generation. Third-party AI providers may process information according to their applicable privacy and data-processing terms. If you do not use the AI photo features, your photographs are not transmitted for AI processing.

b. AI Prompts and Generated Content

Color Zen allows you to enter descriptions or prompts that are used to generate coloring pages. The text you submit may be transmitted to third-party AI service providers that provide or host generative AI models, including models used by the App such as FLUX.2 and Nano Banana, or successor or replacement models.

Prompts are processed for the purpose of generating the content you request, maintaining security, preventing abuse, and operating the AI functionality. AI-generated content may be returned to your device and may be saved or exported by you using functionality available in the App or in iOS.

c. Analytics and Usage Information

We use Google Firebase services to understand how the App performs and how users interact with it. These services may process app interactions and usage events; device and installation identifiers; device type and technical characteristics; operating system and application versions; language and locale; approximate geographic information derived from technical data such as an IP address; and network, application, and performance data.

We currently use Firebase Analytics, Firebase Crashlytics, and Firebase Performance Monitoring.

d. Crash and Diagnostic Information

When the App experiences an error or crash, technical diagnostic information may be processed through Firebase Crashlytics or similar tools. This can include crash logs, device information, operating system information, application state, technical identifiers, and other diagnostic information relevant to identifying and fixing software problems.

e. Subscription and Purchase Information

Color Zen offers subscriptions and/or in-app purchases processed exclusively through Apple's App Store. We do not directly collect or store your payment card information. Apple processes payments according to Apple's own terms and privacy practices.

We use RevenueCat to manage subscription status, purchase entitlements, and related purchase history. RevenueCat may process purchase and subscription history, subscription status, product purchased, transaction and receipt information, anonymous or device-related application identifiers, and entitlement information.

Because Color Zen does not require an account, we do not intentionally provide RevenueCat with your name or email address for subscription management unless this functionality changes in the future.

f. Push Notifications

If you choose to allow push notifications, we use OneSignal to deliver notifications and related App communications. OneSignal may process device and push notification identifiers, IP address, operating system and device information, language, time zone, and notification delivery and interaction information.

You can disable push notifications at any time through the notification settings on your Apple device.

4. How We Use Information

We may use information described in this Privacy Policy to:

• provide and operate Color Zen;
• convert photographs into coloring pages;
• generate coloring pages based on text prompts;
• deliver and manage AI functionality;
• save, display, or export content as requested by you;
• provide premium functionality and manage subscriptions;
• validate and restore purchases;
• deliver push notifications where permission has been granted;
• understand how users interact with the App;
• diagnose crashes, errors, and performance problems;
• improve the App, its features, stability, and user experience;
• respond to support requests and communications;
• detect, prevent, and address fraud, misuse, security incidents, or prohibited activity;
• comply with applicable legal obligations; and
• establish, exercise, or defend legal claims.

We do not sell your personal information. We do not use your information for third-party behavioral advertising. The App does not currently display third-party advertisements.

5. Artificial Intelligence Processing

Some Color Zen features rely on generative artificial intelligence, including converting an imported photograph into line art or a coloring page, generating an original coloring page based on a written description, and processing images or prompts to create artistic output.

To provide these features, the information you choose to submit may need to leave your device and be transmitted temporarily to infrastructure operated by Empire Games and/or third-party AI service providers. These providers may host or provide access to AI models used by Color Zen, including FLUX.2 and Nano Banana.

AI service providers may change over time as we improve the App, replace models, increase reliability, or modify our technical infrastructure. We seek to limit the information transmitted to what is reasonably necessary to perform the requested AI operation.

Please do not submit photographs, prompts, or other material that you do not have the right to use. If a photograph contains another identifiable person, you should only upload it where you have the appropriate permission or other lawful right to do so.

Color Zen does not use uploaded photographs to identify individuals and does not create facial-recognition profiles or biometric identifiers from uploaded images.

6. Third-Party Service Providers

We currently rely on Apple Inc. for App Store distribution, in-app purchases, subscriptions, device permissions, and platform functionality; Google Firebase for analytics, crash reporting, diagnostics, and performance monitoring; RevenueCat for subscription management and purchase validation; OneSignal for push notifications; and third-party AI service providers for the infrastructure and processing required to generate or transform coloring pages.

These companies may process data on our behalf or, in certain circumstances, under their own privacy policies and legal obligations. Their processing may occur outside your country of residence, including outside the European Economic Area. Where required by applicable law, we use appropriate safeguards for international transfers of personal information.

7. Legal Bases for Processing – European Users

If you are located in the European Economic Area, United Kingdom, or another jurisdiction requiring a legal basis for processing, we generally rely on:

• Performance of a contract, where processing is necessary to provide functionality you request, such as AI generation or subscription features;
• Consent, where you grant access to your Camera, Photo Library, push notifications, or where applicable law otherwise requires consent;
• Legitimate interests, where necessary to improve the App, measure performance, prevent fraud and abuse, secure our systems, diagnose errors, and understand general App usage, provided those interests are not overridden by your fundamental rights; and
• Legal obligations, where processing is necessary to comply with applicable law.

You may withdraw consent where processing is based on consent. Withdrawal does not affect processing that occurred lawfully before consent was withdrawn.

8. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the App, comply with legal obligations, resolve disputes, prevent fraud or abuse, and protect our legal rights.

Photographs and images submitted specifically for AI generation are transmitted temporarily for processing and are not intended to be retained by Empire Games longer than necessary to provide the requested generation. Certain technical, analytics, subscription, and diagnostic information may be retained by our service providers according to their applicable retention periods and contractual or legal requirements.

Information you save locally on your device remains subject to your control and may remain on the device until you delete it, remove the App, or otherwise manage it through iOS.

9. Data Security

We use reasonable technical and organizational measures designed to protect information processed through the App. However, no method of electronic transmission, Internet communication, or data storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security of information transmitted through or stored in connection with the App.

10. Your Privacy Rights

Depending on where you live, you may have rights to request access, correction, deletion, restriction, objection, or portability of eligible personal information; withdraw consent where processing is based on consent; and lodge a complaint with a competent data protection authority. For users in the European Union, these rights include those provided by the GDPR.

To make a privacy or data deletion request, contact empiregames.ai@gmail.com.

Because Color Zen does not require an account, we may have limited ability to associate certain anonymous technical information with a specific individual. We may request information reasonably necessary to locate relevant data or verify a request. We will respond to valid requests in accordance with applicable law.

11. Data Deletion

You may request deletion of personal information associated with your interactions with Empire Games by contacting empiregames.ai@gmail.com.

Where applicable, we will delete or anonymize information that we control unless retention is required or permitted by law, including for legal, security, fraud-prevention, accounting, or dispute-resolution purposes. Information stored only locally on your device can generally be deleted by you through the App, iOS, or by removing the App. Information controlled independently by Apple or another third-party provider may need to be managed directly through that provider.

12. Camera and Photo Library Permissions

Access to your Camera and Photo Library is optional and used only when you choose functionality that requires it. You can modify or revoke these permissions at any time through iOS Settings. Revoking a permission may prevent certain App features from functioning, but you can continue to use functionality that does not require the affected permission.

13. Push Notification Choices

Push notifications are optional. You may enable or disable them through iOS Settings at any time. Disabling push notifications does not prevent you from otherwise using the App.

14. Children's Privacy

Color Zen is intended for a general audience and is not specifically directed to children under the age of 13. We do not knowingly request that children under 13 provide personal information directly to us.

If you are below the age at which you may independently consent to the processing of personal information in your country, you should use the App only with the involvement and consent of a parent or legal guardian where required by applicable law.

If we learn that we have collected personal information from a child in circumstances where parental consent was legally required and was not obtained, we will take reasonable steps to delete that information. Parents or guardians may contact empiregames.ai@gmail.com.

15. International Users and Data Transfers

Color Zen is available worldwide. As a result, information may be processed in countries other than the country in which you live. These countries may have privacy laws that differ from those of your jurisdiction. Where required, Empire Games takes appropriate steps to provide lawful safeguards for international transfers.

16. California and Other U.S. Privacy Rights

Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws, including rights relating to access, correction, deletion, portability, and certain forms of data sharing.

Color Zen does not currently sell personal information and does not use personal information for cross-context behavioral advertising. You may contact us at empiregames.ai@gmail.com to exercise applicable rights. We will not discriminate against you for exercising a privacy right provided by applicable law.

17. Links and Third-Party Services

The App or our website may include links to websites, platforms, or services operated by third parties. We do not control the privacy practices of independent third parties and encourage you to review their privacy policies.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the App, our technology, service providers, data practices, or applicable legal requirements. When we make changes, we will update the "Last Updated" date at the top. If changes are material, we may provide additional notice where appropriate or required by law.

19. Contact Us

If you have questions about this Privacy Policy, wish to exercise a privacy right, or would like to request deletion of your personal information, please contact: