Privacy Policy

As used in this Privacy Policy, “We”, “Us” or “Our”, refers to “ColorMe”.


This Privacy Policy is part of and incorporated by reference into the Terms of Service (the “Terms”) governing the use of all our branded software applications (the “Application/s”), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the Applications and/or URL which may replace it or which may be added to the list of websites published by us and linking to this Privacy Policy (the “Website/s”).



By agreeing to the Terms and/or using the Websites or the Applications, you particularly agree to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may collect and/or you may be asked to provide us with your information (including personal information) any time you are in contact with us or use the Applications or the Websites.



Please read this Privacy Policy in order to learn more about the data we collect, what do we use it for and how we protect your privacy.



We reserve the right to update this Privacy Policy from time to time. We will notify you (for example, by email or through our Application) at least 30 days before we make changes to these Terms and Policy and give you an opportunity to review them before they go into effect, unless changes are required by law. Once any updated terms are in effect, you will be bound by them if you continue to use our Application.



We hope that you will continue using our Application, but if you do not agree to our updated terms, you can delete your account at any time.


1. Information That We Collect


Collection of device and technical information


We might collect the data necessary for you to use our app and for us to maintain and analyze the functioning of the app and to personalize the content of the app.


We automatically obtain certain information about your computing device, including IP address; Country code; Time zone; session start/stop time; IDFVs, Language; Network status (WiFi, etc.), browser plug-in types and versions; platform, SDK version, timestamp; Technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software API key identifier for application, Push notifications token. Although some of this information (such as IDFA, IDFV, IP address) may uniquely identify your device, this information does not identify you personally. Some legislation (such as US) may treat information that uniquely identifies your device as personal information.


2. Purposes of Collecting, Processing and/or Disclosing


• Detecting/Protecting against security events


• Internal analytics and reporting


• Customer service


• Operate our business and games


• Game mechanics or functionality


• Facilitate players’ social interactions


• Product development/improvement


• Maintaining and enhancing service


• Auditing consumer interaction & transactions


• Advertising


• Direct marketing


• Player acquisition



3. How We Use Your Information


We shall use your personal information for the following purposes:


To Provide Our Services


We use your personal information to provide you with our mobile application and any other Services you request. This may include processing transactions, providing you with the requested features, syncing your painting history across your devices logged into your account, customer service, etc.


To Personalize Your Experience


We may process your information to personalize the Services for you. For example, we use your language preferences and country location to display the correct language and time zone in the Services. We also use certain information about your device (such as operating system version and screen resolution information) to optimize the display of pictures on your screen.


We will use your information (such as contact information) to send you communications about your account, requested transactions, and changes in our policies. Please note that you may not opt out of such communications, which are necessary to keep you informed about important updates about your account and the Services.


To Conduct Analytics and Other Internal Purposes


We may use your personal information to conduct analytics. This can be used for quality control, internal auditing, and to measure how our mobile application and ad campaigns are performing.


To Ensure Security of our Services


While we are offering services, it is used for the purposes of identity verification, customer service, security protection, fraud monitoring, archiving and backups, ensuring the security of the products and services that we provide to you.


To Conduct Research and Development


We may process your personal information to improve our existing Services and help us design new ones. When we do so, we may implement security measures and safeguards to protect the privacy of your personal information. For example, we may institute technical safeguards or administrative safeguards, such as restricting access to personal information to only those who need access to conduct the research and development functions.


To Promote Our Services


We use your personal information for our marketing activities. For example, we may conduct targeted marketing and send you information about our and our partners’ products, events, and market studies that may be of interest to you.


To Maintain Legal and Regulatory Compliance


Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, and to manage risk as required under applicable law.



4. Sharing of Your Information


We may share your personal information in the following circumstances.


Affiliates


We are multinational organization, with cross-border legal entities and management structures. We may share your personal information within our corporate organization to facilitate the Services; however, we will require that your personal information still be handled in the manner describe herein.


Third-Party Service Providers


We may use third parties to perform certain functions on our behalf to provide you with the Services such as:


to process payments and complete transactions you request, such as payments for our subscription service, which is processed by Apple (App Store) or Google (Google Play Store);


to process and store data, including your personal information;


to provide security for our Services; and


to conduct market research.


We have agreements with third-party service providers in place to ensure they use adequate safeguards when processing your personal information.


Merger, Acquisition, or Other Business Transaction


We may disclose and transfer your personal information to a subsequent owner, co-owner, or operator or the Services, or in connection with a merger, acquisition, consolidation, restructuring, or the sale of substantially all our interests and/or assets (i.e., a bankruptcy proceeding). We shall require the subsequent owner, co-owner, or operator in possession of your personal information to continue to be subject to this Privacy Policy; otherwise, we shall request that they obtain the necessary consent from you.


Legal Obligations and Safety


We may disclose your personal information if it is reasonably necessary to:


Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.);


Comply with valid requests or investigations by public authorities;


Comply with applicable laws or regulations;


Enforce our policies, agreements, and terms, whether in litigation, other disputes, or otherwise;


Protect our legitimate interests, including legal interests;


Protect the security or integrity of the Services; or


Protect the rights, property, or safety of you, other users, employees, partners and affiliates, or other natural persons.


We will, at our discretion, provide you with advance notice if we are compelled to disclose your personal information to law enforcement, public authorities, or other governmental entities, unless we are prohibited from doing so by governmental entities or the law.


With Your Consent


We may transfer your personal information for other reasons after obtaining your consent.



5. How to Exercise Your Rights


You may access, amend and delete information provided by you when using our Applications, or contact us at alyg82757@gmail.com. The scope and the way in which you access, amend or delete your personal information depend on the service you use.


You may opt-out of receiving promotional communications, such as marketing emails we send you, at any time. If you wish to do so, please e-mail us at alyg82757@gmail.com. You can turn off push notifications by visiting the “options” or “settings” page within the relevant games.


You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). For personalized in-game offers opt-out, you can use the options provided in the game settings.


If for any reason you are concerned with the way we are using your personal information, or would like to correct or request that we delete such personal information, please contact us using the information in the “Contact Us” section below. We will respond to your request as promptly as possible.


In some cases, we may not be able to delete your personal information and will retain and use our information as long as necessary to comply with our legal obligations, resolve disputes, and/or


enforce our agreements.



6.Tracking Technologies


What are cookies and tracking technologies?


Cookies are small data files, typically of letters and numbers, that are placed by a web server on your device. We and companies we work with may use cookies and similar technologies, including pixel tags, web beacons, mobile analytics features, and mobile identifiers (collectively, “tracking technologies”) to collect information for many reasons, such as to keep you logged in to your account, remember your preferences and settings, analyze usage of our Services, measure the performance of our Services and advertising campaigns, and ensure security on our Services. Some of the functions performed by tracking technologies are strictly necessary for us to be able to offer you our Services, while others provide us with valuable insight about how we can improve or market our Services.



Through Third Parties


You may also check the third party’s website below for information about how they use tracking technologies to collect and use your information, and how you may be able to opt out of tracking.


Google Firebase Analytics: To conduct usage and advertising analytics


https://policies.google.com/privacy?hl=en-US


Facebook Analytics: To conduct usage and advertising analytics


https://www.facebook.com/policy.php


https://www.facebook.com/policies/cookies


Appsflyer: To conduct usage and advertising analytics


https://www.appsflyer.com/privacy-policy/


AdMob


https://support.google.com/ads/answer/2662922


https://support.google.com/admob/answer/9012903


Max


http://maxads.io/optout.html


Adcolony


https://www.adcolony.com/privacy-policy/


AppLovin


https://www.applovin.com/privacy


Chartboost


https://answers.chartboost.com/en-us/articles/200780269


Facebook


https://www.facebook.com/help/568137493302217


https://www.facebook.com/about/privacy/update?ref=old_policy


Fyber


https://www.fyber.com/legal/privacy-policy/


Google (Ad Words)


https://support.google.com/ads/answer/2662922?hl=en;


Google


https://policies.google.com/privacy


Inneractive


http://inner-active.com/privacy-policy/


Mopub


https://www.mopub.com/legal/privacy/


Mintegral (Mobvista)


https://www.mintegral.com/en/privacy/#yourDataRights


Unity


https://unity3d.com/legal/privacy-policy


Ironsource


https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/


Vungle


https://vungle.com/privacy/


Appsflyer


https://www.appsflyer.com/services-privacy-policy


https://www.appsflyer.com/terms-of-use/



7. Advertising


We are included with third party advertising for their products and services. We and our partners use your information to improve advertising and targeting to measure the relevant third-party ads to show in our games. Information we may have about you such as: ad identifiers and other non-personal information collected from your device, how you interact with our game and Services the game play information, your age, country or region, and gender, and other information collected from third parties with legal right to share it with us are used to make sure that you only see ads from us that might be of interest to you.


Advertising Partners


Non-personal identifiers and other information collected from your device when you play our games or use our Services are shared with advertising partners in order to technically deliver the ads to your device. Such information may be combined with collected information of our advertising partners own to serve you with more relevant ads and to enhance the accuracy of their targeting. For more information we recommend for you to scan through our partners’ privacy policies on their websites.


Ad Identifiers


We use ad identifiers that are non-permanent, non-personal identifiers such as the Android and/or Apple’s ID for advertising associated with your device, and similar technologies such as tracking pixels within ads to provide interest-based advertising. These technologies enable us and our third-party advertising partners to recognize you and your device, allow our Services to interact with a third-party social network or platform and help our payment processors to work it out your payment instructions.


How to reset your preferences for advertising


You may reset your ad identifier being used for interest-based advertising by changing the settings of your device usually found under “privacy” or “ads”. You can also opt-out from your information being collected if you live in the USA, Europe or Canada by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for European users) or http://youradchoices.ca/choices (for Canadian users). The full use of our Services may not available if you choose to adjust your preferences.



8. Security


We take the security of personal information seriously. We adopt standard practices in the internet industry to protect your personal information from unauthorized access, disclosure, use, alteration, and corruption or loss. We shall take all reasonable and feasible measures to protect your personal information. We shall do everything possible to take appropriate technical measures to ensure the accuracy and timely update of the personal information collected about you.


Please understand that due to the nature of the internet industry, it is impossible to ensure that systems are 100% secure. You should understand that the systems may encounter issues due to the factors beyond our control, such as malicious actors. Although the security of your personal information is our highest priority, there will always be a risk that your Personal Information gets compromised. We also depend on you to keep your account information and other personal information secure by keeping your password confidential and taking precautions to keep others from accessing your account.



9. Retention


In general, we keep your information for as long as necessary to achieve the purposes stated in this Policy or to comply with the applicable law.


We recognize that retention requirements can vary between jurisdictions, but we generally apply the retention periods described below.


Account information:


We will retain information associated with your account as long as your account remains active or as necessary to provide you with the requested services.


Information collected from tracking technologies:


We generally retain such information for as long as necessary for usage analytics, the establishment or defense of legal claims, audit, or fraud and/or crime prevention purposes.


Marketing data:


Any contact information you provide to us for marketing purposes, such as your name, email address, and phone number, is retained on an ongoing basis until you unsubscribe from our marketing communications. If you unsubscribe, we will add your contact information to our do-not-contact list to respect your unsubscribe request.



10. Children (COPPA)


Our Services are not intended for use by children under the age of sixteen (16). We will not knowingly collect personal information directly from children under the age of sixteen (16) without parental consent. If you are under the age of sixteen (16), please do not provide us with information of any kind whatsoever. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received information from a child under the age of sixteen (16), please contact us immediately.


To use and play our Services you must be over a certain age depending on where you live. For the full list of age restrictions by country, please see below. We do not knowingly collect personal information from or direct or target interest-based advertising to anyone under the ages set out below. We also do not knowingly allow such persons to use our Services, if in any way such personal data have been processed under the age set out below, please contact us so we can delete that information as quickly as possible.


Please see below listed with age you must be to play and use our games and Services depending on which country you are in while using our games and Services. Please do not play our games or use our Services if you are under the relevant age.



11. Do Not Track


Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit “Do Not Track” (“DNT”) signals. Since uniform standards for DNT signals have not been adopted, we currently do not process or respond to DNT signals on our Services.



12. Special Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland (GDPR)


This section only applies to individuals located in the European Economic Area (“EEA”), United Kingdom (“UK”), or Switzerland (collectively, the “Designated Countries”) at the time their personal information was collected.


We may ask you to identify which country you are in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in the Designated Countries.



13. California Privacy Rights (CCPA)


If you live in California, you can ask us for a list of third parties we share your Personal Information with for marketing purposes.


California law permits California residents to ask us for a notice that identifies the categories of personal information that we share with our affiliates and/or third parties for marketing purposes, and that provides contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us with your name, account information, and proof of California residence with the subject line “My California Privacy Rights” by email.


General Data Protection Law (GDPL)


The General Data Protection Law (GDPL), also referred to as LGPD in Portuguese (Lei Geral de Proteção de Dados Pessoais) is a Federal Law in Brazil that comprehensively regulates data protection.


We enable compliance with the GDPL mechanisms and data protection measures when we process personal data. If you have any questions regarding GDPL compliance please contact us by email.



14. Enforcement


We periodically review our compliance with this Privacy Policy. When we receive formal written complaints regarding privacy issues, it is our policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between us and an individual.



15. Changes to this Privacy Policy


We may amend this Privacy Policy from time to time. Any changes will be placed here and the amended version will supersede this version of our Privacy Policy. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. We will take reasonable steps to draw your attention to any changes in our Privacy Policy. However, to be on the safe side, we suggest that you read this document each time you use the website to ensure that it still meets with your approval.


We will notify you (for example, by email or through our Application) at least 30 days before we make changes to these terms and give you an opportunity to review them before they go into effect, unless changes are required by law. Once any updated terms are in effect, you will be bound by them if you continue to use our Application.


We hope that you will continue using our Application, but if you do not agree to our updated terms, you can delete your account at any time.



16. Contact Us


For any questions regarding our Privacy Policy or our privacy practices, please contact us at alyg82757@gmail.com