Privacy Policy

Kids Coloring Games & Drawing
Effective Date: October 13, 2026

1. Introduction

EVL PPY SRL (“EVL PPY,” “we,” “us,” or “our”) provides Kids Coloring Games & Drawing (the “App”) for iOS and Android. We take the privacy and safety of children and families seriously.

The App is designed for children ages 2–8 and includes coloring, drawing, educational activities and optional AI-powered creation tools made available through a restricted Parents Area. This Privacy Policy describes the information we process, why we process it, the services involved, and parents’ choices and rights.

2. Children's Privacy and the Parents Area

Children can use the Kids Area to color, draw and explore educational activities. Children cannot upload photographs through the Kids Area. Photograph uploads and the associated AI generation functions are available only within a Parents Area protected by a parental verification step (a “parental gate”).

The parental gate helps restrict access to adult-facing features. It does not, by itself, constitute verifiable parental consent under laws that require such consent. Where applicable law requires verifiable parental consent before collecting or disclosing a child's personal information, we must obtain it through a legally sufficient process before that processing occurs.

Parents and legal guardians should supervise use of the App and submit only content that they are lawfully authorized to use. The App does not display third-party advertisements.

3. Information We Process

3.1 Automatically Generated App Identifier

The App generates an identifier automatically. It does not require a traditional account registration with an email address and password. The identifier may be used to associate the App installation or profile with relevant functionality, purchase entitlements, subscriptions, credit balances and service records. Although the identifier does not itself display a name or email address, it may constitute personal data under applicable law.

3.2 Photographs Uploaded by Parents

A parent may choose to upload photographs through the Parents Area to transform them into coloring pages. A photo may depict a child, another person, a pet or an object. Photos selected for generation are transmitted to an external AI service so that the requested image can be produced. We encourage parents to avoid uploading photographs containing unnecessary sensitive information.

3.3 AI Prompts and Descriptions

Parents may submit text descriptions to request new coloring images. These descriptions are transmitted for AI processing. Please do not include children's full names, addresses, contact information or other unnecessary personal details in prompts.

3.4 Subscriptions and Credits

Purchases of subscriptions and credits are made through the Apple App Store or Google Play. We may process purchase verification, entitlement and credit-balance information needed to provide purchased features, address purchase issues and prevent abuse. We do not collect full payment card details directly through the App.

3.5 Technical and Operational Data

Information needed to operate, secure and troubleshoot the service may be processed by us or our service providers. Depending on the actual implementation, this can include application version, device or operating system details, request times, error diagnostics and network data such as IP addresses. We do not use this information for targeted advertising.

4. Why We Use Information

We do not sell children's personal information and do not use children's information for behaviorally targeted advertising.

5. AI Image Generation and External Processing

AI image generation uses external services, including Runware and the Nano Banana 2 Lite model. The precise processing chain can depend on the provider configuration. When a parent requests generation, the selected photograph or written description is transmitted to the applicable AI processing service, which returns a generated result.

Finished coloring images are saved on the user's device by the App; we do not offer a cloud gallery of completed artwork. This does not mean that input photos, prompts or generated outputs are never temporarily held by the AI provider. External service providers may process and retain information according to their applicable terms, configurations and data-processing arrangements.

We seek to use the information only as needed for the requested generation and to apply appropriate protections for a child-directed service. AI outputs may be checked or restricted to reduce inappropriate content.

6. Storage and Retention

Completed coloring artwork is stored locally on the device, subject to the device's storage, backup and deletion behavior. Removing the App or clearing App data may remove locally stored artwork.

Photos and prompts are transmitted for external AI processing. Temporary provider-side storage or logs may exist even if the App does not maintain a permanent cloud gallery. Purchase records, automatically generated identifiers, credit balances and necessary operational data may be retained as needed to deliver services, meet legal obligations, prevent abuse and resolve disputes.

For information about a particular retention or deletion request, contact us at mobile@evlppy.com.

7. Third-Party Providers

Service providers receive only information relevant to the services they perform. We do not authorize them to use children's data for advertising on our behalf.

8. Security

We use reasonable technical and organizational safeguards intended to protect information. These include restricting photo uploads and associated AI tools to the Parents Area. Nevertheless, no storage or transmission method is entirely secure, and parents should avoid submitting unnecessary sensitive information.

9. Parents’ Rights and Choices

A parent or legal guardian may contact us to ask about personal data connected with the App, request access, correction or deletion where applicable, withdraw consent where legally available, or raise privacy concerns. We may need to verify the requester's authority before acting on a request concerning a child.

Email: mobile@evlppy.com.

10. GDPR and International Data Transfers

Where the General Data Protection Regulation applies, EVL PPY SRL is the controller of processing for which it determines the purposes and means. Depending on the activity, an appropriate lawful basis may include performance of a contract, a legal obligation, legitimate interests where permitted or consent where required. Processing involving children's personal data will be assessed under the heightened requirements that apply.

Eligible individuals may have the right to access, rectify, erase, restrict or object to certain processing, request portability, withdraw consent where consent is the basis, and lodge a complaint with a competent supervisory authority. Processing by external providers may involve international transfers, which must be covered by an appropriate legal transfer mechanism where required.

11. Advertising and Tracking

The App does not contain third-party advertising. We do not sell personal data, create targeted advertising profiles from children's activity, or use children's information for cross-app behavioral advertising.

12. Changes to This Policy

We may revise this Privacy Policy to reflect changes to the App, our providers, the law or our processing practices. We will provide appropriate notice, and obtain additional consent when required. The date at the top identifies the effective version.

13. Contact

EVL PPY SRL
Email: mobile@evlppy.com