Privacy Policy — Kids Coloring World

# Privacy Policy — Kids Coloring World

_Last updated: 7/16/2026_

This Privacy Policy describes how **Giovanni Emanuele Spina** ("we", "Data Controller") processes personal data collected through the application **Kids Coloring World** (`app.kidscoloringworld.app`), distributed on **iOS** and classified as **Utility / Strumenti**.

## 1. Data Controller
- **Developer / Company:** Giovanni Emanuele Spina
- **Contact email:** creo.app.app@gmail.com
- **Website:** https://appcodeengine.com/

## 2. Access to content
The app does not require registration and does not provide user account creation. All content is accessible to every user without authentication.

## Data collected
The app collects only the data listed below, limited to the features actually enabled in this version:
- **Advertising (Google AdMob):** device advertising identifier (AAID/IDFA when granted), approximate IP address, basic device information and ad interaction data.
- **App Tracking Transparency (iOS):** tracking consent status. No tracking data is collected if the user does not grant permission.

## 3. Content loaded via WebView
The app loads web content via WebView from **https://kifds-art-studio.lovable.app/**. Any data processed during browsing is handled directly by the website and is subject to its own Privacy Policy. The app does not modify or intercept data transmitted between the user and the site.

## 5. Native features used
The following native features are actually present in the app; each collects only the data necessary for its operation:
- **File / Document Picker:** the user can choose files from the device to attach or send via the WebApp.
- **File download:** downloaded files are saved to the device Downloads folder. We do not keep copies on our servers.

## 6. Advertising (Google AdMob)
The app displays advertisements via **Google AdMob** in the following formats: banner. AdMob may collect the device **Advertising Identifier** (AAID on Android, IDFA on iOS when granted), approximate IP address, device information and ad interaction data.
Ads are configured in **child-directed mode** (COPPA / Google Families / Apple Kids Category tag): AdMob is instructed not to use personalized advertising identifiers and not to serve behaviorally targeted ads.
More info: https://policies.google.com/technologies/ads

## 7. App Tracking Transparency (iOS)
On iOS the app uses Apple's **App Tracking Transparency (ATT)** framework. On first use, a prompt may be shown requesting permission to use the advertising identifier (IDFA) for measurement and advertising purposes. The user may:
- **Grant consent**, authorizing IDFA reading by AdMob and the declared SDKs;
- **Deny consent**: in that case IDFA is not shared and only non-personalized ads are served.
The app remains fully functional even if ATT consent is denied. The choice can be changed at any time via iOS Settings → Privacy → Tracking.

## 11. File upload and download
- **Upload:** the user can select files from the device to send to the hosted website. Files are transmitted to the site and handled according to the site's own Privacy Policy.
- **Download:** downloaded files are saved to the device Downloads folder. We do not keep copies on our servers.

## 12. Sharing data with third parties
Data may be transmitted to the following providers exclusively for the purposes described above:
- Google AdMob
- Apple Services (WKWebView / iOS SDK)

## 13. No sale of personal data
We do not sell users' personal data. Any data processed is used exclusively for the purposes described in this Privacy Policy.

## 14. Children
This application is **directed to children** and is distributed in the **Google Play Families** and **Apple Kids Category** sections.
In compliance with the **Children's Online Privacy Protection Act (COPPA)**, the **Google Families Policy** and the **Apple App Store Review Guidelines § 1.3 (Kids Category)**:
- we do not knowingly collect personal data of minors beyond what is strictly necessary for the app to function;
- we do not use personalized advertising identifiers or cross-app tracking;
- advertisements, if any, are served exclusively in **child-directed** mode (non-personalized, without tracking, filtered according to AdMob families policies);
- no social logins or behavioral analytics SDKs incompatible with the Families mode are used;
- we do not request sensitive data or contact information from minors;
- any features involving economic decisions or external communications are protected by a **parental gate**, as required by Apple and Google.
If a parent or guardian believes that data from a minor has been inadvertently collected, they can contact us at the address indicated in this policy for immediate deletion.

## 15. Legal basis and GDPR rights
Data processing takes place to provide the service, ensure the security of the application, comply with legal obligations and, where required, with the user's consent. In accordance with the **GDPR Regulation (EU 2016/679)**, the user has the right to access, rectify, erase, restrict, object to and port their personal data. You can exercise your rights by writing to: creo.app.app@gmail.com.

## 16. Data retention
Data collected by third-party providers (e.g., Google AdMob, Firebase, RevenueCat, payment stores) is retained according to their respective privacy policies and retention periods. Data managed directly by the app is retained only for as long as necessary for the purposes for which it was collected.

## 17. Security
We adopt appropriate technical and organizational measures to protect personal data against unauthorized access, loss or disclosure, including encrypted connections (HTTPS/TLS) and secure storage of any credentials used.

## 18. Changes to this Privacy Policy
We may update this Privacy Policy in case of changes to the app's features, applicable regulations or service providers used. The date shown at the top of the document represents the latest revision.

## 19. Contacts
For any privacy-related requests, please write to **creo.app.app@gmail.com**.