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Privacy Policy

INFINITY COLORING BOOK
PRIVACY POLICY

Last Updated: September 2025

IMPORTANT NOTICE FOR PARENTS: This app is designed for children under 13 and may collect limited personal information with your consent. Please read this policy carefully before allowing your child to use certain features.

Scope of This Privacy Policy: This Privacy Policy applies only to the Infinity Coloring Book mobile application downloaded from official app stores (Apple App Store or Google Play Store). It does not apply to this website, which is for informational purposes only and does not collect personal information. By downloading and using the app from authorized sources, you agree to the data practices described in this policy.


1. OVERVIEW & COMMITMENT TO PRIVACY

Privacy-First Design for Families

Infinity Coloring Book is designed with children's privacy as our highest priority. We are committed to protecting the privacy of all users, especially children under 13, and we comply with the Children's Online Privacy Protection Act (COPPA) and its 2025 amendments.

Our Core Privacy Principles:

  • Minimal data collection - we collect only what is necessary for app functionality
  • Parental control - parents have full control over their child's information
  • Transparency - clear information about what we collect and why
  • Security - industry-standard protection for any information we handle
  • Choice - separate consent options for different types of data use

2. INFORMATION WE COLLECT

Information Collected from Children Under 13

With Parental Consent, we may collect:

  • User-submitted prompts for custom feature functionality
  • Parent's email address (for consent verification and communication only)
  • Device identifiers and cryptographic keys (ECDSA) for app functionality and security
  • IP addresses for security, fraud prevention, and abuse detection

We Do NOT Collect from Children:

  • Names, addresses, or other personal contact information
  • Photos, videos, or audio recordings
  • Precise geolocation data
  • Browsing history or usage patterns across other apps or websites
  • Any information through cookies or similar tracking technologies for advertising purposes

How We Use Technical Identifiers:

  • Device identifiers and ECDSA keys are used solely to maintain user sessions and ensure app security
  • IP addresses are stored for security logging, fraud detection, and preventing abuse
  • These identifiers are NEVER used for advertising, marketing, or cross-app tracking
  • We do NOT build behavioral profiles or share these identifiers with third parties for commercial purposes

Information Collected from Users 13 and Older

After age verification, we may collect:

  • User-submitted prompts for app functionality
  • Basic verification completion records (for compliance purposes only)

We may also collect:

  • Device identifiers and cryptographic keys (ECDSA) for app functionality and security
  • IP addresses for security, fraud prevention, and abuse detection

We still do NOT collect:

  • Personal contact information beyond what's necessary for app functionality
  • Browsing history or cross-app tracking data
  • Information for advertising or marketing purposes

Automatically Collected Information

For All Users (including children with parental consent), we may collect:

  • Basic app usage statistics (anonymized and aggregated only)
  • Error reports and crash data (may include device identifiers for debugging)
  • App performance metrics (to improve functionality)
  • IP addresses for security logging and fraud prevention
  • Device identifiers and cryptographic keys for session management and security

We do NOT use this data to:

  • Identify individual users
  • Track users across other apps or websites
  • Build user profiles for advertising
  • Share with third parties for their commercial purposes

3. COPPA COMPLIANCE & PARENTAL RIGHTS

Age Verification & Parental Consent

Our COPPA-Compliant Process:

For Users Under 13:
We provide age-appropriate verification that directs children to obtain parental consent before accessing features that collect personal information.

For Users 13 and Older:
We provide a simple age verification process that allows direct access to app features.

Parental Consent Methods

"Email Plus" Verification (Primary Method):

  1. Parent provides email address for consent communication
  2. We send a direct notice explaining our information practices
  3. Parent provides consent through a verification link
  4. We send a confirmation email documenting the consent granted
  5. Features requiring consent become available to the child

Separate Consent Choices (2025 COPPA Requirement):
Parents can choose to consent to:

  • Collection and Use: Allowing collection of information for app functionality
  • Third-Party Processing: Allowing disclosure to service providers for content generation (separate, optional consent)

Your Parental Rights

Parents have the right to:

  • Review: Request to see any personal information we have collected from your child
  • Delete: Request deletion of your child's personal information at any time
  • Refuse: Decline to allow further collection or use of your child's information
  • Revoke: Withdraw consent at any time, which will disable applicable features
  • Contact: Ask questions about our children's privacy practices

To Exercise These Rights:
Email privacy@infinitycoloringbook.com with:

  • Your request (review, delete, refuse, or revoke)
  • Verification of your identity as the child's parent or guardian
  • Any specific information about your child's app usage

Response Time: We will respond to parental requests within 48 hours for urgent matters and within 10 business days for standard requests.


4. HOW WE USE INFORMATION

Permitted Uses Under COPPA

We use collected information only for:

  • App Functionality: Providing the specific features the user requested
  • Service Improvement: Improving app performance and user experience (anonymized data only)
  • Safety: Ensuring content is appropriate and safe for children
  • Legal Compliance: Meeting our legal obligations under COPPA and other applicable laws
  • Parental Communication: Communicating with parents about consent and their rights

We do NOT use information for:

  • Behavioral advertising or targeted marketing to children
  • Building detailed user profiles
  • Sharing with third parties for their commercial purposes
  • Cross-app or cross-website tracking
  • Any purpose not disclosed to and consented to by parents

Data Retention Practices

User-Submitted Prompts:

  • Retained only as long as reasonably necessary for the purposes for which it was collected
  • Users and parents can request deletion at any time
  • Will not be retained indefinitely without ongoing justification
  • Automatic review and deletion procedures are in place

Parent Contact Information:

  • Used solely for consent verification and ongoing parental communication
  • Deleted when consent is revoked or no longer needed
  • Not shared with any third parties

Compliance Records:

  • Basic consent and verification records maintained for legal compliance
  • No personal information of children included
  • Retained only for periods required by applicable law

5. INFORMATION SHARING & DISCLOSURE

Third-Party Service Providers

AI Content Generation Services:
When users with appropriate consent/verification request custom content generation:

  • User text input may be processed by third-party AI services
  • This processing is necessary to provide the requested functionality
  • Service providers are contractually bound to use data only for providing services
  • Service providers may not use data for their own commercial purposes
  • This disclosure requires separate parental consent for children under 13

Other Service Providers:
We may share information with service providers who assist with:

  • App hosting and technical infrastructure
  • Data security and backup services
  • Legal compliance and safety monitoring

All service providers must:

  • Maintain appropriate security and privacy protections
  • Use information only for providing services to us
  • Delete information when no longer needed for service provision
  • Comply with applicable children's privacy laws

Required Legal Disclosures

We may disclose information when required by law:

  • To comply with legal process (subpoenas, court orders)
  • To protect the safety of children or others
  • To investigate suspected illegal activities
  • To protect our legal rights and property

Parental Notification: We will notify parents of legal disclosure requests when legally permitted and practically feasible.

No Advertising or Marketing Use

Important Commitment:

  • We do NOT sell, rent, or share children's personal information for advertising purposes
  • We do NOT engage in behavioral advertising to children
  • We do NOT allow third-party advertising networks to collect information from our app
  • We do NOT build marketing profiles of children

6. DATA SECURITY & PROTECTION

Security Measures

Technical Safeguards:

  • Industry-standard encryption for data transmission and storage
  • Secure servers with appropriate access controls
  • Regular security assessments and updates
  • Limited access to personal information on a need-to-know basis

Administrative Safeguards:

  • Employee training on children's privacy requirements
  • Formal information security policies and procedures
  • Regular review of data handling practices
  • Incident response procedures for security breaches

Physical Safeguards:

  • Secure facilities for any servers or equipment
  • Appropriate disposal of devices containing personal information
  • Restricted access to areas where personal information is processed

Data Breach Notification

In the unlikely event of a security breach involving children's personal information:

  • We will notify affected parents as soon as reasonably possible
  • We will provide information about what happened and what we are doing about it
  • We will notify appropriate regulatory authorities as required by law
  • We will take steps to prevent similar incidents in the future

7. YOUR CHOICES & CONTROLS

For Parents of Children Under 13

Consent Choices:

  • Choose which types of information collection to allow
  • Provide separate consent for third-party processing
  • Revoke consent at any time (which will disable applicable features)

Access and Control:

  • Request to see any information we have about your child
  • Request deletion of your child's information
  • Update your contact information for consent communications
  • Contact us with questions or concerns about privacy practices

For Users 13 and Older

Your Rights:

  • Request to see any information we have collected about you
  • Request deletion of your information
  • Choose not to use features that collect personal information
  • Contact us with privacy questions or concerns

App Store Controls

Additional Controls Available:

  • App store parental controls and restrictions
  • Device-level privacy settings and restrictions
  • Family sharing controls (where applicable)
  • Screen time and content restrictions

8. CALIFORNIA PRIVACY RIGHTS

CCPA Rights for California Residents

California residents (including parents of child users) have additional rights under the California Consumer Privacy Act:

  • Right to Know: Request information about what personal information we collect, use, and share
  • Right to Delete: Request deletion of personal information we have collected
  • Right to Opt-Out: Opt out of the sale of personal information (note: we do not sell personal information)
  • Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

To Exercise CCPA Rights: Email privacy@infinitycoloringbook.com with your request and verification of your identity.


9. INTERNATIONAL USERS

Users Outside the United States

Our Commitment:
While our app is based in the United States and governed by U.S. privacy laws, we are committed to protecting the privacy of all users regardless of location.

Data Transfers:

  • Any personal information collected may be transferred to and stored in the United States
  • We provide appropriate safeguards for international data transfers
  • We comply with applicable international privacy laws where feasible

Local Privacy Rights:
Users in other countries may have additional privacy rights under local laws. Please contact us at privacy@infinitycoloringbook.com to discuss your specific rights and how we can assist you.


10. CHANGES TO THIS PRIVACY POLICY

How We Handle Updates

Notice of Changes:

  • We will post updates to this Privacy Policy on our website and in the app
  • Material changes will be highlighted and explained clearly
  • For children's information, we will provide notice to parents before implementing changes
  • Changes affecting COPPA compliance may require new parental consent

Your Choices After Changes:

  • Continued use of the app after changes constitutes acceptance
  • Parents can withdraw consent if they disagree with changes
  • Users can stop using the app if they disagree with changes
  • We will honor withdrawal of consent and deletion requests

Effective Date: Changes take effect on the date posted, except for material changes affecting children's privacy, which take effect only after appropriate parental notice.


11. CONTACT INFORMATION

Privacy Questions and Requests

Privacy Officer: privacy@infinitycoloringbook.com

For Specific Privacy Requests:

  • Parental Rights Requests: Include child's information and verification of parental identity
  • Data Deletion Requests: Specify what information you want deleted
  • Access Requests: Specify what information you want to review
  • General Privacy Questions: We're happy to explain our practices

Other Contact Information:

  • General Support: support@infinitycoloringbook.com
  • Legal Questions: legal@infinitycoloringbook.com
  • Company: Gizmotron LLC

Response Times:

  • Urgent privacy matters: Within 24 hours
  • Standard requests: Within 10 business days
  • Complex requests: We will acknowledge receipt and provide timeline

12. LEGAL BASIS & COMPLIANCE

COPPA Compliance Statement

This app complies with the Children's Online Privacy Protection Act (COPPA) and its 2025 amendments. We:

  • Obtain verifiable parental consent before collecting personal information from children under 13
  • Provide clear notice of our information practices to parents
  • Allow parents to review and delete their children's information
  • Limit collection to what is reasonably necessary for the activity
  • Implement appropriate data security measures
  • Provide separate consent choices for different types of data use

Other Applicable Laws

We also comply with other applicable privacy laws, including:

  • California Consumer Privacy Act (CCPA)
  • Texas privacy laws
  • Federal Trade Commission Act
  • Other applicable state and federal privacy regulations

Legal Basis for Processing: Our legal basis for processing personal information includes consent, legitimate interests in providing app functionality, and legal compliance requirements.


Questions about this Privacy Policy? Contact us at privacy@infinitycoloringbook.com

This Privacy Policy was last updated on September 2025 and is effective immediately.

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