Privacy Policy

Last updated March 28, 2024

colorinq.com (“we,” “us,” or “our”) respects the privacy of our users. Please note that the practices of colorinq, concerning your access to and use of the https://colorinq.com/ website as well as any other media form, media channel, mobile website, or mobile application related, linked, or otherwise connected thereto (collectively, the “the Site”), with respect to personal information, are now governed by this Privacy Policy as same may be amended from time to time. Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SITE.

This privacy policy applies to the following websites (including any subdomain or section):

• colorinq.com

In this legal document, the legally obligatory information on the processing carried out on your personal data in the context of our Website is provided.

The present Privacy Policy regulates the processing of your personal data performed by the Site, collected through the use of the services offered on the Website (hereinafter, “Services”).

The latest update of this Privacy Policy is indicated at the top of this text and it will become effective as of the date indicated in each version. We, thus, recommends reviewing this Privacy Policy from time to time.

Some of the Services offered on the Website may be subject to specific privacy policies or information that will be displayed in the relevant moment. Additionally, the access and use of the Website and the accompanying Services are governed by the Terms of Use of the Website.

PERSONAL DATA PROCESSING

The following sections address the collection and processing of your personal information through any of the projects run the Site, including any of their subdomains and sections.

Data controller

colorinq as data controller, is responsible for the processing of Users’ personal information on the Website:

You can send an email to privacy@colorinq.com to raise any questions, request or exercise of right regarding personal data protection.

Website Use under Terms and Conditions

You can only contract our services and validly accept our Terms and Conditions if you are of legal age.

Our products are directed to people of legal age. In specific cases, we may explicitly allow them to be hired for use by minors. They must be examined and accepted, on the minor behalf, by the person of legal age who is the holder of the parental authority or in charge of their custody or education.

Notwithstanding the aforementioned, if you are a minor, in accordance with our terms and conditions, you cannot validly enter into any of the contracts we offer.

Our purposes and lawful basis of data we collect

Your personal data is processed with different purposes. Each processing must be based on a lawful basis, among those set forth by the regulation. We use the following basis:

1. Consent: you have given your informed, unequivocal and specific consent to the processing of your personal data aimed to a specific purpose.
2. Legal obligation: the law requires process and disclose certain data on occasions to certain institutions (for example, to the Tax Authority).
3. Execution of a contract: the data are strictly necessary to provide you with our services or to comply with what was agreed with you.
4. Our legitimate interests, provided that your interests and rights do not prevail over them.

The legal bases of our data processing carried out through our Website, in relation to the purposes for which we will use your data, are the following:

Browsing the Website

When you browse and use the Website, even if you do not register, data is automatically collected through technology or automated interactions, such as IP address, device id, certains metadata (HTTP header, your browser, etc.). In addition, information is collected on the number of downloads and searches you perform. These data are recorded in order to control the number of downloads made by each user, thus allowing us to detect a fraudulent or illegitimate use of the Website, and, therefore, guarantee compliance with the Terms and Conditions of Use of the Website, that is, the management of the contractual relationship between you and colorinq.

These technical data observed when the user browser the Website are processed for the purpose of detecting and mitigating risks of attacks (bots, code injections, DDOS attacks), and, generally, to guarantee and maintain the Website security. Our lawful basis is our legitimate interest in protecting the security of our systems and preventing the violation of our terms and conditions.

Personal data processed: IP address, device id and certain metadata such as the browser used or the HTTP/HTTPS header.

Contractual relationship with our registered users (free or plus)

When you register as a user (either free or “plus”), we request the personal data that we need for the management and fulfillment of our contractual relationship with you.

When you are requested to provide personal data that is deemed as necessary, due to legal obligation or in accordance with our contracting conditions, and you refuse to provide them, we may not be able to formalize said contract or provide the service, which will be communicated to you properly.

• Personal data processed (free users): username, email address and name. Only the email address and the first name are required.
• Personal data processed (plus users): the above, plus means of payment (all data are mandatory).

You can open your account as a registered user on colorinq with your own account on other platforms, such as Google, using the federated Login that you will find at the top of our websites, and access whenever you want through them, without having to create and remember a specific username and password to access colorinq.

This option is possible due to the collaboration between colorinq and Google as the joint controllers of the processing of your personal data, so that (i) you can identify yourself directly on these platform, (ii) they confirm that you are who you say you are, and (iii) we provide you with your login as a registered user on colorinq.

colorinq obtains from this platform, with your previous consent, your username, image and email address in order to register you as a colorinq user. On the other hand, this platform collects online identifiers (IP address), technical identifiers (from your device, as well as their advertising identifiers such as your “Google ID”) and record, each time you use their login, the date and time of your access to colorinq.

You can exercise your rights of access, rectification, erasure, limitation of processing, portability and revocation of consent in relation to the personal data obtained from these platforms (and other data that you may have provided to colorinq in your relationship with us) by contacting colorinq at the email address provided in this policy.

Please note that the rectification or deletion of your data in your colorinq account does not automatically imply the rectification or deletion of your data and accounts on the platforms that authenticate your identity: you must also contact them to exercise your rights.

To exercise your personal data protection rights in relation to any other data arising from your relationship with these platforms, you should contact the relevant platform.

Contractual relationship with our external creators

When we formalize a collaboration agreement with you if you are a creator of content to be distributed and licensed by colorinq, we request the personal data that we need for the management and fulfillment of our contractual relationship.

Personal data processed: email address, full name and way of payment.

Personalized advertising on colorinq and other websites

We promote our products:

– with social networks and other platforms users, between profiles of potential colorinq users, using audience segmented by interests, not created by colorinq but already offered by platforms such as Pinterest, Google and X (Twitter) and hired by colorinq for this purpose. Likewise, we can only identify you if you register as an user.

Our lawful base is our legitimate interests of getting new clients through personalized advertising of our products through profiling offered by social media and other platforms.

Personal data processed: We do not directly process personal data: we select the groups of users to whom advertising will be displayed based on the segments offered by the platforms, such as age ranges or country. These platforms provide us with aggregated information about the performance of each campaign, but we cannot identify the specific users who have become registered users as a result of it.

– through retargeting: impacting visitors who have visited and left our Website without registering, when they have accepted the use of our cookies, and these allow us to display advertising to them on third party websites.

In this case, our basis of legitimacy is your consent (given both on our Website as on third party websites where the advertising is displayed). You can find more information about this treatment in our Cookie Policy.

Sending of commercial communications by email

We will send you electronic commercial communications if (i) you have registered or contracted any of the Website Services, (ii) you request information about our products through any of the forms for this on the Website. In any case, we will do so as long as you have not expressed your objection to receiving such communications (you can do this conveniently via the specific slider in your user profile, as well as in each communication you receive, at the bottom, via the “Unsubscribe” button).

We will also send you content updates from coloring pages and coloring books, provided that you have specifically consented to this via the specific slider on your user profile. You can revoke your consent by unchecking it.

Our legal basis is our legitimate interest (to offer you commercial information about products or services similar to those that you have already contracted or about which you have requested information), by virtue of art. 21.2 of Law 34/2002 of July 11, of Information Society Services and Electronic Commerce (LSSI).

Advertisements on our Website

Unless you become a plus subscriber, we will display personalized advertisements on our Website, if you consent the installation of cookies (more information in our Cookies Policy).

When we use cookies, we do so based on your prior consent. You can accept or reject all our cookies or select them granularly, through our cookie setting panel.

Personalized advertising through preference forms

We offer voluntary surveys to learn about your basic user profile and preferences, in order to personalise your experience in our websites as well as the advertising we show you or the information of interest that we send you, based on the profile in which you place yourself.

The purpose of the processing is to personalize our advertising and information based on the information you decide to provide us, and our legitimate interest is the continuous improvement of our products and services and obtaining relevant information in a transparent, respectful, and close manner.

Personal data subject to processing: username, type of use of our products and personal preferences filled in the form.

You can object to this processing simply by omitting the response and closing the screens.

Surveys

Likewise, based on our legitimate interest to know your opinion in order to improve our products’ performance and usability, we may contact you to request your opinion and preferences through satisfaction surveys.

In addition, based on our legitimate interests (improving our products, increasing our sales) we offer you to participate in surveys in order to learn first-hand about your opinions and preferences about our products and, on that basis, to eliminate friction, facilitate their use and improve your interactions with them.) Therefore, we will contact you to ask for your opinion through satisfaction surveys.

Personal data processed: contact information.

Support requests

When you contact us requesting information, support or feedback, we process your data in order to assist you, based on your consent expressed in your own request.

Personal data processed: contact information that you provide us with in order to respond to your request and the content of your request.

Third-Party Integrations, APIs, plugins and extensions.

We may integrate or utilize various third-party extensions, add-ons, APIs, plugins, and other technologies (collectively, “Third-Party Integrations”) within our platform or services. These Third-Party Services are operated and provided by independent companies that are not under our direct control.

For example, making use of Google APIs, colorinq has developed and made available to you specific extensions that allow you to use certain functionalities connected with Google services. This involves connecting and accessing some of your data in Google, always under strict adherence to Google’s API Services User Data Policy, including its Limited Use requirements.

Regarding the processing of your personal data granted by Google, we inform you of the following:

The data obtained from Google -email, name, language preference and image- and the same information is collected in order to give you access to our products and to ensure compliance with our terms and conditions, i.e. with our agreement with you using our extension.

Also, such data is used for security purposes against any type of attack or fraudulent or illegitimate use of the same, based on our legitimate interest to maintain the security, integrity and resilience of our systems and ensure the regular provision of the service, and to comply with our agreements and protect the assets of the company.

You may deactivate or unsubscribe at any time and may exercise your privacy rights, in particular your right to object, by contacting us at the address given in the specific section of this policy.

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Legally binding processing

When in some cases we are legally bound by different regulations (regardless of whether or not you give your consent), to process and / or transfer certain personal data to different entities. For example, to the Tax Authority, or the law enforcement authorities, at their request.

Personal data processed: those set forth in the applicable regulations.

For how long do we keep your data

We process your personal data only for the necessary period of time, depending on each case. Once our processing has terminated, we keep your data blocked for different periods of time (in general, until the prescription of the responsibilities that may have arisen from our interactions). The relevant deadlines in each case are listed below:

1. In relation to processing carried out to guarantee and maintain the security of our Websites and anti-fraud measures, we will keep your data for one year.
2. In relation to the data necessary to provide the contracted service and the contractual relationship, your personal data will be stored while the contractual relationship is still active, and it will subsequently be kept blocked for five years (until the prescription of any contractual liability) and for a period of six years (regarding accounting information).
3. In relation to the sending of commercial communications by email, the data will be processed for 3 years from the last interaction with you or until you decide to object, whichever is the earliest.
4. Regarding the advertisements displayed on our Website by means of cookies, we refer to the descriptive tables available in our Cookies Policy, where you will find detailed information on the persistence or duration of our first-party cookies and links to extended information regarding third-party cookies.
5. We process your data to offer you surveys for the duration of our contractual relationship, unless you have objected to receiving them.
6. In relation to your non-commercial inquiries, the data will be deleted once they have been answered.
7. We will process the data provided for your application process for a period of one year from receipt.
8. Regarding the processing carried out in order to manage the Website through cookies, we refer to the  Cookies Policy in which you will find detailed information on the persistence or duration of our own cookies and links to detailed information on third-party cookies.
9. We will keep your data in relation to the fulfillment of any legal obligation, in general, during the limitation periods of the possible responsibilities derived from our data processing, and specifically during the periods imposed by the regulation in each case.

Data Update

We ask that you to immediately notify us of any changes to your data so that the information contained in our systems is up-to-date at all times and does not contain errors. In this sense, you represent and guarantee that the information and data that you have provided us is accurate, current and truthful.

Disclosure of data

colorinq does not transfer nor share collected personal data with third parties external to the company.

Access by third parties providing services to us

We may disclose personal information of our Users to third parties only in cases when it is strictly necessary for colorinq to perform their functions and to comply with the Terms of Use. We may also share personal information with other third parties to ensure compliance with applicable laws, including:

• Service providers, to manage systems and information technology such as hosting, broadband, IT security or web analytics providers.
• Payment platforms, banks and companies involved in the transaction process, to ensure the fulfilment of the necessary transactions.
• Advertising platforms, CRM and other marketing tools.
• Recruitment management platforms.
• User support management platforms.
• Lawyers, auditors, legal and accounting consultancy services and financial institutions.

These services provided by third parties are necessary for the development of colorinq’s business activity. The processing of personal data is at all times subject to a contract which establishes the duties of the data processor towards the data controller (us). Under no circumstances will personal information be used for other purposes and it will be managed in compliance with colorinq policy guidelines, their privacy policy and the applicable data protection regulation.

In accordance with our commitment to your privacy and your data protection right, we exclusively choose only top-tier service providers, leaders in their respective sectors. You can request the list of providers that have access to your personal data, as well as the services provided by each one, through the email address provided in the exercise of rights section.

We commercially exploit the advertising that is shown to you on our Website by third parties, and we do so through “cookies” and other similar technologies, always with your prior consent, collected through the configuration panel of cookies that informs you of the different purposes of data processing developed by the advertising companies, among others.

You can find the complete information in our Cookies Policy.

Our Website also includes plugins which allow the User to carry out actions on social networks of third parties such as Twitter or Pinterest, like, for instance, sending a publication or showing support to the website. These plugins are indicated with the corresponding social network logotype, and require the access data to the correspondent platform, and your consent.

If you accept these plugins, the content will be transferred to the corresponding social network. You can find in our Cookies Policy links to the privacy statements of these social networks.

Rights of the user

We guarantee the exercise of rights established in the General Data Protection.

You can exercise the rights described below in the following ways: logging in the User account through the support form available on the Website or by emailing us at privacy@colorinq.com.

Please note that colorinq may require you to verify your identity before taking action on the request for the exercise of rights.

You have the following rights:

1. Transparency and information on how we process your personal data (right to be informed). Right that we satisfy, for example, through this legal text.
2. Right to request a copy of the information we hold, which will be provided to you within a month (right of access).
3. Right to update or modify the information we have if it is incorrect or inaccurate (right of rectification).
4. Right to request us to stop processing your information while a complaint is being resolved, among other cases (right to limit processing).
5. Right not to be subject to a fully automated decision based solely on the processing of your data, which produces legal effects concerning you or significantly affects you (right not to be subject to automated individual decisions).

Additionally, when we process your personal data based on your consent or on our contractual relationship with you:

1. Right to request that we delete personal data from our records (right to erasure or “to be forgotten”). You can carry out this request at any time by closing your account, through your profile section.
2. Right to obtain and reuse personal data for your own purposes (right to data portability).
3. Right to revoke at any time the consent previously given to any of our processing of your personal data.

Or, when we process your personal data based on our legitimate corporate interests:

1. Right to object to the processing of personal data based on our legitimate interests claiming circumstances based on your personal situation (right to object). You can oppose these treatments related to the sending of advertising both in the registration form, as well as through your own profile, by unchecking the box enabled in the “Notifications” section and through any of the commercial communication we send to you.

Data security

We have implemented strong security controls to safeguard User’s personal information against loss, misuse, unauthorized access, disclosure or alteration.

For example, to protect your personal data, Secure Socket Layer (SSL) technology is used during the transmission of data. This means that an approved encryption procedure is used for communication between your computer or device and colorinqs’s servers, as long as your browser supports SSL.

International data transfers

We carry out international data transfers in relationship with some of the processing described in the previous clause with certain data processors: subcontractors and content delivery networks to help us to deliver our Services.

A data processor, as already said, is an external subcontractor that we hire, and that may have access to personal data about users or collaborators, or that stores them in the context of the service provided to us.

Some of these external service providers are located outside of the European Economic Area (EEA), so the processing of your personal data involves an international data transfer.

Our international data transfers can occur to countries with a level of protection of personal data potentially lower than that imposed by the RGPD. Said international data transfers are covered by standard contractual clauses (art 46.2.c) GDPR).

Complaint submission

If you, the User, do not agree with the way colorinq processes your personal data, you can contact us by sending an email to privacy@colorinq.com.