Privacy Policy
Colored Caramel (a subcompany of Manfred Limited) Privacy Policy
This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from https://www.coloredcaramel.com/ (the “Site”).
PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number. We refer to this information as “Order Information.”
When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
Communicate with you;
Screen our orders for potential risk or fraud; and
When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
We share your Personal Information with third parties to help us use your Personal Information, as described above. We use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
GOOGLE – https://www.google.com/settings/ads/anonymous
BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
YOUR RIGHTS
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
DATA RETENTION
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.
CHANGES
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at support@coloredcaramel.com or by mail using the details provided below:
Room 1405, 14/F.,
135 Bonham Strand Trade Centre,
135 Bonham Strand,
Sheung Wan,
Hong Kong
Privacy Policy
Colored Caramel Mobile App · Last updated 10 August 2026
This policy applies to the Colored Caramel colouring app for iOS and Android (“the App”). It is a separate document from the privacy policy covering our website at coloredcaramel.com.
1. Who we are
The App is provided by Colored Caramel, a subcompany of Manfred Limited.
Room 1405, 14/F., 135 Bonham Strand Trade Centre,
135 Bonham Strand, Sheung Wan, Hong Kong
Business registration number: 67340930-000
Certificate of incorporation number: 2494263
Email: support@coloredcaramel.com
We are responsible for the personal data described below. In this policy “we” and “our” mean Colored Caramel, and “you” means the person using the App.
2. What we collect
Your account. Your name, your email address, and a securely hashed password.
Your colouring work. Which illustrations you have opened, your in-progress and finished colourings, and the palettes you save, so your work is there when you come back or sign in on another device.
Your subscription. We use RevenueCat to manage subscriptions. When you subscribe, RevenueCat processes a pseudonymous user identifier, the receipt or transaction identifier issued by Apple or Google, and your subscription status, product, purchase and renewal dates, and country of purchase. We never receive or store your payment card details — payment is taken by Apple or Google under their own terms.
Technical and crash information. Your device model, operating system and version, language and region, App version, IP address, a Firebase installation ID, and crash diagnostics including stack traces and the state of the App when a crash occurred.
Push notifications. If you allow them, a Firebase Cloud Messaging token for your device and your notification permission status. You can turn notifications off at any time in your device settings or in the App under Settings → Notifications.
Analytics, only if you agree. Where you consent, we use Google Analytics for Firebase to understand how the App is used: a pseudonymous Firebase installation ID, the screens you view, the actions you take, your approximate location at country or city level derived from your IP address, and session metadata such as timestamps and App version. No analytics data is collected unless and until you agree, and you can change your answer at any time under Settings → Privacy. Declining does not limit any feature.
What we do not do. We do not collect the advertising identifier on your device (Apple’s IDFA or Android’s Advertising ID). We do not show advertising, we do not track you across other companies’ apps or websites, we do not build profiles of you, and we do not sell or share your personal data. The App contains no advertising SDKs.
Permissions. The App asks only for permission to send you notifications. It does not request access to your location, contacts, camera, photo library, microphone or health data.
Printed books. Some illustrations in the App are also available as printed colouring books, and the App links to our website where you can buy them. The subscription is the only thing you can buy inside the App. If you follow a link and buy a book on the website, that is covered by the website privacy policy, and we receive no order, payment or delivery details through the App.
3. Why we use your data, and our legal basis
| Providing the App, your account, and saving your colouring work | Performance of a contract — Article 6(1)(b) |
| Managing your subscription and unlocking paid content | Performance of a contract — Article 6(1)(b) |
| Answering your support requests | Performance of a contract, and our legitimate interest in helping customers — Article 6(1)(b) and (f) |
| Sending push notifications | Your consent — Article 6(1)(a) |
| Analytics | Your consent — Article 6(1)(a) |
| Crash reporting, diagnostics, security and fraud prevention | Our legitimate interest in a working, secure App — Article 6(1)(f) |
| Accounting and tax records | Compliance with a legal obligation — Article 6(1)(c) |
We do not make decisions about you by automated means that have legal or similarly significant effects, and we do not profile you.
4. Who we share it with
- Apple and Google — distribution of the App and processing of subscription payments. For the payment itself they act as independent controllers under their own privacy policies.
- RevenueCat, Inc. (United States) — subscription management, as our processor under a data processing agreement.
- Google Ireland Limited / Google LLC — Firebase Cloud Messaging, Firebase Crashlytics, and, where you have consented, Google Analytics for Firebase, as our processor under Google’s data processing terms.
- Our hosting provider — infrastructure for our self-hosted backend, as our processor under a data processing agreement.
- Professional advisers and public authorities — where we are legally required to disclose, or where disclosure is necessary to establish, exercise or defend legal claims.
5. Sending data outside Europe
Our backend is hosted in the European Union, so your account and colouring data stays in the EEA for its primary storage. Some recipients are established elsewhere:
- RevenueCat processes data in the United States, under the European Commission’s Standard Contractual Clauses with supplementary technical and organisational measures.
- Google may process data in the United States and other countries, relying on the Standard Contractual Clauses and, where applicable, its certification under the EU–US Data Privacy Framework.
- Because our company is established in Hong Kong, some administrative access takes place from there. Hong Kong is not covered by an EU adequacy decision, so these transfers are made under the Standard Contractual Clauses.
You can request a copy of the relevant safeguards by writing to support@coloredcaramel.com.
6. How long we keep it
| Account data | While your account is open, then deleted within 30 days of closure |
| Your saved colourings and palettes | While your account is open |
| Subscription payment records | 7 years from the transaction, for tax and accounting |
| Subscription records in RevenueCat | While the subscription is active, then 24 months |
| Crash diagnostics | 90 days, which is Google’s retention period for this data |
| Firebase installation IDs | Until deleted; Google removes them within 180 days of a deletion request |
| Analytics data | User-level data 2 months; aggregated reporting 14 months |
| Push notification tokens | Until you disable notifications, delete the App, or the token expires |
| Support correspondence | 24 months from the closure of your enquiry |
7. Your rights
Wherever you live, you can ask us for a copy of the personal data we hold about you, ask us to correct it, ask us to delete it, or ask us to stop using it. Email support@coloredcaramel.com from the address on your account, or use Settings → Privacy in the App. We reply within 30 days and we never charge, and we will not treat you differently for asking.
If you are in the European Economic Area, the United Kingdom or Switzerland, you have the right to access your data, to have it corrected or erased, to restrict processing, to object to processing based on our legitimate interests, to data portability, and to withdraw your consent at any time without affecting processing that has already taken place. You also have the right to lodge a complaint with a data protection supervisory authority — in your country of residence, your place of work, or where you consider the infringement occurred. The European Data Protection Board publishes a directory of national authorities at edpb.europa.eu. In the UK it is the Information Commissioner’s Office at ico.org.uk. In Switzerland it is the Federal Data Protection and Information Commissioner at edoeb.admin.ch.
If you are in the United States, depending on your state you have the right to know what personal data we process, to access it, to correct it, to obtain a copy, to have it deleted, and not to be discriminated against for exercising those rights. You also have the right to opt out of sale, targeted advertising and profiling — as set out above, we do none of these, so there is nothing to opt out of. We have not sold or shared personal data in the preceding twelve months. If we decline a request you may appeal by emailing us with “Appeal” in the subject line.
Everywhere else, your local law may give you rights this policy does not list. We honour valid requests wherever they come from, and we will apply whichever standard is more favourable to you: your local law or the standard set out here.
8. Children
The App is intended for adults. We do not knowingly collect personal data from children under 18, and we do not market to them. If you are a parent or guardian and believe your child has provided us with personal data, email support@coloredcaramel.com and we will delete it and confirm once it is done.
9. Deleting your account
You can delete your account and the personal data attached to it in the App under Settings → Account → Delete account, or by emailing support@coloredcaramel.com from the address on your account. Deleting your account removes your profile, your preferences and your saved colourings, except for records we must keep for the accounting periods in section 6.
Deleting your account does not cancel your subscription. Cancel that in your Apple or Google account settings.
10. How we protect your data
We use TLS encryption for data in transit, encryption at rest for our databases and backups, role-based access controls so staff only reach the data they need, and multi-factor authentication on administrative accounts. No system is completely secure, but we work to protect your data and we will notify you and the competent authority of a personal data breach where the law requires it.
11. Changes to this policy
We may update this policy as the App develops or as the law changes. We will change the “Last updated” date above, and where a change materially affects you we will tell you in the App or by email before it takes effect. The current version is always at coloredcaramel.com/privacy-policy/#app and in the App under Settings → Privacy Policy.
12. Contact us
Colored Caramel, a subcompany of Manfred Limited
Room 1405, 14/F., 135 Bonham Strand Trade Centre,
135 Bonham Strand, Sheung Wan, Hong Kong
Business registration number: 67340930-000
Certificate of incorporation number: 2494263
support@coloredcaramel.com
