1.1 Evitara ("we", "us", "our") operates ColorCraft AI at colorcraft-ai.com. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our service.
1.2 We are committed to complying with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), the EU General Data Protection Regulation (GDPR), the UK GDPR, and the California Consumer Privacy Act (CCPA) as applicable to our users.
1.3 By using ColorCraft AI, you acknowledge that you have read and understood this Privacy Policy.
2.1 Data controller / responsible entity: Evitara (private member's association), Australia.
2.2 Privacy contact: jacques@colorcraft-ai.com
3.1 Information you provide directly:
3.2 Information collected automatically:
3.3 Information from third parties:
This section applies to users in the European Economic Area and the United Kingdom.
| Data category | Purpose | Legal basis |
|---|---|---|
| Account data | Create and manage your account | Article 6(1)(b) — performance of a contract |
| Uploaded photos | Generate coloring pages at your request | Article 6(1)(b) — performance of a contract |
| Payment data | Process credit purchases | Article 6(1)(b) — performance of a contract |
| Usage and analytics | Improve and secure the service | Article 6(1)(f) — legitimate interests |
| Marketing emails | Promotional communications | Article 6(1)(a) — consent |
| Children's data (ages 13–15 in EU) | Parental consent verification | Article 8 GDPR |
| Compliance records | Meet legal obligations | Article 6(1)(c) — legal obligation |
5.1 When you upload a photo, that image is transmitted to Base44 (an AI processing service, United States) solely for the purpose of generating your coloring page.
5.2 Your uploaded photos are NOT used to train, fine-tune, or improve any AI model.
5.3 We have a Data Processing Agreement (DPA) in place with Base44 that restricts their use of your photos to generation only.
5.4 Uploaded photos are automatically deleted from Base44's systems within 30 days of generation. Copies held on our infrastructure (Supabase) are deleted within 30 days of generation, or immediately upon your written request.
5.5 Generated coloring page files are retained in your account until you delete them or close your account.
5.6 If your photo contains images of other people, you are responsible for ensuring you have their consent. See Section 11 for rules about photos of minors.
We use your personal information to:
We do not use automated decision-making or profiling that produces legal or similarly significant effects on you.
7.1 We do not sell, rent, or trade your personal information to third parties.
7.2 We share your information only with:
8.1 Australia. Under APP 8, we disclose to overseas recipients: Stripe (US), Supabase (US), Base44 (US), and Lulu (US). We take reasonable steps to ensure these recipients handle personal information consistently with the APPs through contractual data processing agreements.
8.2 EU/UK users. Transfers to the United States are made on the basis of Standard Contractual Clauses (SCCs) approved by the European Commission (EU transfers) and the UK International Data Transfer Agreement or addendum (UK transfers). You may request a copy of the relevant transfer mechanism by contacting us.
| Data type | Retention period |
|---|---|
| Account data | Duration of account plus 2 years after closure |
| Uploaded photos (original) | 30 days after generation, or immediately on request |
| Generated coloring page files | Duration of account or until you delete them |
| Payment and transaction records | 7 years (Australian tax obligations) |
| Support communications | 2 years from last contact |
| Server and access logs | 90 days |
10.1 Australian Privacy Act 1988. You have the right to access and request correction of the personal information we hold about you. If you are not satisfied with how we handle your personal information, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or 1300 363 992.
10.2 GDPR (EU users). You have the right to: access (Article 15), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20), object to processing (Article 21), withdraw consent at any time, and lodge a complaint with your national supervisory authority (see edpb.europa.eu).
10.3 UK GDPR (UK users). The same rights as in 10.2 apply. You may lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or 0303 123 1113.
10.4 CCPA (California users). You have the right to know what personal information we have collected, request deletion, and opt out of sale. We do not sell your personal information. We will not discriminate against you for exercising these rights. Contact jacques@colorcraft-ai.com to submit a CCPA request.
10.5 How to exercise your rights. Contact jacques@colorcraft-ai.com. We will respond within 30 days and may need to verify your identity first.
11.1 ColorCraft AI is not directed to children under 13 years of age.
11.2 Users aged 13 to 17 may use the service only with the consent and ongoing supervision of a parent or legal guardian.
11.3 For EU users, where applicable law sets a higher age of digital consent (up to 16), we require verifiable parental consent for users below that age.
11.4 We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child under 13 has created an account or uploaded photos, contact us immediately at jacques@colorcraft-ai.com and we will delete that information promptly.
11.5 If your coloring page project includes photos of a child, you confirm that you are that child's parent or legal guardian, or that you have obtained the parent or guardian's explicit consent.
We implement TLS/HTTPS encryption for all data in transit, encryption of data at rest within Supabase, and access controls for staff and system access. No method of transmission or storage is 100% secure. Contact us immediately if you suspect unauthorised access to your account.
13.1 We use session cookies (essential for login), preference cookies (to remember your settings), and analytics identifiers (to understand how the service is used).
13.2 You can control cookies through your browser settings. Disabling essential cookies may prevent you from using certain features.
We may update this Privacy Policy from time to time. For material changes, we will notify you by email or within the service. The effective date at the top of this page will reflect the latest revision.
For any privacy-related queries or to exercise your rights, contact: jacques@colorcraft-ai.com