This policy explains how MimiColor processes your personal data when you use the mobile application (the "Application").
1. Data controller
The data controller is Jonathan Darmouni, whose address is 49 rue Saint-Louis, 93250 Villemomble, France.
Privacy contact: jonathan.darmouni@gmail.com.
No data protection officer has been appointed.
2. Data processed
Depending on how you use the Application, the following categories may be processed:
| Category | Examples | Source |
|---|---|---|
| Photographs and images | photo chosen or taken, resized version sent for generation, generated colouring page | you |
| Local usage data | colouring pages, recent photos, albums, titles, preferred style, free credits | your use of the Application |
| Purchase data | product purchased, subscription status, pseudonymous transaction or user identifiers | Apple and RevenueCat where configured |
| Technical data | IP address, device type, operating system or Application version, logs required for security and diagnostics | device and technical providers |
| Contact data | email address and message content if you contact support | you |
MimiColor does not require the creation of a user account. The Application only accesses a photograph when you select it or use the camera. It does not use targeted advertising and does not sell your personal data.
3. Purposes and legal bases
| Purpose | Main legal basis |
|---|---|
| Turn the chosen photograph into a colouring page and deliver the requested features | performance of the contract |
| Store your creations, preferences and recent photos locally | performance of the contract |
| Manage, verify and restore subscriptions | performance of the contract and legal obligations |
| Secure the service, prevent abuse and diagnose errors | legitimate interest in ensuring the security and reliability of the service |
| Respond to a support request | performance of the contract or legitimate interest in responding to users |
| Comply with accounting, tax or judicial obligations | legal obligation |
Where consent is the required legal basis, you may withdraw it at any time, without affecting the lawfulness of processing carried out beforehand.
4. How photographs are handled
When you start a generation:
- the selected photograph is prepared and resized on your device;
- it is transmitted over the internet to the fal.ai image generation service in order to produce the colouring page;
- the generated result is downloaded into the Application;
- if you save it, the colouring page and a compressed copy of the source photo are kept locally on your device for the history and the before/after preview;
- the Application also keeps up to six recent photos locally, the oldest being deleted automatically.
Reprinting or re-exporting a colouring page that has already been saved does not trigger a new remote generation.
Only send a photograph depicting a third party, in particular a child, if you have the necessary authority or consent. Avoid images containing sensitive information or official documents.
5. Recipients and processors
Data is accessible only to the extent necessary:
- to the Publisher and to authorised persons acting for support or security purposes;
- to fal.ai, in order to process the photograph and generate the requested image;
- to Apple, for the distribution of the Application, payment and subscription management;
- to RevenueCat, where that service is configured, to monitor and manage the status of purchases and subscriptions;
- to authorities or professional advisers where required by law or in order to defend rights in legal proceedings.
These providers process certain data under their own terms and policies. Before publication, the Publisher must verify their exact role, their retention periods and the applicable contractual safeguards.
6. Transfers outside the European Economic Area
Some providers may process data outside the European Economic Area, in particular in the United States. Where the GDPR so requires, these transfers rely on an adequacy decision, the European Commission's standard contractual clauses, or any other recognised mechanism, accompanied where necessary by supplementary measures.
You may request information about the applicable safeguards at jonathan.darmouni@gmail.com.
7. Retention periods
| Data | Period or criterion |
|---|---|
| Colouring pages, source photos, albums and preferences stored in the Application | until you delete them or uninstall the Application, subject to your device backups |
| Local recent photos | up to six images; deleted when replaced by more recent images or through the available deletion features |
| Files transmitted for generation and results hosted temporarily | the period strictly necessary for generation, then according to the period documented and contractually agreed with fal.ai [TO BE VERIFIED BEFORE PUBLICATION] |
| Subscription data held by Apple and RevenueCat | for the duration of the contractual relationship, then according to their legal obligations and documented periods [TO BE VERIFIED BEFORE PUBLICATION] |
| Support requests | for the time needed to process the request and retain evidence of the response |
| Accounting records and transaction evidence | the period imposed by applicable law |
8. Security
The Publisher implements technical and organisational measures appropriate to the risk, in particular reducing image size before transmission, encrypted communications in transit and access restrictions. As no system is entirely secure, absolute security cannot be guaranteed.
Creations stored locally benefit from your device's protection mechanisms. Whether they appear in an iCloud or computer backup depends on your own Apple settings.
9. Your rights
Subject to the conditions laid down by the regulations, you may request:
- access to your personal data;
- its rectification;
- its erasure;
- the restriction of its processing;
- its portability where that right applies;
- to object to processing based on legitimate interest;
- to withdraw your consent at any time where it is the basis of the processing;
- to give directions concerning what happens to your data after your death, where French law applies.
To exercise your rights, write to jonathan.darmouni@gmail.com. Proof of identity will only be requested in the event of reasonable doubt and in a proportionate manner. You will receive a reply within the legal time limit, in principle one month under the GDPR.
You may also lodge a complaint with the French data protection authority (CNIL) or with the competent supervisory authority in your country of residence.
Files present only on your device can be deleted directly from the Application or by uninstalling it. A request addressed to the Publisher does not necessarily make it possible to identify or erase local data to which it has no access.
10. Children
MimiColor creates content intended in particular for children, but the service, the selection of photographs and purchases are intended for adults. The Publisher does not seek to knowingly collect contact details directly from children.
The parent or legal guardian must supervise the use of the Application and make sure that they hold the necessary rights before sending the photograph of a minor. If you believe that data concerning a child has been processed without appropriate authorisation, contact jonathan.darmouni@gmail.com.
11. Device permissions
The Application may request:
- access to the camera, solely to take a photograph to be transformed;
- the access needed to the photo library through the system picker, to choose an image;
- permission to add a colouring page to the photo library when you ask for it to be saved.
You can manage these permissions in the iOS settings. A refusal may prevent the corresponding feature from working without blocking the other available features.
12. Changes to this policy
This policy may be updated to reflect changes to the Application, to its providers or to applicable law. The version date will be amended and, in the event of a substantial change, appropriate information will be provided.
13. Contact
For any question relating to this policy:
Jonathan Darmouni
49 rue Saint-Louis, 93250 Villemomble, France
jonathan.darmouni@gmail.com
The retention periods and contractual commitments of fal.ai and RevenueCat remain to be verified with those providers before publication.