Privacy Policy
COLPICK is a RAL colour fan deck. The catalogue and your favourites work offline without an account. PREMIUM uses Sign in with Apple and online purchase verification. Painting one object in a photo uses credits and sends that photo to xAI. Last updated 1 November 2026.
Who is responsible
The controller is GRETIFY s. r. o., Na letisko 2088/15, 058 01 Poprad, Slovensko. Write to info@colpick.app about anything on this page.
What we collect, why, and on what legal basis
| Data | Why | Legal basis (GDPR) | Kept for |
|---|---|---|---|
| Usage counts — which screen was opened, which paid feature was reached, app version, language. No device identifier, no advertising id, no profile. | To see which step of the app people get stuck on and fix it. | Legitimate interest, Art. 6(1)(f) — aggregate counts that cannot be traced to a person. | 24 months, then deleted |
| Crash and error reports — our own error code, app version, OS version. No message contents, no personal data, no file contents. | To find and fix faults without asking you for logs. | Legitimate interest, Art. 6(1)(f). | 90 days, then deleted |
| Your e-mail address and message — only if you write to us through the in-app feedback form. A short technical snapshot (app version, OS, recent app events) is attached, and the app says so next to the send button. | To answer you. | Your request, Art. 6(1)(b). | 24 months, then deleted |
| Purchase record — the store transaction id, a pseudonymous Apple account id and its purchase-linking token. We do not request your name or e-mail from Apple. | So a purchase you made keeps working, and one purchase does not unlock unlimited accounts. The free 7-day Trial is recorded the same way. It is not PREMIUM. Restoring that Apple purchase writes the original purchase date back, so deleting the account does not start the seven days again. | Contract, Art. 6(1)(b). | While the entitlement exists |
| Sign in with Apple refresh token. Apple issues it when you sign in to buy or restore PREMIUM, or to look for objects, paint a photo, or buy credits. We do not request your name or e-mail. | So Delete Account can revoke that Apple sign-in. | Contract, Art. 6(1)(b). | Until the account is deleted, then deleted with it |
| Photo paint — the photograph you choose, the object name and the RAL code. The photograph is sent through our backend to xAI so one object can be recoloured. We do not store the photograph or the painted result. A report from this screen does not include the photograph. We keep a job id, whether that attempt used a credit, and a daily count of how many times objects were looked for. | To recolour the object you chose. | Contract, Art. 6(1)(b). | The photograph is not kept. The job id and the daily count stay until the account is deleted |
| Photo credits — the store transaction id for a pack, the product id, and which attempts used a credit. Credits do not expire. PREMIUM and the 7-day Trial do not include them. On Android the account is a random id with no name and no e-mail, created the first time you look for objects, paint, or buy credits. | So a bought pack can be used and is not granted twice. | Contract, Art. 6(1)(b). | Until the account is deleted. A refund removes the pack. Unused credits are deleted with the account |
| A rate-limit key derived from the connection address. We store a short SHA-256 digest of the address mixed with a server secret, not the address itself. It is not used to build a profile. | To keep the service available and slow automated abuse. | Legitimate interest, Art. 6(1)(f). | Deleted within one hour |
What we do not do
- We do not track you. There is no advertising identifier, no cross-app measurement, and no third-party analytics SDK in the app.
- We never sell data, and we never share it for advertising.
- Your favourites and colour selections stay on your device. We never receive them.
- There is no account for the catalogue, favourites, or screen match. An account is created when you sign in to buy or restore PREMIUM, or when you sign in to look for objects, paint a photo, or buy credits. On Android that account is a random id with no name and no e-mail. The app keeps its free features offline. A previously verified PREMIUM grant can work offline for up to seven days before another online check is required. A confirmed trial end can stay on the device until that date. Setting the clock back does not extend it.
Who processes it for us
| Processor | What for | Where |
|---|---|---|
| Cloudflare, Inc. | App backend — entitlement, credit records, usage counts, crash reports. A photograph passes through to xAI and is not written to our database | Global edge network, incl. transfers outside the EU under the EU Standard Contractual Clauses and Cloudflare’s Data Processing Addendum |
| HOSTCREATORS s.r.o. | This website and the info@colpick.app mailbox | Slovakia (EU) |
| Apple Inc. | App distribution, payment and Sign in with Apple; we never see your payment details | Per Apple’s own privacy policy |
| Google LLC | Android distribution and payment for a credit pack. We never see your card details. We receive a purchase token so the pack can be checked | Per Google’s own privacy policy |
| xAI (SpaceXAI LLC) | Recolours one object in a photograph you chose. API inputs are not used to train models. xAI may keep an encrypted copy for up to 30 days to audit abuse, then deletes it | United States |
Transfers outside the EU
Backend requests may be served by Cloudflare infrastructure outside the European Union. A photograph you ask us to recolour is also sent to xAI in the United States for that edit. Those transfers rely on the European Commission’s Standard Contractual Clauses. The website and the support mailbox are hosted in Slovakia.
Your rights
Under the GDPR you have the right to:
- Access — ask what we hold about you.
- Rectification — have inaccurate data corrected.
- Erasure — have your data deleted.
- Restriction — ask us to stop using it while a dispute is resolved.
- Portability — receive your data in a machine-readable form.
- Objection — object to processing based on legitimate interest.
How to exercise any of them: write to info@colpick.app. We reply within two working days and complete the request within one month. You do not need an account and you do not need to explain why.
Settings → Delete Account removes the account, its entitlement links and unused photo credits from our backend. On iPhone and iPad the same action asks Apple to revoke the sign-in. If Apple cannot be reached, our records are still removed and the app says the sign-in was not revoked. On Android the account has no Apple sign-in. The photograph was not stored by us. Your local favourites are not deleted. Apple keeps its purchase record; a valid purchase can be restored after signing in again. A minimal refunded-transaction record, with no account link, is retained while the purchase system operates to prevent replaying refunded purchases. A refunded credit pack is removed, and credits already used stay used.
Where to complain
If you think we handled your data wrongly, you can lodge a complaint with the Úrad na ochranu osobných údajov Slovenskej republiky — https://dataprotection.gov.sk.
Children
COLPICK is a professional colour reference. It is not directed at children and we do not knowingly collect data from them.
Changes
If what we collect changes, this page changes with it, in the same release as the app. The date at the top is the last change.