Privacy Policy

Effective Date: July 5, 2026

Welcome to coloring.photos. We provide free printable coloring pages designed for children to enjoy. Because we are based in Croatia (EU), our processing of personal data is governed primarily by the General Data Protection Regulation (GDPR) and the Croatian Act on the Implementation of the GDPR.

This Privacy Policy explains in clear, plain language what data is collected when you visit our site, how it is used, and how your privacy rights are protected.

1. Who We Are (Data Controller)

The data controller responsible for your personal data on this website is:

• Operator: Individual Sole Operator trading as “Coloring Photos”
• Postal Address: Ivana Meštrovića 12, 48000 Koprivnica, Croatia
• Contact Email: info@coloring.photos

2. Our Approach to Children’s Privacy

While our coloring pages are designed to be enjoyed by young children, coloring.photos is intended to be navigated and utilized by adults (parents, teachers, and caregivers).

In compliance with European and Croatian laws, the digital age of consent is 16 years old. We do not knowingly collect personal data directly from children under the age of 16 without explicit parental or guardian authorization.

3. Data We Collect and Why We Process It

We process personal information under different legal bases depending on how you interact with our site:

A. Technical & Automatically Collected Data

When you browse our site, our servers automatically log technical network data to ensure the site functions correctly.

• What we collect: IP address, browser type, device type, operating system, language settings, referring URLs, and the date/time stamps of your visits and file downloads.
• Purpose: To safely deliver the digital printable files to your device, monitor site stability, detect malicious activity, and ensure overall platform security.
• Legal Basis: Legitimate Interests (GDPR Art. 6(1)(f))—essential for maintaining a secure and functional online service.
• Analytics Note: We use an internal, first-party statistics architecture that records completely anonymous print and download counts. It does not track, store, or tie individual IP addresses or personal identifiers to these metrics.

B. Advertising Operations (Playwire)

To keep our printable coloring pages completely free, we display advertisements managed by our third-party ad partner, Playwire LLC (via their Ramp monetization platform).

• What they collect: Playwire installs tracking technologies on our site that collect device identifiers, IP addresses, approximate or precise geolocation data, and browsing/ad interaction history. They use this data to serve ads, cap ad frequency, prevent fraud, and build advertising profiles.
• Data Sharing: Playwire may share or sell this data to third-party advertisers and identity networks.
• Consent: Playwire relies on us to gather your permission. Their tracking cookies will only fire after you grant explicit consent via the on-screen cookie banner.
• More Info: We do not control or store this advertising data. You can read how Playwire manages, shares, and protects your information by visiting the Playwire Privacy Policy.

C. Newsletter Sign-Up

If you choose to sign up for our email newsletter, we collect your email address.

• Age Verification: To ensure compliance with digital consent rules, our subscription forms require you to check an explicit confirmation box indicating that you are at least 16 years old and accept this privacy policy.
• Purpose: To send you updates regarding new coloring pages, site features, or community galleries.
• Legal Basis: Consent (GDPR Art. 6(1)(a)). You can instantly revoke your consent and stop receiving these emails at any time by clicking the “Unsubscribe” link at the bottom of any email we send.

D. Email Support

If you email us directly at info@coloring.photos, we collect your email address and any details you include in your message.

• Purpose: To answer your inquiries, handle support requests, or review feedback.
• Legal Basis: Legitimate Interests (GDPR Art. 6(1)(f)) to efficiently manage user support, or Performance of a Contract (GDPR Art. 6(1)(b)) if your email relates to an active service request.

E. “MoMo’s Gallery” User Submissions (Optional)

We offer an optional feature where adults can submit a photograph of a child’s completed coloring page to be displayed in our public showcase.

• Voluntary Nature: Submissions are entirely optional. You do not need to participate to download or print coloring pages.
• Submission Rule: You must upload a photo of the coloring page only. Photos displaying children’s faces, real names, or identifying domestic backgrounds are strictly prohibited and will be permanently deleted upon manual review.
• Information We Collect:
  • Mandatory Submitter Checkbox: Affirmative verification that you are the parent or legal guardian granting us permission to display the artwork.
  • Artistic Name / Nickname (Optional): A fictional or non-identifying moniker to attribute the drawing publicly.
  • Short Description (Optional): A brief text comment about the drawing.
  • Age Band (Optional): A generic category representing the site’s layout difficulty (e.g., Tiny Artist, Little Explorer, Junior Artist, Creative Pro, Master Colorist). We do not collect specific numerical ages.
  • Email Address (Single-Purpose): Used strictly to send you a notification if the artwork is selected for the gallery, allowing you to access and print an achievement certificate. This email address is isolated, never compiled into marketing lists, and never shared.
• Human-in-the-Loop Review: Every submission, including images and associated text descriptions, is manually reviewed by the site operator before it is allowed to appear on the site.
• Legal Basis: Explicit Consent (GDPR Art. 6(1)(a)). You have the right to request the total erasure of any gallery image, description, or associated email at any moment.

4. Cookies and Consent Management

We use cookies and local browser storage technologies to maintain basic site stability and to power our third-party advertising network.

• Consent Banner Management: Our cookie consent mechanisms are managed directly via Playwire’s built-in Ramp Consent Management Platform (CMP). When you visit our site from the EU, UK, or other data-regulated territories, this tool automatically asks for your explicit consent before setting any non-essential cookies.
• Adjusting Preferences: You can view, modify, or completely withdraw your cookie choices at any time by clicking the “Cookie Settings” or privacy management link located permanently in the footer of our website.

5. International Data Transfers

Our monetization infrastructure provider, Playwire LLC, is established in the United States. Consequently, technical tracking indicators (such as your IP address or device signatures) will be transferred to and processed within the US.

To ensure your personal information receives equivalent protection to European standard rules, we ensure that our data handlers utilize legal transfer instruments recognized under the GDPR, such as the EU-U.S. Data Privacy Framework or standard data protection clauses (Standard Contractual Clauses) approved by the European Commission.

6. Data Retention

We keep personal data only for as long as necessary to fulfill the objective for which it was gathered:

• Server Logs & Technical Telemetry: Automatically overwritten or deleted within 30 days, unless flagged for security investigation.
• Support Emails: Retained for up to 12 months following resolution to maintain continuity of user assistance.
• Newsletter Data: Retained until you withdraw consent by clicking unsubscribe, at which point your data is deleted from our active distribution lists.
• Gallery Submissions: Displayed and stored indefinitely unless you request removal, or until we clear out old media folders to refresh site space.

7. Your GDPR Privacy Rights

As a resident of the European Economic Area (EEA), you possess full legal rights over how your information is processed. You may contact us at any time to exercise the following permissions:

• Right of Access: Request a copy of all information we hold regarding you.
• Right to Rectification: Request that we correct any inaccurate data or incomplete information.
• Right to Erasure (“Right to be Forgotten”): Request that we fully purge your personal data (such as removing an image and email associated with MoMo’s Gallery).
• Right to Restrict or Object: Halt certain types of processing or object to our legitimate interest balancing.
• Right to Withdraw Consent: Where our processing relies completely on your consent (Cookies, Gallery, Newsletter), you can rescind that consent at any time.

To issue a request regarding your data, simply contact us via info@coloring.photos. We will fulfill your request within 30 days, free of charge.

If you believe we have handled your personal information unlawfully, you have a legal right to submit a formal grievance to your local data privacy regulator. In Croatia, the competent regulatory agency is:

Agencija za zaštitu osobnih podataka (AZOP)

Selska cesta 136, 10000 Zagreb, Croatia (www.azop.hr)

8. Changes to This Privacy Policy

We may revise this privacy text occasionally to match shifts in web practices or legal rules. When revisions are published, the “Effective Date” at the top of this document will be modified. We recommend checking back regularly.