Chloe’s Paint by Numbers Privacy Policy

1. Who we are

Chloe’s Paint by Numbers is published by Opus Accountancy Limited, a limited company registered in England and Wales, company number 03956240, with its registered office at Bretton House, Bell Meadow Business Park, Park Lane, Pulford, Chester, CH4 9EP.

Opus Accountancy Limited is the data controller for the personal data described in this policy. That means it decides what is collected and why. This policy covers the Chloe’s Paint by Numbers app only. It does not cover any website, and it does not cover any other app.

App

Chloe’s Paint by Numbers (iOS, iPadOS)

Published by

Opus Accountancy Limited

Company number

03956240

Registered office

Bretton House, Bell Meadow Business Park, Park Lane, Pulford, Chester, CH4 9EP

Data protection contact

[email protected]

2. What this app collects

Chloe’s Paint by Numbers collects no personal data at all. There is no account, no sign-in, and nothing you do in the app is sent to us.

3. What this app does not collect

Apple groups the data an app might collect into categories, and asks a developer to declare which apply. For Chloe’s Paint by Numbers, these do not:

• contact information, such as your name, email address or phone number
• health or fitness data
• financial information, such as payment card details
• your location
• sensitive information, such as racial or ethnic origin, health or sexual orientation
• your address book or contacts
• content you create, such as photos, messages or files
• your browsing history
• your search history
• identifiers that could be used to recognise you or your device
• your purchase history
• data about how you use the app
• diagnostic data, such as crash logs or performance measurements
• any other personal data

The app does not track you. It does not link what you do in it to data from other companies’ apps or websites, and it shares nothing with data brokers.

4. Why, and the lawful basis

The UK GDPR requires a lawful basis for processing personal data. This app processes none, so there is none to rely on.

Things that stay on your device

Paintings are saved in the app’s own storage on your device, so a picture left half-finished is waiting when you come back to it. The app also remembers, on the device, whether it has already shown the guide to painting gestures. None of this is sent to us.

If your device is backed up, the saved paintings are included in that backup, as most apps’ files are. An iCloud backup goes to Apple as your storage provider, under Apple’s privacy policy; a backup to a computer stays with you. Either way it never reaches us.

When a picture is finished, you can save it to Photos. The app asks only for permission to add pictures: it cannot see, read or change anything already in your photo library, and the saved picture goes into your library, not to us.

Extra picture packs are bought from Apple, with your Apple Account. Apple takes the payment under its own terms, and your payment details are never available to the app or to us. To unlock a pack, the app asks Apple, from your device, which packs you own. Restoring purchases and redeeming an offer code work the same way. Apple does not tell us who made a purchase.

Children

Chloe’s Paint by Numbers is made for children. It collects no personal data from anyone, of any age: there is no account or sign-in, no advertising, no analytics and no tracking, and nothing a child does in the app is sent to us.

The shop, redeeming a code and restoring purchases all sit behind a grown-ups’ question — a sum a young child is unlikely to work out — so a child cannot start a purchase on their own. Apple also asks for its own confirmation before any payment is taken.

There are no links out of the app to websites, and no way to message or share with anyone from inside it.

How long data is kept

The app sends us no personal data, so there is nothing for us to keep.

Saved paintings stay on your device until you delete the app, which removes them. A copy in a device backup taken earlier stays in that backup until the backup is replaced or deleted. Pictures you saved to Photos stay in your photo library until you delete them there.

Apple keeps its own record of your purchases, under Apple’s terms. That record is what lets you restore them on a new device.

Your rights over your personal data

You have rights over the personal data we process as controller. We aim to respond promptly; how long a response takes depends on the nature and extent of the request. You have the right to:

• request access to your personal data under Article 15 of the UK GDPR, so that you receive a copy of what we hold;
• request rectification under Article 16 of any errors or inaccuracies in it;
• request erasure under Article 17 where there is no good reason for us to continue processing it;
• object to processing under Article 21 where we rely on legitimate interests and you believe your own interests or rights override them;
• request restriction of processing under Article 18, for example while its accuracy is established;
• withdraw consent under Article 7 where we process on the basis of your consent;
• request the transfer of your personal data to you or to another controller under Article 20.

To exercise any of these rights, email [email protected]. There is no charge.

We do not carry out automated decision-making that produces legal effects concerning you or similarly significantly affects you, and we do not profile individuals.

Getting help with the app

Questions about how Chloe’s Paint by Numbers works, rather than about your personal data, are answered on the support page at opus.expert/chloes-paint-by-numbers/support, which also explains how to ask for your data to be deleted.

Contact and complaints

If you have any question about this policy, or would like to discuss how we process personal data, email [email protected]. You can also write to us at Bretton House, Bell Meadow Business Park, Park Lane, Pulford, Chester, CH4 9EP.

You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection. We would ask you to raise the matter with us first so that we have the chance to put it right.

Information Commissioner’s Office

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Telephone 0303 123 1113. ico.org.uk/concerns

Changes to this policy

We may update this policy from time to time. The current version is always the one published on this page, and its effective date is shown at the top. Where a change materially affects what the app collects, it is accompanied by an update to the app’s App Store privacy details.