Privacy Policy

1. Who we are

Color Bud (hereinafter, "the App") is developed and operated by Ingeniería.dev, led by Chris Flores (hereinafter, "we", "the Developer").

• Contact: christian@irack.mx
• Address: Av. Javier Barros Sierra 495, Santa Fe Lomas de Santa Fe Zedec Santa Fé, Álvaro Obregón 01219, Mexico City, CDMX, Mexico

2. What data we collect

None. Color Bud was built with privacy by default, with extra care because it is intended for young children. The App:

• Does not require registration or an account
• Does not ask for the child's or the parent's email, name, age, phone number, or any personally identifiable information
• Does not access the camera, microphone, photos, location, contacts, or calendar
• Does not include any third-party SDKs for analytics, advertising, attribution, profiling, or crash reporting
• Does not send telemetry or usage metrics to any server we control
• Does not make any network requests of its own — it works fully offline

3. What is stored on the device

The App stores locally (using SwiftData inside the iOS sandbox) only what is needed to keep your child's drawings between sessions:

This data is never sent to the Developer's servers or to any third party. If you delete the App, all of this information is removed with it. There is no cloud backup, no iCloud sync, and no way for us to recover a deleted drawing.

4. External services used

None. The App makes no network requests, calls no third-party API, contacts no analytics provider, and uses no AI service. After installation from the App Store, Color Bud works fully offline — your child can use it on a plane, in a car, in a place with no Wi-Fi, with no difference in behavior.

The only network communication associated with Color Bud is the App Store itself when you download the App or receive an update — which is governed by Apple's Privacy Policy, not by us.

5. System permissions

Color Bud does not request any sensitive iOS system permission. The App does not ask for access to:

• Location
• Camera or microphone
• Photos or media library
• Contacts, calendar, or reminders
• Bluetooth or local network
• HealthKit, Motion, or any biometric data
• Push notifications
• App Tracking Transparency (ATT) — we do not track, so we do not ask

The only thing Color Bud interacts with is the touch input on the canvas.

6. Marketing and advertising

The App displays no ads. We do not collect data for remarketing, profiling, behavioral analysis, segmentation, A/B testing, or any promotional purpose. We do not participate in ad networks, we do not embed third-party ad SDKs, we do not show "rewarded video" ads, and we do not sell, share, or barter any information.

This is a deliberate decision: an app intended for a 3-year-old should not contain advertising of any kind.

7. Children's privacy

Color Bud is explicitly designed for children aged 3 to 6 and is rated 4+ on the App Store. We have taken the following measures to align with children's privacy laws, even though we do not actively place the App in the App Store "Kids Category":

• No personal information is collected from any user, regardless of age
• No accounts, no sign-up, no profiles — the App is anonymous by design
• No third-party SDKs for analytics, advertising, or attribution
• No behavioral advertising
• No external links presented to the child inside the canvas; the only external links in the App live in the parent-facing "About" / settings area
• No in-app purchases, no subscriptions, no purchase prompts
• No social features — no chat, no messaging, no sharing to social networks, no user-generated content (UGC) directory
• No camera, microphone, or location access

Because the App processes no personal information of any kind, it is structurally compliant by design with:

• COPPA (Children's Online Privacy Protection Act, United States) — no personal information is collected from a child under 13
• GDPR-K (European Union, age of digital consent 13-16 depending on country) — no personal data is processed, so no consent is needed
• LGPD Infantil (Brazil) — no personal data of minors is collected, processed, or transmitted
• UK Children's Code ("Age Appropriate Design Code") — best interests of the child by default
• LFPDPPP (Mexico) — no personal data is collected from anyone, minor or adult

Parents are nevertheless encouraged to supervise their child's use of any digital device, including Color Bud.

8. User rights (GDPR, CCPA, LFPDPPP)

Even though we collect no data, the following rights are guaranteed by design:

• Right to access: All data lives on your device and can be viewed from within the App (the gallery of drawings).
• Right to rectification: You can edit or delete any drawing at any time.
• Right to erasure: Uninstalling the App deletes every saved drawing and preference. You can also delete individual drawings from inside the App.
• Right to portability: Not applicable — no data exists on external servers.
• Right not to be subject to automated decisions: The App does not use algorithmic profiling.

For any questions about your rights — or your child's rights — please email christian@irack.mx.

9. Security

Local data is stored inside the iOS sandbox, protected by the operating system and by device-level disk encryption (Apple's Data Protection API). Because the App makes no network requests, there is no transmission of data to secure: the data never leaves the device in the first place.

10. International transfers

We do not perform international transfers of personal data because we do not store personal data on any server. The App never communicates with any server we operate. There is no data flow across borders to disclose.

11. Changes to this policy

We may update this Privacy Policy to reflect changes to the App or to applicable law. The current version will always be published at this URL, along with the date of the last update. We do not have email addresses, so we cannot notify users individually — please check this page periodically if you want to stay informed.

12. Governing law

This Policy is governed by the laws of the United Mexican States, in particular the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP). Any dispute will be submitted to the competent courts of Mexico City.

13. Contact

Privacy Officer: Chris Flores
Email: christian@irack.mx
Postal address: Av. Javier Barros Sierra 495, Santa Fe Lomas de Santa Fe Zedec Santa Fé, Álvaro Obregón 01219, Mexico City, CDMX, Mexico

If you are a parent or legal guardian and have any concern about how Color Bud interacts with your child, please email us — we monitor that inbox personally and reply within 48 business hours.