Color RingPRIVACY POLICY (COLOR RING)
Last Updated: 8 January 2026
This Privacy Policy (“Policy”) explains how we collect, use, share, and protect information when you use the Color Ring mobile application (the “App”) and related services (collectively, the “Service”).
By using the Service, you acknowledge that you have read and understood this Policy. If you do not agree, please do not use the Service.
1. WHO WE ARE (DATA CONTROLLER)
The Service is operated by:
MARTIN GREY LLP
Company Number: OC457668
Registered Office: First Floor Office 3 Hornton Place, London, W8 4LZ, United Kingdom
In data protection terms, MARTIN GREY LLP generally acts as the data controller (i.e., we determine the purposes and means of processing personal data).
UK Data Protection Registration (ICO). MARTIN GREY LLP is registered with the UK Information Commissioner’s Office (ICO) as a data protection fee payer. Registration reference: ZC047721.
Privacy contact: support@martingrey.app
2. SCOPE
2.1 This Policy applies to information we collect:
(a) when you use the App;
(b) when you contact support;
(c) when you participate in contests, campaigns, promotions, or similar initiatives (if offered);
(d) when you interact with our communications (e.g., emails, in-app messages), where applicable.
2.2 This Policy does not apply to third-party websites, services, or apps that may be accessible via links or integrations. Their privacy practices are governed by their own policies.
3. INFORMATION WE MAY COLLECT
We aim to collect only what is necessary to operate and improve the Service. Depending on how you use the App, we may collect:
3.1 Information you provide directly
(a) Account information (if the App supports registration/login): such as nickname/username, email address, and profile details you choose to provide.
(b) Support communications: the content of your messages, attachments, and information you voluntarily provide when contacting us.
(c) Contest/campaign information (if you participate): contact details needed to administer the campaign and deliver prizes (see Section 10).
3.2 User-generated content and related metadata
The App allows you to create images/artworks (e.g., colored drawings, saved results) and may allow you to share or publish them (if community features exist). We may process:
(a) the content you create, upload, save, or publish; and
(b) metadata associated with that content, such as creation time, likes, comments, sharing/publishing status, and in-app interactions (where applicable).
Important: if you choose to publish content publicly through the Service, it may be visible to other users or the public depending on the feature.
3.3 Device, technical, and usage information (collected automatically)
When you use the App, we may automatically collect:
(a) device and app information (device model, operating system version, language, time zone);
(b) diagnostic data (crash reports, error logs, performance data);
(c) usage data (features used, screens viewed, session frequency/duration, in-app events);
(d) IP address and approximate region/city-level information derived from network signals for security, fraud prevention, analytics, and service reliability.
3.4 Photos / camera access (only with your permission)
If you grant permission at the iOS level, the App may access your photo library and/or camera to:
(a) import images for use within App features; and/or
(b) export or save your results to your device.
We do not access your photos/camera without your permission.
3.5 Subscriptions and purchases (Apple)
Subscriptions and in-app purchases are processed by Apple’s in-app purchase system. We do not receive or store your full payment card details. We may receive information necessary to enable Premium features and support purchases, such as subscription status, product type, purchase timestamps, and transaction identifiers.
3.6 Advertising and tracking (if applicable)
If the App uses advertising, attribution, or remarketing, we may process advertising-related identifiers and signals to measure performance and prevent fraud. On iOS, certain tracking activities may require additional permission from you. If the App does not use advertising or tracking, this section does not apply.
4. HOW WE USE INFORMATION
We use information for the following purposes:
(a) to provide, operate, and maintain the Service;
(b) to enable App features, including creating and saving your artworks and results;
(c) to manage accounts and authentication (if applicable);
(d) to process and provide access to Premium features and subscription entitlements;
(e) to provide customer support, respond to requests, and troubleshoot issues;
(f) to secure the Service, prevent fraud/abuse, and enforce our rules and Terms;
(g) to analyze and improve the Service (stability, performance, user experience);
(h) to send service-related communications (e.g., subscription notices, important updates);
(i) to send marketing communications only where permitted by law and/or with appropriate consent or opt-out mechanisms;
(j) to administer contests, campaigns, and promotions (if applicable);
(k) to comply with legal obligations and protect our rights.
5. LEGAL BASES (UK/EU-STYLE FRAMEWORK, WHERE APPLICABLE)
Where UK GDPR/EU GDPR or similar laws apply, we process personal data on one or more of the following bases, depending on context:
(a) Contract: processing necessary to provide the Service and its features;
(b) Legitimate interests: e.g., security, fraud prevention, service improvement, analytics, and protection of rights, where not overridden by your interests or fundamental rights;
(c) Consent: e.g., photo/camera access, certain marketing communications, and certain tracking permissions where required;
(d) Legal obligation: compliance with applicable laws and lawful requests.
6. HOW WE SHARE INFORMATION
We do not sell personal data. We may share information in the following situations:
6.1 Service providers (processors)
We may share information with vendors and contractors who perform services for us, such as:
(a) hosting, storage, and infrastructure;
(b) analytics and crash diagnostics;
(c) subscription/purchase entitlement management;
(d) customer support tooling;
(e) prize fulfillment/shipping providers (for campaigns), if applicable.
These providers are permitted to process information only for our instructions and for the purposes described in this Policy.
6.2 Public sharing by you
If the Service offers community/public posting, information and content you choose to publish may be accessible to others. Please consider carefully what you make public.
6.3 Legal and safety reasons
We may disclose information if we reasonably believe it is necessary to:
(a) comply with applicable law, regulation, legal process, or lawful governmental request;
(b) investigate, prevent, or take action regarding suspected illegal activity, fraud, security, or abuse;
(c) enforce our Terms of Service;
(d) protect the rights, property, or safety of us, our users, or others.
6.4 Business transfers
If we are involved in a merger, acquisition, reorganization, financing, or sale of assets, information may be transferred as part of that transaction, subject to applicable law and appropriate safeguards.
7. INTERNATIONAL TRANSFERS
We are based in the United Kingdom. Your information may be processed in countries other than your country of residence, including where our service providers operate. Where required by law, we use appropriate safeguards for cross-border transfers (for example, approved contractual protections).
8. DATA RETENTION
We retain information only as long as reasonably necessary for the purposes described in this Policy, including providing the Service, complying with legal obligations, resolving disputes, and enforcing agreements. Retention periods vary depending on the type of data and the context. We may retain certain information in aggregated or de-identified form where permitted.
9. SECURITY
We use reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, alteration, disclosure, or destruction. However, no system can be guaranteed 100% secure. You are responsible for maintaining the confidentiality of any credentials and for controlling access to your device.
10. CONTESTS, CAMPAIGNS, AND PROMOTIONS (IF OFFERED)
From time to time we may run promotional campaigns, contests, challenges, or similar initiatives (“Campaigns”). Participation is voluntary.
If you participate, we may collect additional information necessary to administer the Campaign, such as verifying eligibility, contacting you, delivering prizes, fraud prevention, and compliance. Any Campaign may also have separate official rules that describe additional details and requirements.
We retain Campaign-related information only as long as reasonably necessary for administration, fulfillment, verification, and legal compliance.
11. CHILDREN’S PRIVACY
The App may be rated 4+ on the Apple App Store. We take children’s privacy seriously.
(a) We do not knowingly collect personal data from children where parental consent is required by applicable law without obtaining such consent.
(b) If you are a parent or guardian and believe your child has provided personal data to us without required consent, please contact us at support@martingrey.app, and we will take appropriate steps consistent with applicable law.
(c) Parents/guardians may have rights to review, request deletion of, or restrict further collection/use of a child’s information, depending on jurisdiction.
Note: If the Service includes public sharing/community features, parents/guardians should supervise a child’s use. Users should not post personal data of children or others without a lawful basis and appropriate permissions.
12. YOUR RIGHTS AND CHOICES
Depending on your location and applicable law, you may have the right to:
(a) request access to your personal data;
(b) request correction/rectification;
(c) request deletion/erasure;
(d) request restriction of processing;
(e) object to processing (including processing based on legitimate interests in some cases);
(f) request data portability;
(g) withdraw consent where processing is based on consent (without affecting lawfulness of processing before withdrawal);
(h) opt out of marketing communications where applicable.
To exercise your rights, contact us at support@martingrey.app. We may need to verify your identity before responding. Certain requests may be limited or refused where permitted by law (for example, to protect others’ rights, prevent fraud, or comply with legal obligations).
Marketing opt-out: If you receive promotional emails from us (where applicable), you may opt out using the unsubscribe method provided in those emails or by contacting us.
13. CHANGES TO THIS POLICY
We may update this Policy from time to time. We will update the “Last Updated” date accordingly. If we make material changes, we may provide additional notice (for example, in-app). Your continued use of the Service after changes become effective means you accept the updated Policy.
14. CONTACT
If you have questions, requests, or complaints regarding this Policy or our data practices, contact:
Operator: MARTIN GREY LLP
Registered Office: First Floor Office 3 Hornton Place, London, W8 4LZ, United Kingdom