Privacy policy

1. Controller and scope

This notice covers lu-ra.com, the Lura Colors app, support requests and participation in a TestFlight beta. The controller is:

Niklas Kopp

Maistraße 8 82377 Penzberg Deutschland

Privacy contact: support@lu-ra.com

2. Visiting the website

When you visit this website, technical connection data is sent to the hosting provider. This includes your IP address, requested URL, access time and information sent by your browser. The purpose is to deliver the website and operate it securely. The legal basis is Article 6(1)(f) GDPR; our interest is providing this service reliably.

Hosting provider: Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA

The static website is delivered through Vercel’s global network. Vercel processes technical connection and operational data. Its infrastructure providers are listed in the Vercel Trust Center.

[To be completed: confirm the hosting/data-processing agreement for production use]

Server log retention: Vercel lists a one-hour window for runtime logs available on Hobby. Other operational and security data follows the purpose-based retention criteria in Vercel’s privacy notice. Actual retention depends on the data type and purpose.

Vercel may also process data in the United States and other countries. Vercel states that it is certified under the EU-US Data Privacy Framework and identifies standard contractual clauses as another transfer mechanism. The links below explain these arrangements.

[To be completed: confirm transfer safeguards under the production hosting agreement]

We have not embedded advertising or analytics tools, externally loaded fonts, a contact form or a newsletter. The website source does not set cookies or save a language preference. Each language uses a separate URL.

3. Email support

If you write to support@lu-ra.com, we receive your sender address, message, technical email metadata and any attachments you choose to include. We use them to answer your request. Contract-related requests are processed under Article 6(1)(b) GDPR; other requests under Article 6(1)(f), with the interest of responding to your questions.

Email provider: ImprovMX; Host Europe / Microsoft

Incoming support email is forwarded by ImprovMX to our mailbox provided through Host Europe / Microsoft. These services handle message content and technical delivery data for forwarding, receiving and storing email. ImprovMX’s privacy notice mentions processing in the United States and Europe. The actual provider agreements and transfer safeguards still need to be confirmed.

Retention and deletion: Support messages are kept while needed to handle the request and related follow-up questions, then deleted. Where statutory retention duties apply or documents are needed to establish, exercise or defend legal claims, the necessary documents are retained until that reason no longer applies.

[To be completed: email transfers outside the EEA and safeguards]

Please do not send unnecessary personal details about children. Remove information from screenshots that we do not need to resolve the issue. An email link opens your own email app; your message is transmitted only when you send it.

4. Local data in Lura Colors

The app does not require a Lura account. It stores the following information locally on your device and does not automatically send it to us:

• Profiles with a name, random identifier, chosen picture and creation time. A first empty profile is created automatically.
• Saved drawings and app settings, including language, sound, display, painting level, zoom, tools and time limits.
• Painting records and usage statistics: app time, active painting time, painting actions, color changes, colors and tools used, pictures, categories and saved drawings.

5. Purpose, storage and deletion

Local storage provides the coloring book, separate profiles and selected parent features. Personal data necessary to provide the requested app service is processed under Article 6(1)(b) GDPR; necessary access to device storage is covered by Section 25(2)(2) TDDDG. The app uses no advertising or cloud analytics. The parent statistics describe app use, without assessing drawings or abilities.

Local profile data stays on the device until deleted. In the parent area, you can delete a profile together with its drawings and associated data. Other profiles and global device settings remain. Deleting the last profile creates a new empty profile. Uninstalling the app can remove locally stored data.

A statistics export that you initiate creates a local file containing profile data, settings, usage statistics and the export time. The app does not send this file. You must delete any exported file separately outside the app. The app has no cloud sync of its own.

Operating system backups, such as iCloud Backup, may include app data depending on your device settings. Apple’s settings and privacy notices apply to those services.

6. Apple and TestFlight

For store downloads, operating system services and Apple links you choose to open, Apple processes data under its own notices. These services are separate from Lura Colors.

If you use a TestFlight beta, Apple automatically collects crash and usage data and shares it with the app provider. This may include your name, email address, device, system, app and session information. Feedback and screenshots you submit are also shared. These beta records are separate from the local family statistics. We use received beta data to resolve errors under our legitimate interest in a working app (Article 6(1)(f) GDPR).

Retention of beta data received by us: Feedback and diagnostic records saved separately by us are kept while needed to investigate and resolve the reported issue. Personal details are then deleted or anonymized unless statutory duties or necessary legal claims require retention. TestFlight data held by Apple follows Apple’s own retention notices.

7. Your privacy rights

Subject to the legal conditions, you have rights to access, correction, deletion, restriction and data portability. You may withdraw consent for future processing. You may object to processing based on legitimate interests for reasons related to your particular situation.

Contact support@lu-ra.com to exercise your rights. We cannot access app data stored only on your device; you can manage it in the parent area. You may also complain to a supervisory authority, particularly where you live, work or believe a violation has occurred.