Last Updated: October 21, 2025

COLORITUS UAB ("we," "our," or "us") operates one or more mobile applications (the "App").This Privacy Policy explains how we collect, use, disclose, and protect information when youuse our App(s).

1. Controller Details

Company: COLORITUS UAB
Registered Office: Kirtimu g. 47, Vilnius - 02244, Lithuania (LT)
Email for privacy requests and inquiries: econompulse@gmail.com

2. Data Minimization & Local Processing

COLORITUS UAB minimizes data collection and, whenever possible, processes data locally onyour device. We do not store unnecessary user data or track activity without your explicitconsent. Personal data is shared with third parties only when necessary for service provision orrequired by law.

3. Information We Collect

3.1 Device & Usage Data

• Device Information: Model, operating system version, unique device identifier(IDFV/IDFA).

• Usage Data: App launch times, screen views, feature toggles used.

3.2 No User Registration

No accounts, emails, or passwords are required to use the App.

4. Legal Basis for Processing

• Legitimate Interest: To operate, maintain, and improve the App.

• Legal Obligation: To comply with applicable laws.

• Consent: If you enable any optional analytics or personalization features (none enabledby default).

5. Purposes of Processing

• Provide and maintain App functionality;

• Improve performance, stability, and features;

• Diagnose and resolve technical issues;

• Analyze usage to enhance user experience.

6. Data Retention

Data is retained only as long as needed for these purposes or as required by law. Device identifiers and usage logs are deleted or anonymized after 12 months.

7. Data Sharing & Disclosure

We do not sell, trade, or rent personal data. Data may be shared only with:

• Service Providers: Under confidentiality agreements.

• Legal Authorities: In response to lawful requests.

• Business Transfers: With confidentiality safeguards in mergers or asset sales.

8. International Transfers

Data may be processed outside your country. We implement safeguards, such as StandardContractual Clauses, for cross-border transfers.

9. Your Rights

You may request access, correction, deletion, or restriction of your personal data, or with draw consent for optional features. To exercise these rights, send a request to econompulse@gmail.com with the subject “Data Processing Request”.

10. Children's Privacy

The App is not intended for children under 16. We do not knowingly collect data from minors. Ifyou believe we have, please contact us for deletion.

11. App Tracking Transparency (ATT) Compliance

If the App uses any tools that track activity across apps or websites, we comply with Apple's ATT framework. You will be prompted for permission before any tracking, and you can managethis at Settings > Privacy > Tracking on your device.

12. Security Measures

We use industry-standard measures (encryption, secure servers) to protect data. No system isfully secure; use the App at your own risk.

13. Policy Updates

We may update this Policy. We will notify you by updating the Last Updated date and posting thenew Policy in the App. Continued use signifies acceptance.