Legal
Privacy Policy
Last updated [DATE] · Draft for legal review, not yet in force
The short version
- Your art stays on your device unless you turn on Cloud.
- No ads, no advertising trackers, no selling of data.
- We never use your artwork to train AI.
- Crash reports are off until you say yes.
1. Who is responsible
Zorzen Studios (KvK [KVK NUMBER]) is the controller of your personal data under the EU General Data Protection Regulation (GDPR). Contact: [PRIVACY EMAIL].
2. What stays on your device
Artworks, brushes, palettes and settings are stored only on your device. We cannot see them. They leave your device only when you share or export them yourself, or when you turn on Pinxa Cloud.
3. What we collect and why
| Data | Why | Legal basis |
|---|---|---|
| Account: email, name and Google account ID | To sign you in, sync your work and restore purchases | Contract |
| Purchases: order ID, product, status from Google Play | To unlock what you bought. We never see card details. | Contract; tax law |
| Cloud files: artworks, brushes and their names | To store, sync and back up your work | Contract |
| Crash reports: device model, Android version, app state | To find and fix bugs. Off by default. | Consent |
| Notification token | To send the notifications you turned on | Consent |
| Support messages | To answer you | Legitimate interest |
| Waitlist: your email address and which sign-up form you used | To tell you when Pinxa is on Google Play | Consent |
| Website visits: counted without cookies or personal IDs | To see which pages help people | Legitimate interest |
| Website analytics, only if you accept cookies: pages visited, device, browser and approximate location, through Google Analytics cookies | To see which pages help people and which sign-up forms work | Consent |
Cookies. pinxa.app sets no cookies unless you accept analytics in the banner. If you do, Google Analytics sets _ga cookies that last up to 13 months, with advertising features switched off. You can change your choice at any time with “Cookie settings” at the bottom of every page; declining deletes those cookies.
4. Who helps us
We use a small number of service providers who process data only on our instructions:
- Google, for sign-in, Google Play billing and, only if you accept cookies, Google Analytics
- Formspree, which stores the waitlist sign-ups from pinxa.app
- [CLOUD HOSTING PROVIDER], for Pinxa Cloud storage in the EU
- [CRASH REPORTING PROVIDER], only if you turn crash reports on
- [EMAIL PROVIDER], for support email
We don’t sell or rent personal data, and we don’t share it for advertising.
5. Data outside the EU
Pinxa Cloud files are stored in the EU. Some providers, such as Google, may process data outside the EU. When they do, it is protected by the EU–US Data Privacy Framework or the European Commission’s standard contractual clauses.
6. How long we keep it
- Account data: until you delete your account.
- Cloud files: until you delete them, or 90 days after Cloud ends.
- Purchase records: 7 years, as Dutch tax law requires.
- Crash reports: 90 days.
- Google Analytics data: 2 months, then deleted by Google.
- Support messages: 2 years after your last message.
- Waitlist sign-ups: [WAITLIST RETENTION], or until you ask us to remove you.
7. Your rights
You can ask to see, correct, delete or download your data, to limit or object to how we use it, and to withdraw consent at any time. You can delete your account and all cloud data yourself in Settings → Privacy and data. For anything else, write to [PRIVACY EMAIL]; we reply within one month. You can also complain to the Dutch data protection authority, the Autoriteit Persoonsgegevens.
8. Children
You can paint in Pinxa without an account at any age. Accounts and Pinxa Cloud are for people aged 16 and over, or younger people with permission from a parent or guardian.
9. Security
Data is encrypted in transit and at rest in Pinxa Cloud. Only the people who need access to run the service have it.
10. Changes
If we change this policy in a way that matters, we’ll tell you in the app before it takes effect.
11. Contact
Zorzen Studios · [PRIVACY EMAIL]