pau. app
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Privacy policy

The least data we could possibly touch.

pau. is a calm coloring book for iPad. It has no accounts, no analytics SDKs, no ad networks, and no tracking. This page describes what little data we do touch — for subscriptions, for sending you the next page of artwork, and not much else — and what rights you have over it.

Last updated · 15 May 2026 Version 1.1 Reading time · about 6 min Data controller · Visoo Labs (SI)
The short version
  • No accounts. No email collection. No profile. No social features.
  • No analytics SDKs. No ad networks. No third-party trackers.
  • Your coloring, favorites, and progress stay on your iPad.
  • The only payment processor is Apple. The only SDK is RevenueCat (for subscriptions).
  • You have full GDPR rights — write to pau@visoolabs.com.
  • We will never sell your data. Full stop.
On this page
  1. Who we are
  2. What we collect (and don't)
  3. How we use it
  4. Third-party services
  5. Sharing your data
  6. Advertising
  7. Analytics
  8. In-app purchases & subscriptions
  9. Children's privacy
  10. How long we keep data
  11. Your rights (GDPR)
  12. Legal basis for processing
  13. Deletion requests
  14. International data transfers
  15. Changes to this policy
  16. Getting in touch
§ 01

Who we are

pau. (bundle ID com.visoolabs.pau) is a calm, single-player digital coloring book for iPad. It is designed and published by Visoo Labs, Tina Panzalović s.p., a sole proprietorship registered in Slovenia with its registered office at Breznica 12, 4274 Žirovnica. Throughout this document, "we", "us", or "pau." means Visoo Labs; "you" means whoever is using the app.

We are the data controller for any personal data processed through the app, except where third-party services (such as Apple or RevenueCat) act as independent controllers for their own purposes. Their policies are linked further down.

§ 02

What we collect (and what we don't)

The honest summary is: pau. has no user account, no profile, no friends list, no leaderboard, no comments, no email signup, and no online identity. We do not collect personal information directly from you. A few small categories of data may still be processed; we list them all below.

Things we do not collect or process

  • Your name, email address, phone number, postal address, or any other contact details.
  • Your location (no GPS, no IP geolocation, no maps).
  • Photos, camera, microphone, contacts, calendar, or health data.
  • Behavioral analytics, screen recordings, session replays, or heatmaps.
  • Any kind of advertising identifier (IDFA) or cross-app tracking signal.

On-device data (stays on your iPad)

Your coloring progress, the pages in My Works, your favorites, and your app preferences are stored locally on your iPad using standard iOS storage. This data does not leave your device unless you choose to share or back it up via iOS itself (for example through an iCloud device backup run by Apple, which we do not control or see).

Content you create

Any artwork you paint inside pau. lives on your iPad. When you tap "Save to Photos", iOS saves a copy of the image into your Photos app via the standard add-only permission. When you tap "Send feedback", iOS opens the Mail composer pre-addressed to pau@visoolabs.com; anything you choose to send arrives in our inbox. We don't receive your artwork unless you actively attach it to a message.

Catalog requests (CDN)

pau. fetches the read-only catalog of coloring pages (a small manifest plus versioned JSON and SVG files) from our content CDN, operated by a European provider. These requests are anonymous: no account, no cookie, no authentication token, and no user data is uploaded. The CDN provider may keep short-lived technical access logs (typically IP address, timestamp, and the file requested) for security and abuse-prevention purposes, as described in their privacy policy.

Purchase & subscription metadata

If you start a Premium subscription, Apple processes the transaction. RevenueCat, our subscription-state provider, then receives the StoreKit transaction data Apple already shares with them — typically anonymous or pseudonymous identifiers and the status of your subscription. We do not send RevenueCat any personal data, email address, or account identifier from our side. We never see your full payment-card details.

§ 03

How we use it

The small amount of data described above is used only to make pau. work and to comply with our legal obligations. Concretely, we use it to:

  • Deliver the catalog of pages, books, and quotes to your iPad over our CDN.
  • Process and validate your Premium subscription (via Apple and RevenueCat).
  • Keep your coloring progress, favorites, and My Works visible inside the app.
  • Improve the stability, performance, and compatibility of the app.
  • Respond to support messages you send to us.
  • Comply with legal, accounting, or tax obligations.

We do not profile you, build behavioral segments, or share your data with advertisers — there is no advertising in pau.

§ 04

Third-party services

pau. uses a deliberately tiny set of third-party services. Each one has its own privacy policy and may act as an independent controller or as our processor:

  • Apple StoreKit / In-App Purchases — the only payment processor for the app. Apple also handles "Manage Subscription" via AppStore.showManageSubscriptions(in:). See Apple's privacy policy.
  • RevenueCat (RevenueCat + RevenueCatUI SDKs) — subscription state management and paywall rendering. RevenueCat receives only the StoreKit transaction data Apple already shares with them; no personal data, email, or account identifier is sent from our side. See RevenueCat's privacy policy.
  • Apple Photos — destination when you tap "Save to Photos" on a finished page. Requires the standard iOS add-only Photos permission.
  • Apple Mail (MFMailComposeViewController) — opens a pre-addressed email to pau@visoolabs.com when you tap "Send feedback".
  • SwiftDraw (open-source Swift package) — parses bundled and downloaded SVG line art into renderable paths. Runs locally on your iPad; makes no network calls.
What pau. does not use No AI/ML services. No analytics SDK (no Firebase, Mixpanel, Amplitude, Sentry, etc.). No advertising SDK or ad network. No authentication or social-login provider. No background tracking. No maps or location service. No camera, microphone, or contacts access.
§ 05

Sharing your data

We share data only with the services listed above, and only to the extent needed to deliver the app:

  • Apple — as required for App Store distribution, purchases, and subscription management.
  • RevenueCat — purchase-related and anonymous device identifiers needed to manage your subscription state.
  • CDN — handles the anonymous content requests for catalog files.

We may also disclose information where the law requires us to (for example, in response to a valid legal request), or where we genuinely need to in order to protect rights, safety, or prevent fraud. We do not sell personal data, and we never have.

§ 06

Advertising

pau. shows no advertising. The app does not integrate any ad SDK or ad network — no AdMob, no Meta Audience Network, no in-house ads, nothing. There is no in-app advertising surface to monetize, and no advertising identifier (IDFA) is read.

If we ever introduced advertising in a future version (we have no plans to), we would update this policy and provide any consent flows required for the EEA, UK, and other regions before turning anything on.

§ 07

Analytics

pau. uses no analytics SDK. There is no Firebase Analytics, Mixpanel, Amplitude, Sentry, PostHog, or anything similar. We do not track screen views, taps, sessions, retention, or funnels.

If we ever add product analytics in a future version, we will describe it on this page and rely on consent where required by law.

§ 08

In-app purchases & subscriptions

The optional Premium subscription is processed entirely through Apple StoreKit. Payment is charged to your Apple ID; Apple handles the card, the receipt, and the renewal. We never see your card details and we do not bill you directly.

RevenueCat sits between Apple and our app: it validates the receipt with Apple, tells our app whether your subscription is active, and renders the paywall UI. RevenueCat may process identifiers and purchase history as described in their privacy policy linked above.

You can manage or cancel anytime from Settings → Apple ID → Subscriptions, or from inside pau. via the gear icon → Manage Subscription. Refunds are issued by Apple via reportaproblem.apple.com.

§ 09

Children's privacy

pau. is a Lifestyle-category app and is not directed at children under 13. We do not knowingly collect personal information from children under 13 — and given there is no account or profile system, there are very few places where such information could land in our hands at all.

If you are a parent or guardian and believe a child has somehow shared information with us inadvertently (for example by emailing us), please write to pau@visoolabs.com and we will delete it promptly.

§ 10

How long we keep data

Most pau. data isn't stored by us at all — it's on your iPad. A few specifics:

  • On-device data (coloring progress, favorites, My Works, preferences) stays on your device until you delete the app or clear its data.
  • Purchase records may be retained by Apple and RevenueCat as required for accounting, fraud prevention, and legal compliance — as set out in their policies.
  • CDN access logs are kept by the CDN provider for the limited period described in their privacy policy, for security and abuse prevention.
  • Support emails you send us are kept in our inbox for as long as needed to resolve your request, and then archived or deleted on a routine basis.
§ 11

Your rights (GDPR)

If you are in the EEA, the UK, or another region with comparable privacy rights, you have the right to:

  • Access the personal data we hold about you (we expect this to be very little).
  • Have inaccurate data corrected.
  • Have data deleted, where applicable.
  • Restrict or object to certain types of processing.
  • Receive your data in a portable format.
  • Lodge a complaint with your local supervisory authority — in Slovenia that's the Informacijski pooblaščenec.

To exercise any of these rights, email pau@visoolabs.com.

§ 12

Legal basis for processing (GDPR)

Depending on the type of processing, we rely on one of the following legal bases under the GDPR:

  • Performance of a contract — providing the app, the catalog, and the Premium subscription you requested.
  • Legitimate interests — keeping the app secure, preventing abuse of our CDN, and improving the app's stability and compatibility, where these interests are not overridden by your rights.
  • Legal obligation — keeping invoicing, tax, and consumer records as required by Slovenian and EU law.
  • Consent — only where required (for example, if we ever add optional analytics or personalized advertising in a future version). Today, we do not rely on consent because we do not process the kinds of data that would require it.
§ 13

Deletion requests

You can ask us to delete the data we control by emailing pau@visoolabs.com. Please include:

  • The app name (pau.) so we can route it correctly.
  • A short description of your request.
  • Any identifier that might help us find your data (for example the App Store / Apple ID email used for your purchase, if applicable). We don't need anything else.

Two practical notes: most pau. data only ever exists on your own iPad — deleting the app (or clearing its data in iOS Settings) removes that side of things directly. Apple and RevenueCat may still retain some purchase-related records for as long as their own policies and applicable law require.

§ 14

International data transfers

Some of the third-party services we rely on (notably Apple and RevenueCat) operate globally, including from the United States. As a result, the small amount of data described in this policy may be processed outside your country of residence. Where required by law, those providers rely on appropriate safeguards — typically the European Commission's Standard Contractual Clauses — to protect the data during transfer.

§ 15

Changes to this policy

We may update this Privacy Policy when the app changes or when the law does. Any update will be posted on this page and, where relevant, reflected in the App Store listing. The "last updated" date at the top of the page will always tell you when the current version took effect.

If a change is material (new data uses, new third-party processors, changed retention), we will give you at least 30 days' notice through an in-app notice before it takes effect.

§ 16

Getting in touch

Privacy questions, data requests, kind words — all of it goes to one inbox, read by a human:

Visoo Labs · Tina Panzalović s.p.
Breznica 12
4274 Žirovnica
Slovenia
pau@visoolabs.com

For general terms of use, see the Terms of Service. For refunds, please use Apple's refund flow — we don't have the ability to refund on their behalf.

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pau.

A calm, hand-drawn coloring book for iPad — natural brushes, a daily "color your peace" page, and no ads, accounts, or trackers. Made quietly in Slovenia by Visoo Labs.

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