Privacy Policy

Who is responsible

Souvenir Color is published by MAKATA STUDIO S.A.S. (NIT 901192999-3), Carrera 38 Sur #35-06, Envigado, Antioquia, Colombia, the data controller. For any question or request: hello@makata.tv or +57 314 596 1611.

At a glance

• No account, no advertising, no audience measurement or advertising tracking tools in the app.
• Your photos are analyzed on your iPhone to suggest ideas; they do not leave it for that.
• A photo is sent only when you request a drawing and agree to it, and only that photo is sent.
• It is deleted from our servers as soon as your iPhone has saved the drawing, and within 30 minutes at most (72 hours for a drawing scheduled for the next morning).
• Your drawings and your progress stay on your iPhone.

What stays on your iPhone

• Access to your photos: the app reads the photos you give it access to in order to prepare suggestions and albums. This analysis (faces, subjects, image quality) happens on the device, with Apple’s tools.
• Your drawings, their progress, your texts and stickers, your settings.
• If you turn on iCloud previews in Settings, Apple may download photos from iCloud to the iPhone to prepare the previews; the analysis stays on the iPhone.
• “Your drawing is ready” notifications, scheduled locally.
• The optional performance panel in Advanced settings: its measurements do not leave the iPhone.

Deleting the app erases these data from the iPhone.

Photos sent to create a drawing

When you tap “Create,” schedule a drawing for the next day or choose “Surprise me,” the app asks for your consent before sending anything. Without consent, nothing is sent.

• Only the chosen photo is sent, reduced to at most 1,024 pixels and saved again without its metadata (no location, date or device).
• It is sent encrypted to our creation service, which we run on the servers of Modal Labs, Inc. The drawing is produced there by artificial intelligence models that we operate ourselves; no other artificial intelligence company receives your photo.
• The photo and the drawing are deleted as soon as your iPhone confirms it has saved the drawing, or if you cancel. Otherwise, they expire 30 minutes after the request, or 72 hours for a scheduled drawing; an automatic cleanup runs every five minutes.
• They are used for nothing else: no model training, no sharing, no selling.

The installation identifier

The first time you create a drawing, the app registers a random identifier with our service and a secret kept in the iPhone’s keychain. This identifier is linked neither to your name, nor to your Apple ID, nor to the device’s identifiers.

The service keeps this identifier, a fingerprint of the secret (never the secret itself), the app’s name and version, the operating system, the registration date and the last day of use. It is used to secure your requests and apply the daily creation limit. It is kept as long as the installation is used; you can ask for its deletion.

Technical data

• Creation counters per installation and per day, and for each request a hash fingerprint (SHA-256) that cannot reconstruct the photo, kept for 7 days to avoid duplicates.
• To limit abuse, the number of new installations per IP address and per day: the address is not kept as it is, only a hash fingerprint (SHA-256) tied to the day, deleted after 8 days.
• Our logs contain only technical events (request number, error type), never photos.
• Our hosting provider may keep connection logs (including the IP address) under its own policy.

Album place names (optional)

Off by default. If you turn it on in Settings, the app sends Apple the approximate location of a group of photos to obtain the city name, which it keeps on the iPhone. Apple handles this request under its own privacy policy.

Why we may process these data

Sending a photo and looking up place names are based on your consent, which you give at the time of the action and may refuse. The installation identifier, counters and logs are based on our legitimate interest in securing the service and limiting its use.

Recipients and transfers

Modal Labs, Inc. hosts our creation service as a data processor. Its servers are outside Colombia and the European Union, including in the United States. Modal acts only on our instructions, under its data processing agreement: it may use your data only to operate the service, encrypts them at rest and in transit, and has its security audited (SOC 2 Type II). Your photo is sent there only with your consent, given when you create a drawing. Apple receives place-name requests if you enable that option. No one else receives your data.

Children

Souvenir Color is intended for adults. If a photo that is sent shows a child, it is handled exactly like any other: only to create the drawing, then deleted as described above.

Your rights

You can request access to your data, their correction or deletion, object to processing or request its restriction, and withdraw your consent at any time by writing to hello@makata.tv. If possible, include the approximate date of your creations: we know neither your name nor your email address.

We respond to information requests within ten business days and to complaints within fifteen business days, as provided by Colombian law (Law 1581 of 2012).

You can also file a complaint with the CNIL (cnil.fr). In Colombia, you can contact the Superintendencia de Industria y Comercio (sic.gov.co).

Security

Communications with our service are encrypted (HTTPS). The installation secret stays in the iPhone’s keychain; our servers keep only a fingerprint of it.

Changes

If this policy changes, the new version is published on this page with its date.