Pausi

Privacy

Pausi works without an account, ads or analytics. Your photos stay on your device – unless you want an AI picture.

Last updated: September 30, 2026. This is a translation; if in doubt, the German version applies.

Who is responsible?

TET TenThirty GmbH, Auerspergstraße 5/16A, 1080 Vienna, Austria (FN 637428w, Commercial Court of Vienna).
E-mail: valentin.gensthaler@tenthirty.at

What stays on your device

Pausi stores photos, coloring pages, puzzles, “Recently colored” and your settings only on your device. The app uses the camera and photo library only for the photos you take or choose yourself.

The quick outline, cutting out a subject and the puzzles (dot-to-dot, paint by numbers) are computed entirely on the device. Nothing is transmitted.

AI pictures

Only when you create an AI picture and have given your consent beforehand does Pausi send the photo, reduced in size and encrypted, to our server at Google Cloud (Firebase, Frankfurt data center). From there it goes to Google's AI model Gemini (Vertex AI) in data centers in the EU, which draws the coloring pages from it.

• The photo is used only for this purpose and is neither stored nor logged by us.
• According to its terms of service, Google does not use data from Vertex AI to train AI models.
• The legal basis is your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time in the app's settings.

Tip: for AI pictures, it is best to photograph toys, animals or objects – not people.

Balance and anonymous identifier

So that AI pictures and purchases reach your device, Pausi creates a random, anonymous identifier via Firebase Authentication on first launch. No name, e-mail address or account is needed.

For this identifier we store in Google Firestore (data centers in the EU): your balance of AI pictures, whether Pausi Plus is unlocked, the related bookings (time, type, amount) and which activity (coloring page, dot-to-dot, paint by numbers) you have unlocked for a picture. We do not receive the picture itself, only a random picture number.

Our server logs technical events (time, anonymous identifier, errors) for troubleshooting and to prevent abuse. These logs are deleted after 30 days.

The legal basis is the performance of the contract for the app and your purchases (Art. 6(1)(b) GDPR) and our legitimate interest in preventing abuse (Art. 6(1)(f) GDPR).

Protection against abuse

So that only the genuine Pausi app can request AI pictures, our server checks requests with Firebase App Check. For this, Apple (App Attest) or Google (Play Integrity) confirms to Firebase that the request comes from an unmodified app on a real device. No content is transmitted.

Purchases

You buy Pausi Plus and AI pictures through Apple's App Store or Google Play. Payment is handled by Apple or Google – we do not receive any payment data.

To verify purchases and credit your balance, we use RevenueCat (RevenueCat, Inc., USA). RevenueCat receives the purchase receipt and the anonymous identifier for this. For the transfer to the USA, the safeguards provided by the GDPR apply (EU standard contractual clauses). The legal basis is the performance of the contract (Art. 6(1)(b) GDPR).

What there isn't

No ads, no analytics or tracking tools, no location data, no access to contacts. Purchases in the app are protected by a question for parents.

How long we keep data

Balance, Plus status and bookings for as long as you use Pausi – otherwise purchased AI pictures would be lost. We delete them at any time on request. You delete photos and pictures on your device yourself, at the latest together with the app.

Your rights

You have the right to access, rectification, erasure, restriction of processing, data portability and objection, as well as the right to withdraw consent at any time. To do so, write to us at the address above and include your Pausi ID (Settings → Help) so we can find your anonymous balance.

You can also lodge a complaint with the Austrian Data Protection Authority: Barichgasse 40–42, 1030 Vienna, dsb.gv.at.