Privacy Policy

Version: 1.0 | Effective date: 13 October 2026

Welcome to “Civo Color” (listed in app stores as “Civo Color: Color by Number”, the “App”). This Policy explains how Nanjing Heyback Technology Co., Ltd. (the “Company”, “we”, “us”) collects, uses, shares and protects information when you use the App.

The App is a color-by-number app: we provide built-in line-art pictures and you color each area by its number. The App does not offer account registration. On first launch, the App creates an anonymous user ID for you through Google Firebase and generates a device ID stored on your device. Neither contains your name, phone number or email address, but they are used to link usage records, subscriptions and feedback from the same device (see Section 2).


1. Data Controller

Item Details
Company Nanjing Heyback Technology Co., Ltd.
Registered address F2594, No. 18 Yinchun Road, Maigaoqiao Innovation Park, Qixia District, Nanjing, Jiangsu, China
Support / privacy support@xiaoheigohome.com
Legal representative support@xiaoheigohome.com
Data Protection Officer Not yet appointed; please contact us at the email above

2. Data We Collect

2.1 Identifiers

2.2 Usage Events

2.3 User Profile

Our own servers keep a profile for each anonymous user ID: device brand and model, OS version, platform, app version, interface language, country/region, first and most recent use, your onboarding questionnaire answers (see 2.4), and a snapshot of your subscription status (free / trial / Pro). We use it to understand our audience, investigate compatibility issues and reconcile subscription status.

2.4 Onboarding Questionnaire

When you complete onboarding, the optional answers you give (such as gender, age range, coloring experience, interests and how you heard about the App) are uploaded to our own servers and set as Firebase Analytics user properties, to understand our audience, measure marketing channels and improve content recommendations. You may skip these questions.

2.5 Subscription and Purchase Information (RevenueCat)

2.6 Advertising (Google AdMob)

The App shows app-open ads and rewarded video ads (which you choose to watch) through Google AdMob. Civo Pro subscribers do not see ads.

2.7 Crashes and Stability (Firebase Crashlytics)

Crash stack traces, non-fatal errors and device state at the time of a crash, associated with the anonymous user ID, used only to locate and fix problems.

2.8 Push Notifications

If you allow notifications, your push token is registered with Google Firebase Cloud Messaging and with our self-hosted push service (located in mainland China, see Section 6), together with device brand, OS version, app version, language and the anonymous user ID, to deliver notifications and measure open rates.

2.9 In-App Feedback

When you submit feedback in the App, we receive: feedback type and description, the contact details you choose to provide, screenshots (up to 3) and the App’s runtime logs that you choose to attach (to help us investigate), device brand and model, platform, OS version, app version, country/region, the anonymous user ID and device ID, and the IP address at the time of submission (to prevent abusive submissions).

2.10 Coloring Progress and Artwork (Stored on Your Device Only)

Your coloring progress and finished artwork are stored only on your device and are not uploaded to our servers. When you choose to save artwork to your photo library, the App only writes the image to the library and does not read any photos in it. When you choose to share artwork, the image is handed to the app you pick, which handles it under its own policies.

2.11 Permissions

Permission Purpose Where the data goes
Photos / Storage (write only) Saving finished artwork to your photo library Stays on your device
Notifications New pictures, campaigns and reminders See 2.8
Tracking (iOS ATT) / Advertising ID Personalised ads, ad frequency capping and measurement See 2.5 and 2.6

The App does not use the camera, microphone, location or contacts, and does not read your photos, clipboard content or list of installed apps.


Purpose Legal basis (EU GDPR)
Providing core features such as coloring, saving progress and saving artwork Performance of contract (Art. 6(1)(b))
Managing subscription entitlements through RevenueCat and reconciling subscription status Performance of contract (Art. 6(1)(b))
Analytics, product improvement, crash fixing, compatibility diagnosis, abuse prevention Legitimate interests (Art. 6(1)(f))
Onboarding questionnaire (optional) Consent (Art. 6(1)(a)); you may skip it and request deletion of submitted answers
Push notifications Consent (Art. 6(1)(a)); can be turned off in system settings
Personalised ads Consent (Art. 6(1)(a)); can be withdrawn at any time (see Section 8)
Showing non-personalised ads, measuring ad performance, preventing ad fraud Consent where required (Art. 6(1)(a)); otherwise legitimate interests
Handling your feedback Performance of contract / legitimate interests
Tax and regulatory compliance Legal obligation (Art. 6(1)(c))

4. Retention

Data category Retention
Firebase Analytics events Up to 14 months, deleted automatically by Google
Crashlytics logs 90 days, deleted automatically by Google
In-app events on our servers Up to 24 months from receipt
User profile (including onboarding answers) Up to 24 months from your most recent use
In-app feedback (including screenshots and logs) Up to 24 months after the request is resolved
Push tokens Removed within 12 months after they expire or the App is uninstalled
Anonymous user ID (Firebase Authentication) Kept until you ask us to delete it, to keep subscriptions and usage records linked
RevenueCat subscription metadata and subscription records on our servers While the subscription exists, and afterwards for as long as needed to meet accounting, tax and legal obligations
Advertising data According to Google AdMob’s retention policies

Data past its retention period is deleted or anonymised unless the law requires otherwise. Uninstalling the App removes local data on your device (coloring progress, preferences, etc.), and it cannot be recovered; artwork you have saved to your photo library is not affected.


5. Security

We protect data with encryption in transit (HTTPS), access controls and private storage. Feedback attachments are kept in private storage and can be viewed only by authorised staff through temporary links.


6. Storage and International Transfers

For transfers from the European Economic Area, the United Kingdom and similar regions to the countries above, we rely on the Standard Contractual Clauses (SCCs) or equivalent safeguards offered by our providers.


7. Who We Share Data With

Provider Role / data Policy link
Google Firebase (Authentication anonymous sign-in, Analytics, Crashlytics, Cloud Messaging) Anonymous identity, analytics, crash logs, push https://firebase.google.com/support/privacy
Google AdMob (including the User Messaging Platform) Ad serving, consent management and measurement https://policies.google.com/technologies/partner-sites
RevenueCat Subscription purchases and entitlements https://www.revenuecat.com/privacy
Apple / Google Play App distribution and payments https://www.apple.com/legal/privacy/ ; https://policies.google.com/privacy
Alibaba Cloud (Singapore; Hangzhou, China) Hosting of our servers and push service https://www.alibabacloud.com/help/en/legal/latest/fe2cxg
Cloudflare File storage (R2) for feedback attachments https://www.cloudflare.com/privacypolicy/

We do not sell your personal information for money. We do not share it with third parties except the providers listed above, where required by law, or where necessary to protect the safety of users and the public. Where you have consented to, or not opted out of, personalised ads, providing advertising identifiers and related information to Google AdMob for personalised advertising may be considered a “sale” or “sharing” of personal information under the laws of some US states; you can opt out as described in Section 8.


8. Advertising and Tracking Choices


9. Your Rights

Under applicable laws (GDPR / UK GDPR / LGPD / US state privacy laws, etc.) you may:

We will not treat you differently for exercising these rights.


10. How to Delete Your Data

  1. Uninstall the App to delete coloring progress, preferences and other local data on your device.
  2. Delete data on our servers: email support@xiaoheigohome.com with your device model, OS version and app version; if you have submitted feedback before, include its content or time so we can locate your records. After verification we will, within 30 days, delete the in-app events, user profile, feedback and push records linked to your device, and ask providers such as RevenueCat and Google Firebase to delete the corresponding records. Subscription transaction records that we must keep to meet tax, audit or other legal obligations will be deleted when the legal retention period ends.

11. Children’s Privacy

The App is intended for users aged 13 and over (its Google Play target audience is 13+) and is not directed at children. We do not knowingly collect personal information from children under 13 (or the age set by local law). If you believe a child has provided us with information without parental consent, please contact us and we will delete it.


12. Changes and Contact

If we update this Policy because of feature or legal changes, we will update the version number and effective date at the top; for material changes we will notify you in the App and obtain your consent where required by law.

Contact:

If you are not satisfied with our response, you may complain to your local data protection authority.