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
- Anonymous user ID (created by Google Firebase Authentication anonymous sign-in): the main identifier in the App. The same ID links usage analytics, subscriptions (as the RevenueCat App User ID), in-app feedback, crash reports and push notifications.
- Device ID: randomly generated by the App and stored locally; a new one is generated if you reinstall the App.
- Push token (FCM / APNs): obtained only after you allow notifications.
- Advertising identifiers (IDFA on iOS, only if you allow tracking; the Advertising ID on Android) and the IDFV on iOS.
2.2 Usage Events
- In-app events, such as screens opened, pictures browsed and selected, coloring progress and completion, use of in-app features, paywall and ad impressions and results, opening of notifications and links, and API error messages.
- Each event contains: event name, anonymous user ID, device ID, session ID, platform, app version, the country/region set on your device, interface language, event parameters and the time it occurred.
- This information is sent to Google Firebase Analytics and to our own servers for analytics, product improvement and troubleshooting. Our own servers do not store IP addresses in event records.
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)
- Store country/region, product ID, purchase receipt, renewal and trial status, price and promotional information. To support restoring purchases, syncing subscription status and push notifications, RevenueCat also receives the anonymous user ID, push token, Firebase instance ID, interface language and subscription status, as well as advertising identifiers (IDFA / Advertising ID, IDFV), IP address and OS version collected by its SDK.
- RevenueCat notifies our own servers of subscription events (such as initial purchase, trial start and conversion, renewal, cancellation, refund and expiration). From these we record the RevenueCat App User ID, product ID, store, price and currency, country/region, purchase and expiration times and whether it is a trial, to reconcile subscription status and for financial bookkeeping.
- We never access your full payment details (such as card numbers); payments are processed by Apple / Google.
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.
- Personalised ads are served only with your consent: in the European Economic Area, the United Kingdom and Switzerland, the App asks for your consent on first launch through Google’s User Messaging Platform (UMP); on iOS, the App asks for tracking permission through App Tracking Transparency (ATT). With your consent, AdMob may use advertising identifiers and other information to show you personalised ads.
- Without consent, only non-personalised ads are shown: non-personalised ads are not based on your past behaviour, but AdMob may still process device information for frequency capping, fraud prevention and aggregated reporting.
- The AdMob SDK processes advertising identifiers, IP address, device information and ad impression/click data under Google’s own policies. See Section 8 for how to change or withdraw your choices.
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.
3. Purposes and Legal Bases
| 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
- Our servers: in-app events, user profiles, feedback and subscription records are stored on Alibaba Cloud (Singapore).
- File storage: feedback screenshots and runtime logs are stored in Cloudflare R2 private storage.
- Push service: our self-hosted push service runs on Alibaba Cloud (Hangzhou, mainland China) and stores push tokens, the anonymous user ID, device brand, OS version, app version and language; notifications are delivered to your device through Google Firebase Cloud Messaging.
- Third-party providers: Google (US / EU), RevenueCat (US), Apple (US / EU).
- Our operations team is based in mainland China, and authorised staff may access the data above from mainland China to operate and support the App.
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
- European Economic Area, United Kingdom, Switzerland: on first launch, the App shows a Google UMP message asking whether you consent to personalised ads. You can reopen it at any time from “Settings › Privacy options” in the App to change or withdraw your consent. After withdrawal only non-personalised ads are shown; withdrawal does not affect the lawfulness of processing based on consent before it was withdrawn.
- iOS: the App asks for tracking permission through ATT. You can go to “Settings › Privacy & Security › Tracking” at any time to turn off tracking for this App or turn off “Allow Apps to Request to Track”. Without permission, neither the App nor AdMob reads the IDFA.
- Android: go to “Settings › Google › Ads” (on some devices “Settings › Privacy › Ads”) to delete or reset your Advertising ID.
- Residents of certain US states: you can opt out of the use of your information for targeted (personalised) advertising through “Settings › Privacy options” in the App (where shown in your region), the system settings above, or by emailing support@xiaoheigohome.com.
- Notifications: you can turn off notifications for the App in system settings at any time.
- Civo Pro subscribers do not see ads.
9. Your Rights
Under applicable laws (GDPR / UK GDPR / LGPD / US state privacy laws, etc.) you may:
- access and obtain a copy of data linked to your anonymous user ID or device ID;
- request correction or deletion (where technically feasible), including deletion of onboarding answers and feedback;
- object to or restrict processing for analytics or advertising, and withdraw any consent you have given at any time;
- opt out of the use of your personal information for targeted advertising (the “sale” or “sharing” described above);
- request an export of your subscription records;
- lodge a complaint with your local supervisory authority.
We will not treat you differently for exercising these rights.
10. How to Delete Your Data
- Uninstall the App to delete coloring progress, preferences and other local data on your device.
- 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:
- Email: support@xiaoheigohome.com
- Address: F2594, No. 18 Yinchun Road, Maigaoqiao Innovation Park, Qixia District, Nanjing, Jiangsu, China
If you are not satisfied with our response, you may complain to your local data protection authority.