Privacy Policy

Last updated: 25 Nov 2025

Welcome to “Zivo AR Drawing” (“the App”). This Policy explains how Nanjing Heyback Technology Co., Ltd. (“Company”, “we”) collects, uses, shares, and protects information when you use the App. Because Zivo does not provide account registration, all data is linked only to device-level identifiers or randomly generated session IDs.

I. Data Controller

II. Data We Collect

We do not ask you to create an account, and we do not upload your drawings or live camera feed to our servers. We may process the following categories of information in order to deliver AR drawing features, subscriptions, and advertising:

1. Device & App Diagnostics (Firebase Analytics)
   Device model, OS version, language, region, time zone, app version, first launch time, coarse location inferred from IP, engagement events (e.g. “created AR board”, “exported timelapse”).
   Purpose: product analytics, crash reproduction, feature prioritisation.

2. Crash & Performance Logs (Firebase Crashlytics)
   Stack traces, device status at crash, anonymised installation ID. These logs help us stabilise AR rendering and camera pipeline.

3. Subscription & Purchase Metadata (RevenueCat)
   Store country, product identifier, receipt / purchase token, renewable status, pricing, promotional offers. No full payment instrument data reaches us.

4. Advertising & Attribution Data

   • Advertising identifiers (IDFA, GAID, AppTrackingTransparency status)
   • Network & contextual signals (IP subnet, approximate location, device capabilities)
   • Aggregated impression / click / conversion counters
     These data points are required to deliver ads from Google AdMob, Meta Audience Network, Apple Search Ads / AdServices, or other demand partners, and to evaluate campaign performance (SKAdNetwork / Privacy Sandbox reports).

5. Camera & Photo Library Permissions
   We use the rear camera, LiDAR/ARKit/ARCore data, and optionally your photo library to overlay drawing guides. Frames and photos are processed on-device and are not uploaded to our servers; only permission status is logged for diagnostics.

6. Support Communications
   If you email us, we receive the information you provide (email, attachments, device screenshot). We use it solely to resolve your request.

III. Legal Bases & Purposes (Art. 6 GDPR)

You may withdraw consent for advertising tracking at any time in iOS Settings › Privacy › Tracking or Android Settings › Google › Ads. This will not affect processing performed before the withdrawal.

IV. Permissions & Sensors

We currently do not access motion sensors beyond what ARKit/ARCore requires; if future versions do, we will update this Policy first.

V. Data Retention

Uninstalling the App removes locally cached brushes, preferences, and any downloaded scenes.

VI. Storage & Cross-border Transfers

Operational services run on Alibaba Cloud (Singapore region). Telemetry may also be stored by Google (United States, EU), RevenueCat (United States), Meta (global infrastructure), and Apple (United States/EU). We rely on Standard Contractual Clauses (SCC 2021/914/EU) or equivalent safeguards provided by each processor.

VII. Third-party Processors

Each partner processes data strictly under our instructions and agreements.

VIII. Advertising & Tracking Choices

• iOS: Go to Settings › Privacy › Tracking to toggle “Allow Apps to Request to Track”. You can also reset IDFA via Settings › Privacy & Security › Tracking › Reset Advertising Identifier.
• Android: Settings › Google › Ads › “Delete advertising ID” or “Opt out of Ads Personalisation”.
• In-App: You can switch between personalised and contextual ads in Settings › Privacy inside Zivo. When you opt out, we continue to show contextual ads without using IDFA/GAID.
• Children: We design ad placements to comply with family policies. If you indicate you are under the minimum age required by an ad network, we only serve contextual ads.

IX. Your Rights

Where applicable (GDPR / UK GDPR / LGPD / etc.), you may:

• Request access to a copy of data linked to your device identifier;
• Request rectification or deletion (where feasible);
• Object to or restrict analytics/ads processing;
• Port subscription purchase data (where technically possible);
• File a complaint with your local supervisory authority.

Please email support@xiaoheigohome.com with your device model, OS, app version, and (if possible) advertising ID so we can locate relevant telemetry.

X. Data Deletion

Because Zivo stores drawings and brushes locally:

1. Uninstall the App to remove all creative assets and cached files from your device.
2. If you want Firebase / RevenueCat records associated with your device to be deleted, email us with the advertising ID or RevenueCat app user ID (shown under Settings › Privacy). We will forward deletion requests to our processors within 30 days.

XI. Children’s Privacy

Zivo is rated 4+ on the App Store / E for Everyone on Google Play and is intended for a general audience. Children should use the App under parental supervision to ensure safe spatial awareness. We do not knowingly collect personal data from children beyond minimal analytics described above.

XII. Changes & Contact

We may update this Policy to reflect product or regulatory changes. Material updates will be announced via in-app notice and will require renewed consent if the change affects advertising or sensitive permissions.

Contact us:

• Email: support@xiaoheigohome.com
• Address: F2594, No. 18 Yinchun Road, Maigaoqiao Innovation Park, Qixia District, Nanjing, Jiangsu, China

If you are dissatisfied with our response, you may contact your local data protection authority.