Privacy Policy

This Privacy Policy applies to ColorWalk (the “App”), a mobile application provided free of charge (with in-app advertising) by Beomjun Kang (the “Service Provider”). The Service Provider values your privacy and complies with applicable data protection laws.

1. Information we collect

The App can be used without creating an account, and we do not ask for or collect directly identifying information such as your name, email address, or phone number.

The following information may be collected automatically when you download and use the App:

About IP addresses

Your IP address is transmitted to third-party services when the App connects to the internet, but Google Analytics does not log or store IP addresses. They are used only momentarily to infer approximate country- or region-level location, and are then discarded.

Location information

The App does not collect location information via GPS, cell towers, or Wi-Fi, and does not request location permissions. Only the approximate country- and region-level information described above is used, for aggregate usage statistics and ad delivery.

Nature of the identifiers

These identifiers are pseudonymous — they are not linked to directly identifying information such as your name, email address, or phone number. However, because they distinguish individual app installations or devices, they are not fully anonymous, and the Service Provider treats them with the same care as personal information. If you reset your advertising identifier in your device settings, the app instance identifier is reset along with it.

2. Information processed on your device

• Photos and daily records you capture or select are stored only on your device. They are never uploaded to the Service Provider’s servers or shared externally.
• The App may request camera and photo library permissions in order to take or import photos. These permissions are used only when you use those features, and the remaining features continue to work if you decline.
• The App may also request notification permission for the daily reminder that tells you the color of the day. This is requested only when you turn the reminder on yourself in the settings screen (off by default), and the notification is scheduled and shown entirely on your device. No information is sent to any server to deliver it, and the notification content does not include your photos or records. The remaining features continue to work if you decline.

3. Third-party services

The App uses the following third-party services for usage analytics, crash reporting, and advertising. Each has its own privacy policy:

Only the data described in the table above is transmitted to these services, and the Service Provider uses it solely to operate and improve the App and to serve advertising. Google prohibits its customers from sending personally identifiable information (PII) to Google Analytics, and the Service Provider does not transmit any directly identifying information.

4. Advertising

The App is provided free of charge and displays in-app advertising through Google AdMob to cover operating costs. The ads shown are banner ads displayed on screen and rewarded ads that you choose to watch in exchange for a reward.

Personalized advertising

• The App uses personalized advertising. Google and its advertising partners may serve ads matched to your interests based on your advertising identifier and your app usage.
• The identifiers used for this are the Android Advertising ID (AAID) and the iOS Identifier for Advertisers (IDFA). You can reset either identifier or limit its use at any time in your device settings.
• On iOS, the App requests App Tracking Transparency permission. If you do not allow it, the IDFA is not used, and all features of the App remain fully usable.

Users in the European Economic Area (EEA), the UK, and similar regions

• Where prior consent is required, the App presents a consent form through Google’s User Messaging Platform (UMP) to request your consent to the collection and use of personal data for ad personalization.
• If consent is not obtained, the App does not request ads.
• You can change your choices at any time via “Privacy choices” in the App’s settings screen (which manages your advertising privacy choices). That option is shown to users in regions where prior consent is required.

Google signals (Analytics Advertising Features)

The App uses Google signals data collection, one of the Google Analytics Advertising Features.

• Feature in use: Google signals data collection. For users who are signed in to a Google account and have turned on Ads Personalization, statistical reports are enriched with the age range, gender, and interest categories that Google estimates from the information it holds.
• How identifiers are used: The Service Provider and Google use first-party identifiers such as the App Instance ID and Firebase installation ID, and Google may additionally use its own advertising identifiers, including those described above. The Service Provider does not identify individual users through this feature and only views the results as aggregated statistics from which no individual can be recognized.

How to opt out of advertising

You may opt out of personalized advertising at any time by any of the following means:

• In the App: “Privacy choices” in ColorWalk’s settings screen, which manages your advertising privacy choices (shown to users in regions where prior consent is required)
• iOS: Settings → Privacy & Security → Tracking, and turn off tracking permission for ColorWalk
• Android: Settings → Google → All services → Ads, and delete or reset your advertising ID
• At the Google account level: Turn off Ads Personalization in Google Ad Settings — https://myadcenter.google.com
• Analytics opt-out (for web browsers) — https://tools.google.com/dlpage/gaoptout/

If you opt out, ads may still appear, but they will be general ads that are not based on your interests.

5. Disclosure of information

The Service Provider does not sell or rent your information. Automatically collected information may be disclosed in the following cases:

• When required by law, or in response to a subpoena or similar lawful legal process
• When the Service Provider believes in good faith that disclosure is necessary to protect its rights, protect your safety or the safety of others, investigate misuse, or respond to a government request
• When sharing with trusted service providers who work on the Service Provider’s behalf, do not use the disclosed information independently, and have agreed to adhere to the rules set out in this policy

6. Data retention and deletion

• Crash data: Firebase Crashlytics keeps crash stack traces and associated identifiers (including Crashlytics installation UUIDs and Firebase installation IDs) for 90 days before beginning the process of removing them from live and backup systems.
• Analytics data: In Google Analytics, event-level data is deleted automatically after 2 months and user-level data after 14 months. Aggregated statistical reporting data, which cannot identify an individual, is not subject to that retention period and may be kept.
• Advertising data: Retention and deletion of data processed using advertising identifiers is governed by Google’s advertising policies; see the Google documentation linked in Section 3 for details.
• On-device data: Photos and records stored on your device can be deleted at any time using “Delete All Data” in the App’s settings screen, and they are removed together with the App if you uninstall it.
• If you wish to delete information you provided directly to the Service Provider by email, contact us at the address below and we will respond within a reasonable time.

7. Your rights

You may exercise the following rights at any time:

• Opt out of collection: Uninstalling the App stops all collection of information by the App. You can use the standard uninstall process available on your device or through the app marketplace.
• Delete on-device data: Use “Delete All Data” in the App’s settings screen to remove photos, memos, and stats stored on your device without uninstalling the App.
• Withdraw permissions: You can revoke camera, photo library, and notification permissions at any time in your device settings.
• Opt out of personalized advertising: You can opt out at any time using the methods described under “How to opt out of advertising” in Section 4.
• Access, correction, deletion, and suspension of processing: Contact us at the address below and we will respond within the period required by applicable law.

8. Children’s privacy

• Under the Korean Personal Information Protection Act, the Service Provider does not knowingly collect personal information from children under the age of 14.
• Under the U.S. Children’s Online Privacy Protection Act (COPPA), the Service Provider does not use the App to knowingly solicit data from, or market to, children under the age of 13.
• The App is not primarily directed to children. If the Service Provider discovers that a child below these ages has provided personal information, it will be deleted immediately. If you are a parent or guardian and become aware that your child has provided personal information, please contact us so that we can take the necessary action.

9. Security

The Service Provider applies physical, electronic, and procedural safeguards to protect the information it processes and maintains. However, no method of transmission over the internet or electronic storage is 100% secure, so absolute security cannot be guaranteed.

10. Changes to this policy

This policy may be updated from time to time. The Service Provider will notify you of any changes by posting the updated policy on this page. Your continued use of the App after a change takes effect constitutes acceptance of the updated policy. Please review this page periodically.

11. Your consent

By using the App, you consent to the processing of your information as set out in this policy and as amended by the Service Provider.

12. Contact

For questions about this policy, complaints, or remedy requests regarding the handling of personal information, please contact:

• Data Protection Officer: Beomjun Kang
• Email: smulsmul2020@gmail.com

13. Dispute resolution (Republic of Korea)

If you need counseling or remedies for infringement of personal information, you may contact the following organizations: