Privacy Policy

Scope of this Privacy Policy

This Privacy Policy applies exclusively to the Coloring Fun mobile application published under the JellyDeer brand, referred to below as the “Application”.

It does not apply to the DeerDigital website or to other games and applications. Those products may have separate privacy policies reflecting their own features and data practices.

Data controller

The controller responsible for personal data processed directly in connection with the Application is:

How the Application is designed

Coloring Fun is a child-oriented coloring application that operates primarily offline and does not use a proprietary user-account system or backend.

The Application does not provide:

• user registration or login;
• public user profiles;
• chat or communication between users;
• social-networking features;
• uploading of photographs or videos;
• public sharing of children’s content;
• proprietary cloud storage of coloring progress.

The Application uses Google AdMob to display advertisements and Google Play Billing to process the optional one-time purchase.

Information that may be processed

The Application does not ask a child to enter their name, postal address, telephone number, email address or date of birth.

Depending on how the Application is used, the following information may nevertheless be processed:

• locally stored coloring progress, unlocked pictures and settings;
• limited device, Application and advertising information processed through Google AdMob;
• advertisement requests, impressions and interactions;
• diagnostic, security and invalid-traffic prevention information;
• purchase status, product identifier and purchase-verification information provided through Google Play Billing;
• contact details and message content if a parent or another person voluntarily contacts the operator;
• information reasonably necessary to provide support, process a complaint or comply with law.

The Application does not intentionally request access to a child’s:

• precise location;
• contacts;
• photographs or videos;
• microphone recordings;
• health information;
• biometric information.

Information stored locally

Coloring progress, unlocked pictures, sound settings and other operational preferences may be stored locally on the user’s device.

The operator does not normally have remote access to this local information and does not operate a proprietary server that receives the child’s coloring progress.

Local information can generally be removed by clearing the Application’s data in the device settings or uninstalling the Application.

Uninstalling the Application may not remove a purchase record maintained by Google in connection with the relevant Google Play account.

Google AdMob advertising

The free version of the Application displays advertisements using Google AdMob and the Google Mobile Ads SDK.

Because Coloring Fun is intended for children, advertising requests are intended to use the appropriate age-restricted treatment and comply with Google Play Families and AdMob requirements.

The Application does not intentionally request personalised or interest-based advertising for child users.

Advertisements may instead be selected using limited contextual information, such as:

• the general content of the Application;
• language and general regional context;
• information required to deliver and secure an advertisement;
• information required to measure basic advertising performance;
• information used to prevent fraud or invalid traffic.

Google may act as an independent controller for certain processing carried out through its advertising services.

Information processed for advertising

Google AdMob or the Google Mobile Ads SDK may process limited information necessary to request, deliver, display, secure and measure advertisements.

Depending on Google’s current implementation, device configuration and applicable law, this may include:

• IP address;
• device type and operating-system version;
• Application identifier and version;
• device language and general regional information;
• advertisement request and impression data;
• advertisement interaction information;
• diagnostic and security information;
• invalid-traffic and fraud-prevention data;
• temporary or resettable technical identifiers where legally and technically permitted.

Where child-directed or age-restricted treatment applies, the advertising implementation is intended to restrict data use and prevent prohibited advertising practices and identifiers.

Children’s privacy

Coloring Fun is intended for children and families. The Application is designed to avoid asking children to submit identifying personal information.

The Application does not include:

• user accounts;
• public profiles;
• chat;
• social sharing;
• features encouraging children to disclose their identity.

The operator does not knowingly sell children’s personal information or use it to create personalised advertising profiles.

Advertising displayed to child users is intended to be restricted to non-personalised, age-appropriate advertising in accordance with applicable Google policies.

If a parent or legal guardian believes that a child has accidentally provided personal information directly to the operator, they may contact us and request review and deletion where appropriate.

One-time Google Play purchase

The Application offers an optional one-time purchase used to unlock all coloring pages included in the purchased product.

Payments and sensitive payment information are processed through Google Play Billing.

The operator does not receive the complete payment-card number, bank-account credentials or other full payment credentials.

To unlock or restore the purchase, the Application may process:

• purchase status;
• the purchased-product identifier;
• a purchase token;
• order-related technical information;
• similar verification information supplied through Google Play.

Google Play and Google services

The Application is distributed through Google Play. Google may independently process information relating to:

• the relevant Google account;
• Application installation and updates;
• platform security and fraud prevention;
• Google Play diagnostics;
• licence and purchase verification;
• payments and purchase history;
• Google AdMob advertising.

The scope of Google’s independent processing is determined by Google under its own terms, privacy documentation and product settings.

The operator does not control all processing performed directly by Google Play, AdMob or the user’s Google account.

Purposes and legal bases

Where consent is legally required for a particular form of processing, that processing should occur only after valid consent has been obtained.

The Application does not rely on a child’s consent for personalised advertising.

Recipients and service providers

Depending on the activity, information may be processed by or disclosed to:

• Google in connection with Google AdMob, the Google Mobile Ads SDK, Google Play and Google Play Billing;
• the email provider when a person contacts the operator;
• technical providers where necessary to maintain or secure the Application;
• legal, accounting or tax advisers where necessary;
• public authorities where disclosure is required by law.

The operator does not sell personal information to third parties for their own advertising purposes.

International data transfers

Google and other service providers may process information in countries outside the European Economic Area.

Where European data-protection law applies, such transfers must rely on an appropriate legal mechanism, such as an adequacy decision, standard contractual clauses or another recognised safeguard.

The specific transfer mechanism used by an independent provider is described in that provider’s own privacy documentation.

Data retention

• Local coloring progress remains on the device until it is cleared or the Application is uninstalled.
• Ordinary support communications are retained for the time needed to respond and for a reasonable follow-up period.
• Purchase, accounting, complaint and legal records may be retained for statutory periods or applicable limitation periods.
• Advertising information processed by Google is retained under Google’s applicable settings and retention rules.

Information controlled directly by the operator will be deleted or anonymised when it is no longer required and no legal basis for further retention exists.

Data-protection rights

Subject to the conditions of applicable law, a person may have the right to:

• obtain confirmation of whether personal data is being processed;
• request access to personal data and a copy of it;
• request correction of inaccurate or incomplete data;
• request deletion;
• request restriction of processing;
• receive certain data in a portable format where the legal conditions are met;
• object to processing based on legitimate interests;
• withdraw consent where processing is based on consent;
• lodge a complaint with a competent data-protection authority.

In the Czech Republic, the relevant supervisory authority is the Office for Personal Data Protection — Úřad pro ochranu osobních údajů.

Because the Application does not operate user accounts, the operator may be unable to connect a particular person with information stored only on that person’s device.

Identity may be reasonably verified before a request is fulfilled to prevent unauthorised disclosure.

Security

Reasonable technical and organisational measures are used in view of the limited nature of the Application’s data processing.

The Application aims to minimise information, restrict access to operator-controlled records and use established Google Play and advertising infrastructure.

No system can be guaranteed to be completely secure. Do not send unnecessary sensitive information through ordinary email.

Changes to this Privacy Policy

This Policy may be updated if the Application, advertising implementation, purchase system, providers, legal requirements or data practices change.

The current version will be published on this page with its effective date.

A material change affecting children’s privacy may also be communicated through the Application or its product page where appropriate.