Privacy Policy

Effective Date: October 19, 2020

Welcome to Neocolor. PAH Ventures, LLC and its affiliates (collectively, “Neocolor,” “we,” “us,” or “our”) transform your photos into meaningful artistic coloring books. We developed this Privacy Policy to explain how we collect, use, share, and protect your Personal Information (defined below), and your choices about the collection and use of your Personal Information. This Privacy Policy applies to Personal Information collected or processed through our websites (collectively, the “Site”) and applications (collectively, the “App”) that link to this Privacy Policy (the Site together with the App, collectively, the “Service”).

1. What is Personal Information?

“Personal Information” is information that, either alone or in combination with other information, identifies you. When we combine other information (i.e., information that does not, on its own, identify you) with your Personal Information, we treat the combined information as Personal Information.

2. How We Collect and Use Personal Information

A. Information that You Provide Us

We collect the following types of information that you provide to us:

  • Contact, Account, and Payment Information.

    We process Personal Information that you provide through creation and management of your account, such as your name and email address. We also process payment information, via a third-party service provider, if you choose to purchase photo packages through the Service. We process this Personal Information only as necessary to provide the Service to you under the terms of our Terms of Use or for our legitimate interests in providing a Service that meets your needs and expectations. For example, we use this information to accept payments from you; respond to your inquiries regarding the Service; facilitate our account recovery services in the event you forget your log-in credentials; and for other purposes related to the reasons for which you provide your Personal Information. We use your email address to contact you from time to time in furtherance of our legitimate interests in providing you with information regarding the Service, such as payment receipts, information regarding critical updates to the Service, and security notices.

  • User ID and Password Information.

    We process user ID and password information to enable you to log into and use the Service. We process this Personal Information only as necessary to provide the Service to you under our Terms of Use. In the event you are able to log into our Service through a social networking site (e.g., Facebook or Twitter), we may receive Personal Information in accordance with the privacy policy of that site, which we may add to information you have already provided us.

  • User Content and Metadata.

    We process your content, which includes photos and other materials that you post through the Service, and may include Personal Information. To facilitate the Service and to make certain features available to you, we also process “metadata” related to your content. Metadata is usually technical data that is associated with your content. For example, metadata can describe how, when and by whom a piece of user content was collected and how that content is formatted. You can also add metadata to your content, such as a hashtag. We process your content and related metadata only as necessary to provide the Service to you under the terms of our Terms of Use.

B. Information We Receive from Your Use of the Services

We collect the following types of information through your use of the Service:

  • Cookies, Device Identifiers, and Similar technologies.

    When you use or access the Service, we use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use Neocolor. We process the information, including Personal Information, collected through such technologies to further our legitimate interests in operating the Service, enhancing your experience through personalization, and helping us better understand the features of the Service that you and other users are most interested in. In addition, we and our advertisers may use cookies, device identifiers, and similar technologies to provide you with personalized advertisements which provide a source of revenue to continue to allow us to provide the Service to you.

    Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of device identifiers. If you choose to reject cookies or block device identifiers, some features of the Service may not be available or some functionality may be limited or unavailable. If you disable cookies or device identifiers, you may continue to receive advertisements, but these advertisements will no longer be tailored to you. Please review your help pages of your browser or mobile device for assistance with changing your settings.

    Without an industry or legal standard of interpreting Do Not Track Signals (“DNT”) sent to us by your browser, we do not respond to DNT signals at this time. To learn more about how DNT works, please visit

  • Log File Information:

    When you use our Service, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Site), number of clicks, and how you interact with links on the Service, domain names associated with your internet service provider, pages viewed, and other such information (collectively, “Log File Information”). We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients. We use Log File Information collected from our implementation of the Service to further our legitimate interests in securing the Service by identifying potential threats and vulnerabilities, and in analyzing the effectiveness of our Service to improve the Service’s function and content.


We will not disclose your Personal Information except as set forth in this Privacy Policy or with your consent. For example, we generally do not sell, lease, or exchange your Personal Information, but if we ever do, we will first obtain your consent.

This section describes to whom we disclose Personal Information, and for what purposes:

  • Our Service Providers.

    We employ service providers to perform tasks on our behalf and to assist us in providing the Service. We take appropriate measures to help ensure that our service providers provide the same level of protection for your Personal Information as we do.

  • Advertisers.

    We may share certain information with advertising partners to enable them to deliver targeted advertisements that they believe will be of most interest to you.

  • Social Media Services.

    Third-party social networks that provide interactive plug-ins or social networking features (for example, to allow you to "Like" a page or photo on the Service) on the Service, may use cookies or other methods (for example, web beacons) to gather information regarding your use of our Service. The use of such information by a third party depends on the privacy policy available on that social network’s website, which we encourage you to carefully review. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of our Service with any of your Personal Information that they may have.

  • Google Analytics.

    We use Google Analytics, an analytics service to help us analyze the traffic on the Service. For more information on Google Analytics’ processing of Personal Information, please see “How Google uses data when you use our partners' sites or apps”.

  • Companies Involved in Mergers and Acquisition Transactions.

    If we sell or otherwise transfer part or the whole of Neocolor or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), any information collected through the Service, including Personal Information, may be among the items sold or transferred.

  • Law Enforcement, Government Agencies, and Courts:

    Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of any other person. We may also disclose Personal Information to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.


If you are using the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States. The data protection laws of the United States might not be as comprehensive as those in your country. By using the Service, you consent to your information being transferred to the United States for the purposes described in this Privacy Policy.


We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account.

Despite these efforts to store Personal Information in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as so-called hackers from illegally obtaining access to Personal Information. We do not represent or warrant that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.


Neocolor does not knowingly collect or solicit any Personal Information from children. The Service and its content are not directed at children under the age of 16. In the event that we learn that we have collected Personal Information from a child without parental consent, we will promptly take steps to delete that information.


We provide Customers with access to—and the ability to amend or delete—certain categories of Personal Information through the Account Management page. Our opt-out features, described in Section 8, also enable you to exercise your right to object to certain processing activities.

If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of, your Personal Information, you may submit a request to We will promptly review all such requests in accordance with applicable laws.

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning your Personal Information. We encourage you to first reach out to us at, so we have an opportunity to address your concerns directly before you do so.


We may send notifications, newsletters, promotions, or other information via email (“Communications”). You may choose to stop receiving Communications by indicating your preference in your account profile or settings. You may also follow the unsubscribe instructions in any email you receive. Please note that certain Service-related Communications are necessary for the proper functioning and use of the Service and you may not have the ability to opt out of those Communications.


We will retain your Personal Information for the period necessary to fulfill the purposes for which your Personal Information has been collected as outlined in this Privacy Policy unless a longer retention period is required by law.


We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing your Personal Information to third parties, including social media sites on which you choose to share your Neocolor content.


Neocolor may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING TO THE SERVICE.


If you have any questions about this Privacy Policy or the Service, please email us at