Privacy Policy

THIS PRIVACY POLICY WAS UPDATED ON MAY.22TH.2018.

According to the General Data Protection Regulation (GDPR) (EU) 2016/679.

BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES. DrawAPP reserves the right to modify this Privacy Policy at reasonable times, so please review it frequently. If DrawAPP makes material or significant changes to this Privacy Policy, DrawAPP may post a notice on DrawAPP’s website along with the updated Privacy Policy. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

Non-personal data

For purposes of this Privacy Policy, “non-personal data” means information that does not directly identify you. The types of non-personal data DrawAPP may collect and use include, but are not limited to: application properties, including, but not limited to application name, package name and icon installed on your device. Your checkin (include like, recommendation) of a game will be disclosed to all DrawAPP users.

The data we collect depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use. The data we collect can include SDK/API/JS code version, browser, Internet service provider, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent deice identifier, iOS ad identifier (IDFA), Android ad master identifier, network card (MAC) address, and international mobile device identification code (IMEI) The equipment model, the terminal manufacturer, the terminal device operating system version, the session start / stop time, the location of the language, the time zone and the network state (WiFi and so on), the hard disk, the CPU, and the battery use, etc.

DrawAPP may use and disclose to DrawAPP’s partners and contractors the collected non-personal data for purposes of analyzing usage of the Services, investigate, prevent or take action regarding unauthorized use of the services to further develop the Services and other DrawAPP services and products.

Use of Personal Data

For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual.

Personal information collected by DrawAPP is information voluntarily provided to us by you when you create your account or change your account information. The information includes your Facebook id, name, gender, location and your friends’ id on Facebook. DrawAPP also stores your game checkins, likes, dislikes, recommendations and messages.

DrawAPP may use collected personal data for purposes of analyzing usage of the Services, providing customer and technical support, managing and providing Services (including managing advertisement serving) and to further develop the Services and other DrawAPP services and products. DrawAPP may combine non-personal data with personal data. But unless the Law forces us, we will not share any personal data with any unaffiliated third party for any purpose…ever..

The personal data and information includes:

Please note that certain features of the Services may be able to connect to your social networking sites to obtain additional information about you. In such cases, DrawAPP may be able to collect certain information from your social networking profile when your social networking site permits it, and when you consent to allow your social networking site to make that information available to DrawAPP. This information may include, but is not limited to, your name, profile picture, gender, user ID, email address, your country, your language, your time zone, the organizations and links on your profile page, the names and profile pictures of your social networking site “friends” and other information you have included in your social networking site profile. DrawAPP may associate and/or combine as well as use information collected by DrawAPP and/or obtained through such social networking sites in accordance with this Privacy Policy.

Disclosure and Transfer of Personal Data

DrawAPP collects and processes personal data on a voluntary basis and it is not in the business of selling your personal data to third parties. Personal data may, however, occasionally be disclosed in accordance with applicable legislation and this Privacy Policy.

DrawAPP may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or DrawAPP to legal liability.

DrawAPP may also disclose your personal data to third parties when DrawAPP has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with DrawAPP’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or DrawAPP believes that such disclosure is necessary to protect DrawAPP’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on DrawAPP. To the extent permitted by applicable law, DrawAPP will make reasonable efforts to notify you of such disclosure through DrawAPP’s website or in another reasonable manner.

Besides, If DrawAPP becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

Safeguards

DrawAPP follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in DrawAPP’s possession. Only those persons with a need to process your personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to your personal data in DrawAPP’s possession. Personal data collected by DrawAPP is stored in secure operating environments that are not available to the public. To prevent unauthorized on-line access to personal data, DrawAPP maintains personal data behind a firewall-protected server. However, no system can be 100% secure and there is the possibility that despite DrawAPP’s reasonable efforts, there could be unauthorized access to your personal data. By using the Services, you assume this risk.

Other

Please be aware of the open nature of certain social networking and other open features of the Services DrawAPP may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. DrawAPP is not responsible for any personal data you choose to make public in any of these forums.

If you are under 15 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access the Services. DrawAPP takes children’s privacy seriously, and encourages parents and/or guardians to play an active role in their children's online experience at all times. DrawAPP does not knowingly collect any personal information from children below the aforementioned age and if DrawAPP learns that DrawAPP has inadvertently gathered personal data from children under the aforementioned age, DrawAPP will take reasonable measures to promptly erase such personal data from DrawAPP’s records.

DrawAPP may store and/or transfer your personal data to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy. DrawAPP may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of DrawAPP’s stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provided, however, that this Privacy Policy shall continue to govern such personal data.

DrawAPP regularly reviews its compliance with this Privacy Policy. If DrawAPP receives a formal written complaint from you, it is DrawAPP’s policy to attempt to contact you directly to address any of your concerns. DrawAPP will cooperate with the appropriate governmental authorities, including data protection authorities, to resolve any complaints regarding the collection, use, transfer or disclosure of personal data that cannot be amicably resolved between you and DrawAPP.

Legal Basis for Data Processing

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you so you may use the Sites); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes).

International Transfers of Personal Data

Our business may require us to transfer your Personal Data to countries outside of the European Economic Area (“EEA”), including to countries such as the People’s Republic of China or Singapore. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as standard contractual clauses. A copy of those clauses can be obtained by contacting our Help Center.

Your Rights

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data.

Where the use of your information is based on consent, you can withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law.

We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

Requests should be submitted by contacting us through email: eyewind.draw@hotmail.com