DRAW AR PRIVACY POLICY
[DRAW AR BY ULADZISLAU PAZDNIAKOU]
Last updated [January 14, 2020]
[Uladzislau Pazdniakou] (“we” or “us” or “our”) respects the privacy
of our users (“user” or “you”). This Privacy Policy explains how we
collect, use, disclose, and safeguard your information when you visit
our mobile application (the “Application”). Please read this Privacy
Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF
THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE
APPLICATION.
We reserve the right to make changes to this Privacy Policy at any
time and for any reason. We will alert you about any changes by
updating the “Last updated” date of this Privacy Policy. You are
encouraged to periodically review this Privacy Policy to stay informed
of updates. You will be deemed to have been made aware of, will be
subject to, and will be deemed to have accepted the changes in any
revised Privacy Policy by your continued use of the Application after
the date such revised Privacy Policy is posted.
This Privacy Policy does not apply to the third-party online/mobile
store from which you install the Application or make payments,
including any in-game virtual items, which may also collect and use
data about you. We are not responsible for any of the data collected
by any such third party.
COLLECTION OF YOUR INFORMATION
We may collect information about you in a variety of ways. The
information we may collect via the Application depends on the content
and materials you use, and includes:
Personal Data
Demographic and other personally identifiable information (such as
your name and email address) that you voluntarily give to us when
choosing to participate in various activities related to the Application,
such as chat, posting messages in comment sections or in our
forums, liking posts, sending feedback, and responding to surveys. If
you choose to share data about yourself via your profile, online chat,
or other interactive areas of the Application, please be advised that all
data you disclose in these areas is public and your data will be
accessible to anyone who accesses the Application.
Derivative Data
Information our servers automatically collect when you access the
Application, such as your native actions that are integral to the
Application, including liking, re-blogging, or replying to a post, as well
as other interactions with the Application and other users via server
log files.
Financial Data
Financial information, such as data related to your payment method
(e.g. valid credit card number, card brand, expiration date) that we
may collect when you purchase, order, return, exchange, or request
information about our services from the Application. [We store only
very limited, if any, financial information that we collect. Otherwise, all
financial information is stored by our payment processor, [ Amazon
Payments,] [ Authornize.Net,] [ Braintree Payments,] [ Chargify,] [
Dwolla,] [ Google Checkout,] [ Paypal, ] [ SafeCharge,] [ Stripe,] [
WePay,] [ 2Checkout,] [other], and you are encouraged to review their
privacy policy and contact them directly for responses to your
questions.
Facebook Permissions
The Application may by default access your Facebook basic account
information, including your name, email, gender, birthday, current city,
and profile picture URL, as well as other information that you choose
to make public. We may also request access to other permissions
related to your account, such as friends, checkins, and likes, and you
may choose to grant or deny us access to each individual permission.
For more information regarding Facebook permissions, refer to the
Facebook Permissions Reference page.
Data from Social Networks
User information from social networking sites, such as [Apple’s Game
Center, Facebook, Google+ Instagram, Pinterest, Twitter], including
your name, your social network username, location, gender, birth
date, email address, profile picture, and public data for contacts, if you
connect your account to such social networks. This information may
also include the contact information of anyone you invite to use and/or
join the Application.
Geo-Location Information
We may request access or permission to and track location-based
information from your mobile device, either continuously or while you
are using the Application, to provide location-based services. If you
wish to change our access or permissions, you may do so in your
device’s settings.
Mobile Device Access
We may request access or permission to certain features from your
mobile device, including your mobile device’s [bluetooth, calendar,
camera, contacts, microphone, reminders, sensors, SMS messages,
social media accounts, storage,] and other features. I f you wish to
change our access or permissions, you may do so in your device’s
settings.
Mobile Device Data
Device information such as your mobile device ID number, model, and
manufacturer, version of your operating system, phone number,
country, location, and any other data you choose to provide.
Push Notifications
We may request to send you push notifications regarding your
account or the Application. If you wish to opt-out from receiving these
types of communications, you may turn them off in your device’s
settings.
Third-Party Data
Information from third parties, such as personal information or network
friends, if you connect your account to the third party and grant the
Application permission to access this information.
Data From Contests, Giveaways, and Surveys
Personal and other information you may provide when entering
contests or giveaways and/or responding to surveys.
The following companies are the Processors of the personal data of
the applications of Draw AR:
1. AppsFlyer Ltd. https://www.appsflyer.com/ru/privacy-policy/
2. Amplitude https://amplitude.com/
3. Facebook Ireland Ltd. https://www.facebook.com/policy.php
4. Google
Inc. https://policies.google.com/terms, https://firebase.google.com/ter
ms/analytics/
5. AppMetrica by Yandex https://appmetrica.yandex.ru/
The User hereby freely gives, specific, informed and unambiguous
consent to the processing of the personal data relating to him or her
and mentioned above for the purposes of personal data processing
indicated hereto.
USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with
a smooth, efficient, and customized experience. Specifically, we may
use information collected about you via the Application to:
1. Administer sweepstakes, promotions, and contests.
2. Assist law enforcement and respond to subpoena.
3. Compile anonymous statistical data and analysis for use
internally or with third parties.
4. Create and manage your account.
5. Deliver targeted advertising, coupons, newsletters, and other
information regarding promotions and the Application to you.
6. Email you regarding your account or order.
7. Enable user-to-user communications.
8. Fulfill and manage purchases, orders, payments, and other
transactions related to the Application.
9. Generate a personal profile about you to make future visits to
the Application more personalized.
10. Increase the efficiency and operation of the Application.
11. Monitor and analyze usage and trends to improve your
experience with the Application.
12. Notify you of updates to the Application.
13. Offer new products, services, mobile applications, and/or
recommendations to you.
14. Perform other business activities as needed.
15. Prevent fraudulent transactions, monitor against theft, and
protect against criminal activity.
16. Process payments and refunds.
17. Request feedback and contact you about your use of the
Application.
18. Resolve disputes and troubleshoot problems.
19. Respond to product and customer service requests.
20. Send you a newsletter.
21. Solicit support for the Application.
22. [Other].
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain
situations. Your information may be disclosed as follows:
By Law or to Protect Rights
If we believe the release of information about you is necessary to
respond to legal process, to investigate or remedy potential violations
of our policies, or to protect the rights, property, and safety of others,
we may share your information as permitted or required by any
applicable law, rule, or regulation. This includes exchanging
information with other entities for fraud protection and credit risk
reduction.
Third-Party Service Providers
We may share your information with third parties that perform services
for us or on our behalf, including payment processing, data analysis,
email delivery, hosting services, customer service, and marketing
assistance.
Marketing Communications
With your consent, or with an opportunity for you to withdraw consent,
we may share your information with third parties for marketing
purposes, as permitted by law.
Interactions with Other Users
If you interact with other users of the Application, those users may see
your name, profile photo, and descriptions of your activity, including
sending invitations to other users, chatting with other users, liking
posts, following blogs.
Online Postings
When you post comments, contributions or other content to the
Applications, your posts may be viewed by all users and may be
publicly distributed outside the Application in perpetuity
Third-Party Advertisers
We may use third-party advertising companies to serve ads when you
visit the Application. These companies may use information about
your visits to the Application and other websites that are contained in
web cookies in order to provide advertisements about goods and
services of interest to you.
Affiliates
We may share your information with our affiliates, in which case we
will require those affiliates to honor this Privacy Policy. Affiliates
include our parent company and any subsidiaries, joint venture
partners or other companies that we control or that are under common
control with us.
Business Partners
We may share your information with our business partners to offer
you certain products, services or promotions.
Offer Wall
The Application may display a third-party-hosted “offer wall.” Such an
offer wall allows third-party advertisers to offer virtual currency, gifts,
or other items to users in return for acceptance and completion of an
advertisement offer. Such an offer wall may appear in the Application
and be displayed to you based on certain data, such as your
geographic area or demographic information. When you click on an
offer wall, you will leave the Application. A unique identifier, such as
your user ID, will be shared with the offer wall provider in order to
prevent fraud and properly credit your account.
Social Media Contacts
If you connect to the Application through a social network, your
contacts on the social network will see your name, profile photo, and
descriptions of your activity.
Other Third Parties
We may share your information with advertisers and investors for the
purpose of conducting general business analysis. We may also share
your information with such third parties for marketing purposes, as
permitted by law.
Sale or Bankruptcy
If we reorganize or sell all or a portion of our assets, undergo a
merger, or are acquired by another entity, we may transfer your
information to the successor entity. If we go out of business or enter
bankruptcy, your information would be an asset transferred or
acquired by a third party. You acknowledge that such transfers may
occur and that the transferee may decline honor commitments we
made in this Privacy Policy.
We are not responsible for the actions of third parties with whom you
share personal or sensitive data, and we have no authority to manage
or control third-party solicitations. If you no longer wish to receive
correspondence, emails or other communications from third parties,
you are responsible for contacting the third party directly.
TRACKING TECHNOLOGIES
Cookies and Web Beacons
We may use cookies, web beacons, tracking pixels, and other
tracking technologies on the Application to help customize the
Application and improve your experience. When you access
the Application, your personal information is not collected through the
use of tracking technology. Most browsers are set to accept cookies
by default. You can remove or reject cookies, but be aware that such
action could affect the availability and functionality of the Application.
You may not decline web beacons. However, they can be rendered
ineffective by declining all cookies or by modifying your web browser’s
settings to notify you each time a cookie is tendered, permitting you to
accept or decline cookies on an individual basis.
Internet-Based Advertising
Additionally, we may use third-party software to serve ads on the
Application, implement email marketing campaigns, and manage
other interactive marketing initiatives. This third-party software may
use cookies or similar tracking technology to help manage and
optimize your online experience with us. For more information about
opting-out of interest-based ads, visit the Network Advertising
Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.
Website Analytics
We may also partner with selected third-party vendors[, such as [
Adobe Analytics, ] [ Clicktale,] [ Clicky, ] [ Cloudfare, ] [ Crazy Egg,] [
Flurry Analytics,] [ Google Analytics, ] [ Heap Analytics, ] [I nspectlet,] [
Kissmetrics,] [ Mixpanel, ] [ Piwik,] and others], to allow tracking
technologies and remarketing services on the Application through the
use of first party cookies and third-party cookies, to, among other
things, analyze and track users’ use of the Application, determine the
popularity of certain content, and better understand online activity. By
accessing the Application, you consent to the collection and use of
your information by these third-party vendors. You are encouraged to
review their privacy policy and contact them directly for responses to
your questions. We do not transfer personal information to these
third-party vendors. However, if you do not want any information to be
collected and used by tracking technologies, you can install and/or
update your settings for one of the following:
[ Adobe Privacy Choices Page][ Clicktale Opt-Out Feature] [
Crazy Egg Opt-Out Feature] Digital Advertising Alliance Opt-Out
Tool [ Flurry Analytics Yahoo Opt-Out Manager] [ Google Analytics
Opt-Out Plugin] [ Google Ads Settings Page]
[Inspectlet Opt-Out Cookie] [Kissmetrics Opt-Out Feature]
[Mixpanel Opt-Out Cookie] Network Advertising Initiative Opt-Out
Tool
You should be aware that getting a new computer, installing a new
browser, upgrading an existing browser, or erasing or otherwise
altering your browser’s cookies files may also clear certain opt-out
cookies, plug-ins, or settings.
THIRD-PARTY WEBSITES
The Application may contain links to third-party websites and
applications of interest, including advertisements and external
services, that are not affiliated with us. Once you have used these
links to leave the Application, any information you provide to these
third parties is not covered by this Privacy Policy, and we cannot
guarantee the safety and privacy of your information. Before visiting
and providing any information to any third-party websites, you should
inform yourself of the privacy policies and practices (if any) of the third
party responsible for that website, and should take those steps
necessary to, in your discretion, protect the privacy of your
information. We are not responsible for the content or privacy and
security practices and policies of any third parties, including other
sites, services or applications that may be linked to or from the
Application.
SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to
help protect your personal information. While we have taken
reasonable steps to secure the personal information you provide to
us, please be aware that despite our efforts, no security measures are
perfect or impenetrable, and no method of data transmission can be
guaranteed against any interception or other type of misuse. Any
information disclosed online is vulnerable to interception and misuse
by unauthorized parties. Therefore, we cannot guarantee complete
security if you provide personal information.
POLICY FOR CHILDREN
We do not knowingly solicit information from or market to children
under the age of 13. If you become aware of any data we have
collected from children under age 13, please contact us using the
contact information provided below.
CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers and some mobile operating systems [and our
mobile applications] include a Do-Not-Track (“DNT”) feature or setting
you can activate to signal your privacy preference not to have data
about your online browsing activities monitored and collected. No
uniform technology standard for recognizing and implementing DNT
signals has been finalized. As such, we do not currently respond to
DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for
online tracking is adopted that we must follow in the future, we will
inform you about that practice in a revised version of this Privacy
Policy.
OPTIONS REGARDING YOUR INFORMATION
Account Information
You may at any time review or change the information in your
account or terminate your
account by:
● Logging into your account settings and updating your
account
● Contacting us using the contact information provided
below
● [Other] Upon your request to terminate your account,
we will deactivate or delete your account and information from
our active databases. However, some information may be
retained in our files to prevent fraud, troubleshoot problems,
assist with any investigations, enforce our Terms of Use and/or
comply with legal requirements.]
Emails and Communications If you no longer wish
to receive correspondence, emails, or other communications
from us, you may opt-out by:
● Noting your preferences at the time you register your
account with the Application
● Logging into your account settings and updating your
preferences.
● Contacting us using the contact information provided
below If you no longer wish to receive correspondence,
emails, or other communications from third parties, you are
responsible for contacting the third party directly.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the
“Shine The Light” law, permits our users who are California
residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if
any) we disclosed to third parties for direct marketing purposes
and the names and addresses of all third parties with which we
shared personal information in the immediately preceding
calendar year. If you are a California resident and would like to
make such a request, please submit your request in writing to us
using the contact information provided below. If you are under
18 years of age, reside in California, and have a registered
account with the Application, you have the right to request
removal of unwanted data that you publicly post on the
Application. To request removal of such data, please contact us
using the contact information provided below, and include the
email address associated with your account and a statement
that you reside in California. We will make sure the data is not
publicly displayed on the Application, but please be aware that
the data may not be completely or comprehensively removed
from our systems.
CONTACT US If you have questions or
comments about this Privacy Policy, please contact us at:
[Uladzislau Pazdniakou]
[Zhudro, 61]
[Belarus, Minsk, 220104]
[draw.ar.app@gmail.com]