Drawely Privacy Policy

THIS PRIVACY POLICY WAS UPDATED ON Sep.14TH.2020 According to the General Data Protection Regulation (GDPR) (EU) 2016/679.


We may also refer to Drawely Apps For Free team as “We”, “us” or “Our”


Drawely Apps For Free team has adopted this privacy policy (“Privacy Policy”) to explain how we collect, store, and uses the information collected in connection with our Services. 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. We reserve the right to modify this Privacy Policy at reasonable times, so please review it frequently. If we make material or significant changes to this Privacy Policy, we may post a notice on our 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 we 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 our 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.

We may use and disclose to our’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 our services and products.

Use of Personal Data

We 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 Drawely Apps For Free services and products. We 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.

Link to the privacy policy of third party service providers used by the app
Google Play Services
Fabric.io
Google Payments Privacy
Flurry
Firebase Analytics


The personal data and information include:

  • Your device types and its OS version
  • The local language and country settings on your device
  • Photos/Media: We may access files on the device such as images and videos. We do not upload this information off your device and SD card.
  • Storage: We may collect and store information (including your images and videos) locally on your device using mechanisms such as application data caches.

CHILDREN’S PRIVACY

Drawely App target all ages. We consider ourselves to be family-oriented, however, we have decided to voluntarily implement higher child protection standards even though our products and services are not directed to, and we do not knowingly collect personal information from children under 13, with the sole exception of persistent identifiers as described below. If we learn that we have collected personal information other than the persistent identifier of a child under the age of 13, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at android@drawely.com.
In order to preserve the family-friendly reputation of our Apps, we age-gated some of the features in our Apps, so that they are not available for use by children under 13. The age gate is being conducted after the download of some of our Apps for specific territories in order to assure the privacy and protection of younger users of our Apps. The features enabling potential collection and sharing of personally identifiable information, with the exception of persistent identifiers, are disabled and the same for complying with Admob policy to bring non-personalized ads for all users who did not pass the age gate.

For the user’s safety, it is not possible to change the age later on. We do not store the year of birth of users who have identified themselves as below the age of 13 in our Apps.
The only personal information we collect from users who have identified themselves as below the age of 13 for the purposes of offering our services are persistent identifiers (such as device version, advertising). Such persistent identifiers are used and shared with third parties solely for providing support for the internal operations meaning to place a contextual advertisement (including frequency capping), to authenticate users of or personalize the content on Apps, to maintain or analyze the functioning of the Apps, personalize the content of the App (such as sending push notifications), to perform network communications to protect the security or integrity of the user or the App, to ensure legal or regulatory compliance.
When using the persistent identifiers we will not contact users under the age of 13, display behavioral advertising to them, nor do any user tracking or profiling. In addition, we strive that all of our advertising partners adhere to the same standards for the collection, usage, and disclosure of children’s personal information as we do, but we can not be responsible if they breach the commitments they gave to us regarding the collection of information. In case of such breaches, you agree that our liability is limited to the amounts we are able to receive as indemnification for the breaches from our advertising partner. For detailed information about disclosure to third parties please see section How do we share your information and data to third parties of this Privacy Policy. For any additional questions about third-party information disclosure please refer to android@drawely.com.
We will send push notifications only to users who allow us to do so in order to re-engage them in terms of using the App. You may unsubscribe at any time by following the instructions in section Push Notifications of this Privacy Policy. We strive to ensure that the content of the push notifications will always be family-friendly. Push notifications are using Firebase Messenging only Here the link for the Firebase Privacy Policy.

Disclosure and Transfer of Personal Data

We collect and process 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. 
We 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 Drawely Apps For Free to legal liability.
We may also disclose your personal data to third parties when we have a reason to believe that disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users, or others who may be harmed or may suffer loss or damage, or we believe that such disclosure is necessary to protect our rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on us. To the extent permitted by applicable law, we will make reasonable efforts to notify you of such disclosure through our website or in another reasonable manner. 
Besides, If we become 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

We follow generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information in our 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 our possession. Personal data collected by us is stored in secure operating environments that are not available to the public. To prevent unauthorized on-line access to personal data, we maintain personal data behind a firewall-protected server.

Other

Drawely Apps For Free is not responsible for any personal data you choose to make public in any of these forums.
We 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. We may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our 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.
We regularly review its compliance with this Privacy Policy. If we receive a formal written complaint from you, it is our policy to attempt to contact you directly to address any of your concerns. We 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 us.
Legal Basis for Data ProcessingWe 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 DataOur 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: android@drawely.com
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