Privacy Policy & Cookies

1. GENERAL

Drawly (“Drawly”, “we”, “us” or “our”) is the Data Controller within the meaning of the General Data Protection Regulation (“GDPR”).

This privacy policy explains how we collect, process, and use (“Use”) personal data in connection with our services.

For the purposes of this privacy policy, “Services” means any websites, apps, products, and related services offered by Drawly (including any Drawly mobile, desktop, or web applications).

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2. DATA WE COLLECT, PROCESS & USE

2.1 In general

In general, you can use the Services without providing personal information such as your name, email address, postal address, telephone number, or financial information (all such information concerning the personal or material circumstances of an identified or identifiable individual data subject together “Personal Data”).

Therefore, if you do not provide us directly with Personal Data in another way or actively consent to the Use by us of certain Personal Data, we generally do not Use your data, with the exception of the following:

2.1.1 Regarding the Website

Your browser transfers certain data so that it can access the Website, namely:

    •    the IP address

    •    the date and time of the request

    •    the browser type

    •    the operating system

    •    the language and version of the browser software

2.1.2 Regarding the App(s)

Certain data is transmitted by your device when you use our app(s), including:

    •    your IP address

    •    the periods of time in which you use the app(s)

    •    the type of device you use (e.g., iPhone, iPad, Mac)

    •    events within the application recorded with Google services such as Google Analytics and Firebase

This is used to help us understand how the Services are used and to continuously improve them.

2.1.3 Free trials / account-related communications (where applicable)

In certain cases—such as downloading and installing a free trial of a paid app—we may ask you to enter a valid email address to begin your free trial (if a free trial is offered). We may use that email address to communicate with you about your trial status and related service messages.

2.1.4 Support communications

When you communicate with our support team, we save a record of the communication (including attachments and information you voluntarily decide to share with us) for troubleshooting and support purposes.

2.1.5 Emails sent by us (tracking pixels)

Email messages sent by us via third-party services such as SENDY or Amazon Web Services may contain a tracking pixel which helps us collect statistics on delivery and opening rates of our correspondence. These pixels do not provide us with additional personal data about you or your online behavior beyond these email performance metrics. You can disable image rendering in your email client to deactivate this feature; however, you may be unable to view images in emails.

Legal basis: The legal basis for processing the data described in sections 2.1.1 through 2.1.5 (to the extent such data is considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests).

    •    For 2.1.1, our legitimate interest is enabling access to the Website.

    •    For 2.1.2, our legitimate interest is understanding usage and improving the Services.

    •    For 2.1.3, our legitimate interest is communicating about your free trial and related service messages.

    •    For 2.1.4, our legitimate interest is providing the support you requested.

    •    For 2.1.5, our legitimate interest is measuring email delivery and engagement for operational and communication purposes.

2.2 Use based on consent

Only where you have given us prior consent, we may also use your Personal Data for other purposes, but only to the extent needed in each specific case. The legal basis for processing in this section is Art. 6 (1) sentence 1 lit. a GDPR (consent).

2.3 Disclosure required by law

We may disclose Personal Data to third parties where such disclosure is required by law (for example, upon request of a court or law enforcement authorities). The legal basis for processing in this section is Art. 6 (1) sentence 1 lit. c GDPR (legal obligation).

2.4 Additional uses

We may also Use certain data as set forth in section 3 below.

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3. DRAWLY’S COOKIES POLICY

3.1 Cookies on our websites

Drawly’s websites may use cookies to personalize your experience on our sites. Cookies tell us which parts of our websites people have visited, help us measure the performance of ads, and give us insights into user behavior so we can improve our communications and products.

You can disable cookies anytime in your web browser. Here is how it works in Google Chrome and Safari browsers:

Chrome:

    •    Go to Settings in the Chrome menu (Chrome toolbar).

    •    Scroll down and click Advanced.

    •    In the Privacy section, click Content settings.

    •    Click Cookies and change settings as desired.

Safari:

    •    Go to Preferences.

    •    Click the Privacy tab.

    •    Choose to Block all cookies.

For other browsers, please check the documentation provided by your browser vendor.

Drawly’s cookies do not collect information that personally identifies you. Also, other sites or companies will not be able to track you through our cookies.

When you disable cookies, our website may no longer be able to provide you with the best user experience and you may miss opportunities for personalization (such as displaying information in your language or prices in your currency).

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COOKIES: USE OF (FURTHER ANALYZING) TOOLS

Cookies are stored on your computer when using the Website. Cookies are small text files that are stored on your computer or device and associated with your browser, through which certain information is submitted to the party setting the cookie (in this case, us). Cookies serve to make our website more user-friendly and effective overall.

The Website uses cookies to the following extent:

    •    Transient / session cookies

    •    Persistent / settings cookies

    •    Analysis cookies

Transient cookies are automatically deleted when you close your browser. This includes session cookies. Session cookies store a session ID that identifies your session in the browser.

Persistent cookies help the Website remember your information and settings for future visits. They are automatically deleted after a specified period, which may differ depending on the cookie.

We also use cookies that enable analysis of a user’s browsing behavior.

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3.2 Google services and analytics (Website and apps)

The Website and apps may use Google services such as Firebase, AdMob, and Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies—text files placed on your device—to help analyze how you use the Website.

The information generated by the cookie about your use of the Website will generally be transmitted to and stored by Google on servers in the United States.

If IP anonymization is activated, your IP address will be truncated within EU/EEA member states. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there.

Google will use this information on behalf of Drawly for the purpose of evaluating your use of the Website, compiling reports on Website activity, and providing other services relating to website activity and internet usage.

The IP address transmitted by your browser within the scope of Google Analytics will not be associated with other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings in your browser; however, please note that if you do so you may not be able to use all functions of the Website.

You can also opt out from the storage by Google of the data created by the cookie and related to your use of the Website (including your IP address) and the processing of such data by Google by downloading and installing the Google Analytics opt-out browser add-on available at:

https://tools.google.com/dlpage/gaoptout?hl=en

As an alternative to the browser add-on, or within browsers on mobile devices, you may be able to use an opt-out mechanism on the Website (where provided). In that case, an opt-out cookie is placed on your device. If you delete your cookies, you may need to repeat the opt-out process.

For further information, please refer to:

    •    https://www.google.com/analytics/terms/

    •    https://support.google.com/analytics/answer/6004245?hl=en

    •    https://policies.google.com/privacy?hl=en&gl=en

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3.3 Effect of deactivating cookies/tools

If you decide to deactivate (some of) the cookies and tools described above, certain features and functionalities of the Services might not work or might not be accessible to you.

3.4 Legal basis

The legal basis for processing described in section 3 (to the extent such data is considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests). Our legitimate interest is to use and analyze data to improve our Services, understand user interests and requirements, and help personalize the user experience.

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4. TECHNICAL IMPLEMENTATION OF THE SERVICES BY SUBCONTRACTORS

We may use service providers who process Personal Data on our behalf to operate and maintain the technical platform for the Services (for example, hosting providers, analytics providers, customer support tools, or communications providers).

These service providers process data exclusively according to our instructions (processing on our behalf). The legal basis for the processing described in this section is Art. 6 (1) sentence 1 lit. b GDPR (performance of contract and pre-contractual measures) and Art. 28 GDPR (processing on behalf of a controller), where applicable.

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5. DURATION OF STORAGE OF PERSONAL DATA

Unless a shorter storage period is indicated in this privacy policy, we generally store Personal Data only as long as:

(i) required for the provision of the Services to you, and/or

(ii) necessary with regard to the contractual relationship with you, and thereafter only if and to the extent we are obliged to do so by mandatory statutory retention obligations.

If we no longer require the Personal Data for the purposes described above, such Personal Data will only be stored for the applicable legal retention period and not processed for other purposes.

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6. YOUR RIGHTS

You have the right to request information from us at any time about your Personal Data stored by Drawly.

Where applicable, if the legal requirements are met, you also have rights to request:

    •    access to your Personal Data

    •    rectification of inaccurate Personal Data

    •    erasure of your Personal Data

    •    restriction of processing

    •    to object to the processing of your Personal Data

    •    to receive your Personal Data provided to us in a structured, commonly used, and machine-readable format (data portability)

If you have given your consent to the use of Personal Data, you can revoke that consent at any time with effect for the future.

If you believe that the processing of your Personal Data by us is in breach of applicable data protection laws, you can lodge a complaint with the competent supervisory authority for data protection.

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7. KEEPING YOUR PERSONAL DATA SECURE

We have taken technical and operational precautions to protect Personal Data retained by us against unauthorized access and misuse. Our security procedures are reviewed regularly and adapted to reflect technological progress.

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8. CALIFORNIA RESIDENTS NOTICE (CCPA)

In relation to Section 1798.130 of the California Consumer Privacy Act of 2018 (CCPA):

    •    consumer rights are described in section 6 above;

    •    categories of personal information we collect or have collected about consumers in the preceding 12 months are described in sections 2 and 3 above;

    •    we do not sell, and have not sold in the past 12 months, personal information as described in subdivision (t) of Section 1798.140 CCPA.

If you need further information or would like to discuss this topic further, please visit our “Contact Us” page to get in touch.

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DISCLAIMER

COPYRIGHT

This site and its content are owned and operated by Drawly. The material included herein, including text and graphics and the selection and arrangement thereof, is © copyrighted by Drawly — All Rights Reserved.

No material from our website may be copied, reproduced, republished, posted, transmitted, or distributed in any way without prior written permission from Drawly. You may print hard copy portions of this website solely for personal, non-commercial use to benefit your knowledge and experience with Drawly. Printing material for any other reason, transferring it for use on any other website, or modification, distribution, or republication of this material without prior written permission from Drawly is strictly prohibited.

ACCURACY

Every effort has been made to ensure the accuracy of the material contained on this site. The information on this site is made available to you on the understanding that it is for guidance and information purposes only.

Users should independently verify the accuracy, currency, completeness, and relevance of the material on this site, or information contained in it if needed. Changes in circumstances after a document has been placed on the internet may impact the accuracy or currency of the information. For specific queries, please contact Drawly via the “Contact Us” page on this site.

LINKS

Drawly may link to other websites in good faith, but no assurance can be given as to the quality, accuracy, or relevance of material on such sites. We do not control these websites or the material they contain and therefore take no responsibility for them.

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If you want, I can also:

    •    replace “Website” with your actual domain name (if you share it), and/or

    •    add a simple “Contact” section (email/address) if you have one you want included.