DRAWNTOGETHER
Privacy Notice
Pop Sandbox (collectively “we” “us” “our” “Pop Sandbox”) make the app DrawnTogether (the “App”) available to the public. This Privacy Notice outlines how we collect, use, disclose, and retain Personal Information when you use the App.
WHAT PERSONAL INFORMATION DO WE COLLECT?
In this Privacy Notice, Personal Information means any information that can be used to identify you, either alone or in combination with other information. (“Personal Information”).
Information you provide to us
When you use the App, we may collect the following Personal Information directly from you:
● Profile Information, such as your name, username and password, email address, your profile image or avatar and links to your profiles on various social networks or websites;
● Correspondence, including your name, contact information and the contents of your messages, when you contact us with your questions;
● Order and Payment Information, which will be limited to the last 4 digits of your credit card number, and will include details on your order for in-game items, subscriptions or other tangible goods such as T-shirts and posters; and
● Personal Information about others. We give you the ability to invite people from your network to use the App, including by importing your address book or manually entering their contact information, such as name and email or phone number. You are responsible for ensuring that you have permission to share this information with us.
Information We Get About You From Connected Third-Party Platforms
We may collect your Personal Information when you connect to third-party platforms and social networks. Depending on the third-party platform or social network, your privacy settings and your friends’ privacy settings, we may collect and use the following Personal Information:
● Profile Information, including your name, social network user name, list of friends or contacts, email address and phone number;
If you are unclear about what information a third-party platform is sharing with us, please go to that platform or social network to find out more about their privacy practices and any options available to you regarding such sharing.
Information we collect automatically
When you use the App, we will collect Personal Information about the ways in which you use and interact with the App, such as when and for how long you use it, which features and other players you interact with, what progress or levels you achieve, and other activities and features you use. We also collect images, drawings or other user-generated content that you create or upload on the App. Finally, we use third parties to help us place personalized advertisements in the App and better understand our users. These third parties may automatically collect certain information as described in more detail below in ‘Automated Collection’ below.
HOW DO WE USE PERSONAL INFORMATION?
We may use your Personal Information for the following purposes:
● To create and administer your account on the App;
● To process payment on the App;
● To make better recommendations on in-app content, which we do by collecting information on the choices you make in the App, such as art you interact with, artists you follow, tools and colours you use;
● To help you to connect with other people you know and other third-party platforms you use, including communicating with others, including sending them an invitation to use the App;
● To communicate with you about the App, including to provide you with information on in-game updates and new features;
● To provide customer service, including technical support, and to respond to inquiries;
● To comply with our regulatory and legal obligations;
● To detect, prevent or investigate security breaches or fraud and to protect our business, including to enforce ours or others’ legal rights or to comply with applicable laws; and
● For any other purposes for which you provide consent.
AUTOMATED COLLECTION
We use Google Analytics to help us understand how users interact with the App. We also use Google AdMob to display personalized third party ads within the App, which helps us offer the App for free. To enable Google Analytics and AdMob, we embed a software development kit (“SDK”) provided by Google, which may automatically collect the following information:
● Your device’s IP address, which may be used to estimate the general location of your device;
● Non-user related crash logs, which may be used to diagnose problems, improve the SDK and display ads;
● Performance data such as app launch time, hang rate, or energy usage, which may be used to evaluate your use of the App, understand the effectiveness of existing product features, plan new features and display ads;
● Information about how you use the App, Device ID, such as your device's advertising identifier or other app-bounded device identifiers, which may be used for the purpose of third-party advertising and analytics;
● Advertising data, such as advertisements you have seen and clicked on, which may be used to power analytics and advertising features; and
● Other user interactions like app launch taps, and interaction information, like how much time you spend on the App and how you interact with it, the uniform resource locators (“URLs”) of other websites that you click to and from our App (including the date and time clicked), length of visits to the App, App interaction information and methods used to browse away from the App, all of which may be used to help us improve the App, better understand our users and improve advertising performance.
For more information on how Google uses your information for advertising purposes and how to control information collected by Google, please visit https://policies.google.com/technologies/partner-sites. If you are an Android user, you can also delete your device’s advertising identifier in the ‘Privacy’ settings of your device. If you are an iPhone user, your device will prompt you enable the App to collect and use your device’s advertising identifier.
HOW WE SHARE YOUR PERSONAL INFORMATION
In order to make the App available, we use third-party service providers to assist us in various ways. We use the following service providers:
● Printful, which we share your contact information with in order to fulfill and deliver orders for tangible goods;
● Shopify, which process payments on our behalf for orders for tangible goods;
● The Apple App Store and Google Play, which help us fulfill in-App purchases and application updates;
We also use Amazon Web Services, IAM + Cognito, S3 and Neptune to provide us with hosting solutions, security, storage and data backup. Where we make Personal Information available to third-party service providers, these parties are under contractual obligations to comply with applicable privacy and data protection legislation, to protect your Personal Information, to only use the Personal Information for the purposes in which it was transferred.
We share your Personal Information with other users when you interact with them on the App. If you connect to the App via a third-party platform or social network, we may share some of your Personal Information with your social network friends who also use the App. These individuals will see your name, profile photo, profile and descriptions of your in-App activity.
We may disclose your Personal Information a buyer or a successor in the event of a merger, restructuring, consolidation, change in control, liquidation, reorganization or other sale or transfer of some or all of our assets.
In certain narrow circumstances, the law permits us to disclose your personal information without consent. For instance, we may disclose your personal information to government, regulatory or law enforcement agencies as requested by those entities, if we have a good faith belief that the disclosure is required or permitted by law, or when we believe disclosure is necessary or appropriate to protect the rights, interests, property, or safety of Pop Sandbox, our customers, or others.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We protect your Personal Information with security safeguards appropriate to the sensitivity and the quantity of information such as through the use of administrative, technical, physical and organizational safeguards. We use these security measures designed to help secure your Personal Information against unauthorized use, loss, access, modification, destruction or disclosure while it is in our custody or under our control. Specifically, we Amazon Web Services, which is ISO/IEC 27001:2013, 27017:2015, 27018:2019, 27701:2019, 9001:2015, and CSA STAR CCM v3.0.1 certified.
As part of these safeguards, we require that you create and maintain credentials, such as a username and a password, to get access to the App. It is important that you protect and maintain your account’s security and that you immediately tell us of any unauthorized use of your account. Where you access our App through another account (for example, a social network) please keep that account information secure as well.
While we take precautions against security breaches by protecting Personal Information in our control and custody, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our App.
We take reasonable steps to ensure that the Personal Information in our custody is accurate and up-to-date for the purposes for which the information was collected. While we rely on you to provide us with accurate Personal Information, we will make every reasonable effort to keep your Personal Information accurate and up to date, for the purposes for which the information was collected.
THIRD PARTY SITES AND LINKS
The App contains links to third-party websites and other apps that are not hosted by us. As specified above, you may also connect to our App through one of those third-parties’ websites or apps.
We recommend that you read those third-parties’ terms of service and privacy policy, in order to understand how they collect and use Personal Information.
LOCATION AND RETENTION OF PERSONAL INFORMATION
The Personal Information we collect is stored and processed on servers located in Canada.
We will keep your Personal Information for as long as you maintain an active account with us. If you delete your account, we will securely destroy your Personal Information. However, any section that you create that is included in another user’s completed drawing will not be deleted. Those sections will be removed from the App for future use. We also keep your Personal Information for as long as we may be required to by law.
CHILDREN’S PRIVACY
Our App is not marketed to, or intended for, children under the age of 13.
If you have any questions or concerns about our practices related to privacy and children’s data, please contact us at the information below. If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption applicable privacy law, we will take measures to promptly remove that information from our records.
YOUR RIGHTS
Subject to certain exceptions, at any time, you have the right to:
● Request a copy of your Personal Information, including, information on the types of Personal Information we hold about you, what it is being used for, and with whom it has been shared. You may also request access to your Personal Information that is in our possession.
● Correct or update any inaccurate, outdated or incomplete Personal Information. When appropriate, the amended information will be transmitted to any third-parties having access to the Personal Information in question;
● Opt-out of marketing communications we send you by following the unsubscribe link contained in the message; and
● Withdraw your consent to our processing of your Personal Information. Please note that if you withdraw your consent, you may not be able to access all of the App’s features and functionality.
If you wish to exercise any of these rights, please contact us at the information below. If we cannot accommodate a request, we will provide you with a justification.
CONTACT US
If you have any questions about our privacy practices or would like to exercise any of your rights regarding your Personal Information, please contact our Privacy Officer at:
info@popsandbox.com
We may make changes to this Privacy Notice to reflect our current privacy practices with respect to Personal Information. If we change the way we handle your Personal Information, we will update this Privacy Notice and notify you or seek your consent, as and when appropriate.