VanDraw
Welcome!
VanDraw (the "App", "Website") is owned and operated by VanDraw Limited, a Hong Kong incorporated entity with its registered office at Unit 907, 9/F., Silvercord Tower 2, 30 Canton Road, Tsim Sha Tsui, Hong Kong(referred to throughout as "we", "us", or "our").
This document outlines our approach to collecting, utilizing, and safeguarding information that may identify you personally, along with the options available to you regarding our data handling practices.
We encourage you to read this Privacy Policy thoroughly before engaging with our Services or submitting any personal data. By accessing or using our Services, you acknowledge and accept the practices described herein. If you find any part of this policy unacceptable, please refrain from using our App or Website.
YOUR CONTINUED USE OF OUR SERVICES CONSTITUTES ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DISAGREE WITH ANY PORTION, PLEASE DISCONTINUE USE IMMEDIATELY.
Why we retain information
You might wonder: if we're committed to protecting privacy, why do we need to store any data at all?
In certain instances, data storage is essential for delivering our Services. For example, processing your purchase information is necessary to provide you with the premium features you've selected.
Another vital reason is continuous improvement. To enhance our App and Website for all users, we need to understand how people interact with our offerings. We achieve this through careful analysis of usage patterns, always with privacy preservation as a core consideration.
How we gather your information
We obtain Personal Data through three primary channels:
- Direct provision – when you reach out to us for assistance or submit an inquiry.
- Automatic collection – via analytics tools that track your interactions with our App and Website.
- Third-party sources – such as Google Play or the App Store, which share limited data when you download our App or complete purchases.
What information we hold and why
We are committed to data minimization, collecting only the information strictly required for specific purposes. The categories of data we process are detailed below.
1. Analytics and service enhancement
To refine our App and Website, improve functionality, and develop features you'll appreciate, we gather fundamental usage data. We do not retain this information ourselves, nor do we commercialize it. Instead, it is transmitted to trusted analytics partners (listed in section 5) who provide us with anonymized or aggregated reports that help us understand user behavior and optimize the experience.
| Types of data collected |
|
|---|---|
| Legal justification |
Legitimate business interest:
|
2. Premium features and payment processing
When you purchase premium features, we require certain information to process your transaction, confirm your entitlement, and handle any refund requests. All payment processing is handled by the relevant Platform (Google Play or App Store) — we never see or store your full payment card details.
WE DO NOT COLLECT, PROCESS, OR STORE SENSITIVE FINANCIAL DATA SUCH AS BANK ACCOUNT NUMBERS, CREDIT CARD DETAILS, OR SIMILAR INFORMATION. ALL PAYMENT TRANSACTIONS ARE HANDLED SECURELY BY THE PLATFORM THROUGH WHICH YOU DOWNLOAD THE APP.
| Types of data collected |
|
|---|---|
| Legal justification | Contractual necessity – this data is essential to fulfill our obligations to you. |
3. Customer support and communications
When you contact us via email with questions, concerns, complaints, or refund requests, we use the information you provide to respond appropriately and resolve your issue.
| Types of data collected | Contact details: Email address, full name, and any additional information you choose to share. |
|---|---|
| Legal justification |
Legitimate interest with balanced consideration:
|
How long we keep your data
We generally do not store your personal data on our own servers. Most information remains on your device while you use our App or Website. Our third-party partners have their own retention policies, and we require them to handle your data responsibly.
In certain circumstances, such as legal proceedings, investigations, or government requests, we may be required to retain data for longer periods. Any such retention will be limited to what is strictly necessary for compliance and conducted with appropriate security measures.
Who has access to your information
We share your Personal Data only when necessary and for legitimate purposes:
Legal compliance
We may disclose information when required by law, including to government agencies and law enforcement, or in connection with legal proceedings to protect our rights or defend against claims.
Partner arrangements
We engage third-party service providers to assist with our operations. These partners are contractually bound to use your data only for the specific purposes outlined in this policy and to maintain strict security standards. We have Data Processing Agreements (DPAs) with all our processors. For transfers outside the EEA, we rely on EU Standard Contractual Clauses (SCC) to ensure adequate protection.
Analytics partners
- Google Firebase – Privacy policy
- Cloudflare CDN – Privacy policy
- Adapty – Privacy policy
We may onboard additional partners over time. Before any new engagement, we conduct a thorough assessment of their data protection standards, execute appropriate legal agreements, and ensure lawful cross-border data transfer mechanisms are in place. Updates will be reflected in this policy.
Independent payment processors
When you make in-app or website purchases, your payment details are handled directly by the Platform (Google Play, App Store) or Stripe. These entities act as independent data controllers for your payment information. We receive only transaction confirmation and account identifiers. Review their privacy policies for details:
- Google – Privacy policy
- Apple – Privacy policy
- Stripe – Privacy policy
Do we use automated decision-making?
No. We do not employ automated decision-making or profiling techniques in our processing activities.
Your rights regarding personal data
We believe you should maintain control over your personal information. Accordingly, we provide the following rights, which you can exercise by contacting us at legal@vandraw.com.
Access. You have the right to understand what personal data we hold about you and how we use it. This Privacy Policy serves as our disclosure of these practices. You may also request a copy of your information.
Correction. If your personal information is inaccurate, you may request that we correct it.
Portability. You may request an export of your personal data in a structured, commonly used, and machine-readable format (e.g., .csv or .pdf). Where feasible, we can transmit this directly to a third party you designate.
Deletion. Subject to certain legal exceptions, you may request deletion of your personal data.
Restriction. You may ask us to limit the use of your personal data in specific circumstances. Please note that we may not always be able to comply if such processing is essential for service delivery or product functionality.
Non-discrimination. We will not treat you differently or retaliate against you for exercising any of these rights.
When we receive a request, we may ask for additional information to verify your identity or clarify your preferences. We aim to respond to verifiable requests promptly. If we anticipate any delay, we will notify you via the email address associated with your account or your request.
We do not charge a fee for processing verifiable requests unless they are excessive, repetitive, or manifestly unfounded. In such cases, we will explain our reasoning and provide a cost estimate before proceeding.
These rights are not absolute, and exceptions may apply. Factors such as legal obligations, the rights of others, safety considerations, and our ability to bring or defend legal claims may limit our ability to fulfill certain requests. We will not honor requests that cannot be adequately verified or that lack proper authorization.
Residents of certain jurisdictions may have additional rights under applicable laws. If you are an EU resident, you also have the right to lodge a complaint with your local data protection authority.
Children's use of our services
Our App and Website are not directed at children under the age of 13. For EU residents, the minimum age is 16. We do not knowingly collect data from anyone below the applicable age threshold. If you become aware that a child has provided us with personal information, please contact us immediately so we can investigate and take appropriate action.
Updates to this Privacy Policy
We may revise this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make updates, we will post the revised version on this page with a new effective date. Your continued use of our Services after such changes constitutes acceptance of the updated policy.
The version number and date will be updated with each revision.
Contact us
Should you have any questions about this Privacy Policy, our data practices, or wish to exercise any of your rights, please contact us:
Email: legal@vandraw.com