Last Updated: 28.08.2025
This privacy policy (the "Privacy Policy") describes the collection and processing of information about you that can directly or indirectly identify you (the "Personal Data") carried out by "AR Drawing: Sketch & Paint" app (the "App"), which is available on Google Play, App Store platforms (the "Platform").
When you use the App developed by us and/or by our partner developers, we can collect your Personal Data.
This Privacy Policy provides (1) the App users; and (2) other subjects with information on which Personal Data we collect and how we process such Personal Data. Unless expressly provided otherwise, all of the following terms apply to all of the above categories of data subjects.
The controller of your Personal Data who determines purposes and means of the processing is Digital Solutions Technologies Limited, incorporated under the laws of Hong Kong and having its registered address at Unit 1603, The L. Plaza, 367 - 375 Queen's Road Central, Sheung Wan, Hong Kong ("we", "us", "our").
If you have any questions about the information set out in the Privacy Policy or wish to exercise any of the rights to process personal data set out below, you can contact our data protection officer by email. The contact details of our data protection officer are app@ar-drawing.com.
IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE OUR APP OR OUR WEBSITE.
We collect Personal Data in the following ways:
We respect your privacy and aim to limit the Personal Data that we collect from you to the amount, which is strictly necessary to fulfill the purposes of processing. Categories of Personal Data that we process are specified below.
Your Personal Data in the App is used as follows:
To help us improve our App, enhance existing features, and add new ones you'll enjoy, we collect some basic Personal Data about how you use the App. Please note, we don't store this data ourselves, and we never sell it or use it for anything else.
Instead, this data is automatically sent to trusted analytics platforms (listed in our Privacy Policy below). These platforms process the data and share reports with us that are either anonymous or only use limited, non-identifiable information. This helps us understand how the App is used and how we can make it better for you.
| List of Personal Data |
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|---|---|
| Legal basis for Personal Data processing | Legitimate interest:
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From time to time, we may offer you paid features in the App. In order to receive payments, confirm payment status, provide you with paid features on the App, and ensure that you can receive a refund for in-app purchases, we require certain Personal Data that we receive from the Platform through which you download our App.
PLEASE NOTE THAT WE DO NOT PROCESS YOUR BANK, DEBIT, OR CREDIT CARD DETAILS, ACCOUNT DETAILS, OR OTHER PAYMENT DETAILS OTHER THAN THOSE PROVIDED TO US BY THE PLATFORM THROUGH WHICH YOU DOWNLOAD THE APP.
| List of Personal Data |
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|---|---|
| Legal basis for Personal Data processing | For contract performance. |
You may contact us by email indicated on our website, as well as this Privacy policy, with a question/request/complaint, etc. In such cases, we will have to process Personal Data you provide to give you the appropriate feedback on your inquiry.
| List of Personal Data | Users of our App: Email, full name and surname. |
|---|---|
| Legal basis for Personal Data processing | The legitimate interest based on the balance of interests:
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We exclusively collect your Personal Data without retaining it. All Personal Data is exclusively stored on your devices as long as you're using our App. Our third-party collaborators adhere to a data retention policy, ensuring the removal of your personal data accordingly. We process your Personal Data for as long as necessary to fulfill the purpose of the processing.
At the same time, in certain circumstances, we may be required to retain your Personal Data for some period of time to comply with applicable law or regulatory requirements. This may include, but is not limited to, situations involving litigation, investigations, or governmental requests. We will retain your Personal Data only for as long as necessary to comply with these legal obligations and will take appropriate measures to ensure its security and confidentiality during this period.
We neither use automated decision-making nor refer to automated profiling.
In some cases, we need to provide your Personal Data to third parties. We share your Personal Data only if it meets the following objectives:
We may disclose your Personal Data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies), in connection with any legal proceedings or prospective legal proceedings and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
In order to fulfill the purposes specified in the section "Which Personal Data do we process and how?", we transfer your Personal Data to service providers and their sub-service providers. We strive to limit the use of your Personal Data by these third-party providers and prohibit them from processing your Personal Data for purposes not set out in this Privacy Policy. In addition, we require third-party providers to securely store your Personal Data and keep it confidential.
We may engage third-party service providers as follows:
To make our App better and improve your experience, we use trusted analytics tools that collect and analyze data for us. These tools help us understand how people use the App and how it's performing. The data they collect is aggregated and anonymized, so your privacy stays protected.
We work with the following third-party analytics platforms for this purpose:
We may also use third-party service providers for other purposes as follows:
We may, from time to time, engage other third-party service providers. The list of such contractors is subject to change, but each time before we transfer your personal data to new contractors, we:
In addition, we verify that there is a lawful basis for cross-border data transfers (if applicable). Details of the use of these organizations will be promptly included in this Privacy Policy.
In some cases, your Personal Data regarding your use of App may be processed by third parties who act as an independent controller when you make in-app purchases payments.
When you make payments related to the App, you submit your payment details to the relevant platform (Google Play, App Store, etc.) that processes your payments. We only receive a limited amount of information that is listed in the section "Which Personal Data do we process and how?". We do not receive any Personal Data about you or your bank details. Please, refer to the privacy policy of the relevant platform to check how it processes your payment data:
| Right of access | You have the right to access the Personal Data we have about you, along with related details. What happens when you make a request? We'll give you a copy of your Personal Data. If you ask for more than one copy, we may charge a reasonable fee. If you send your request electronically, we'll usually send the data in a common digital format, unless you prefer something else. If we can't fulfill your request for any reason, we'll explain why and let you know how you can appeal the decision. |
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| Right to rectification | You have the right to request the correction of incomplete or inaccurate Personal Data. What will we do to realize your right? Once we receive and verify your request, we will promptly correct or complete your Personal Data. |
| Right to erasure | You can request the deletion or removal of your Personal Data in certain circumstances. What will we do to realize your right? Once we receive and verify your request, we will delete your Personal Data, unless there are legal grounds for retaining it. |
| Right to restrict processing | You can request the restriction of processing your Personal Data under specific conditions, such as when its accuracy is contested, when the processing is unlawful, when we no longer need the data, or when you have objected to the processing. What will we do to realize your right? We will not process your Personal Data (with the exception of storage) other than on the basis of consent or to assert, exercise, or contest legal claims and actions or to protect the rights of another person or entity, or for reasons of important public interest. |
| Right to data portability | This right applies to information processed based on your consent or a contract. You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format, and, if technically feasible, transmit it to another data controller. What will we do to realize your right? We will transmit the Personal Data relating to you and given to us in a structured, ubiquitous, and machine-readable format. |
| Right to object | If we rely on legitimate interests for processing your Personal Data, you have the right to object to such processing based on your specific situation. What will we do to realize your right? We will not process your Personal Data until we have demonstrated that there are compelling legitimate grounds for processing that override the interests, rights, and freedoms of the data subject, or for asserting, exercising, or contesting legal claims and causes of action. |
| Right to withdraw consent | If you provided explicit consent for the processing of your Personal Data, you have the right to withdraw your consent at any time. What will we do to realize your right? If we have no other legal basis for processing your Personal Data, we will cease processing it upon receiving your withdrawal request. |
| Right to lodge a complaint | If you believe that our processing of your Personal Data violates applicable legislation, you have the right to lodge a complaint with a supervisory authority. |
You may exercise these rights by means of an email sent to our email address. We will address your request as early as possible and no longer than within one month. Please note that this period may be extended by two further months where necessary, taking into account the complexity and number of the requests. In this case, we will inform you of the extension within one month of receipt of your request and will explain to you the reasons for the delay.
Use of our App is limited to users aged 16 years and above. We do not knowingly collect or solicit Personal Data about or direct or target personalized advertisements to anyone under the age of 16, or knowingly allow such persons to use our App. If you are accepting this Privacy Policy and using the App, you warrant you are 16 or more years old. If you are under the age of 16, please do not send any Personal Data to us. If we learn that we have collected Personal Data about a child under age 16, we will delete that Personal Data as quickly as possible. If you believe that we might have any Personal Data from or about a child under the age of 16, please contact us.
The App and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use our App or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and the practices described in it.
If you have any questions about our Privacy Policy or information practices, or we haven't done a good enough job explaining any of the Privacy Policy, please feel free to contact us at our designated request address: app@ar-drawing.com.