Privacy Policy

1Introduction

Welcome to Draw & Learn (“App,” “Application,” “Service”). This Privacy Policy explains how information is collected, used, disclosed, stored, and protected when you access or use the App.

Draw & Learn is an educational drawing application designed primarily for children and families. We recognize the importance of protecting privacy, particularly the privacy of children, and are committed to handling information responsibly and transparently.

By downloading, installing, accessing, or using the App, you acknowledge that you have read and understood this Privacy Policy. If a user is below the age of digital consent in their jurisdiction, a parent or legal guardian should review this Privacy Policy before permitting use of the App.

2Data Controller

The App is owned and operated by Epsilon Developers, operated by Anurag Mahajan and Satyam Kushwaha.

For privacy inquiries: contact@epsilondevelopers.xyz
Address: 95/2, Padeshipura, Indore – 452003, Madhya Pradesh, India.

3Scope of This Policy

This Privacy Policy applies to the Draw & Learn mobile application (Android and iOS versions), associated support services, and customer support communications. It does not apply to third-party websites, services, applications, or platforms that may be linked from or integrated with the App.

4Information We Collect

The App is designed to minimize data collection and to function primarily through local device storage.

A. Information stored locally on the device

This information generally remains on the device and is not automatically transmitted to Epsilon Developers.

B. Device information

The App and certain third-party services may process technical device information including device model and type, operating system version, screen resolution, app version, language, and country/region settings, and advertising identifiers where permitted by law. This helps maintain functionality, security, and compatibility.

C. Diagnostic information

To improve reliability and performance, limited technical information — such as crash reports, error logs, performance diagnostics, and stability metrics — may be collected by the app platforms (Google Play / Apple) and used solely for maintenance, debugging, security, and service improvement.

D. Purchase information

Premium purchases may be processed through Razorpay, Google Play Billing, or Apple In-App Purchases. We do not collect, store, or process complete payment card information — that is handled directly by the authorized payment processors. We may receive limited transaction-related information necessary to verify purchases and unlock purchased features.

E. Advertising information

The free version of the App may display advertisements through Google AdMob. Advertising providers may process device and advertising identifiers, device information, general usage information, and approximate (country/region) location where permitted, under their own privacy policies.

5Information We Do Not Intentionally Collect

The App does not intentionally request or require children to provide full names, home addresses, email addresses, telephone numbers, school names, government identification numbers, biometric information, precise location, contact lists, photographs of users, or audio recordings of users.

If we become aware that such information has been collected inadvertently, we will take reasonable steps to delete it.

6Children’s Privacy

Protecting children’s privacy is a fundamental priority. The App is designed to comply with applicable child-privacy requirements, including COPPA (US), GDPR & GDPR-K (EU), UK GDPR, the UK Age Appropriate Design Code, India’s Digital Personal Data Protection Act, 2023, Google Play Families policies, and Apple Kids Category requirements.

Parents and guardians may contact us to request access to, correction of, or deletion of information, or to ask privacy-related questions. See our dedicated Children’s Privacy Notice and Parental Consent Policy.

7How Drawing Recognition Works

The App includes a proprietary sketch-recognition system that evaluates drawing similarity and learning progress. This recognition:

• Operates entirely on the device;
• Uses mathematical and geometric matching methods (point-cloud and shape descriptors);
• Generates a confidence score used to award stars; and
• Does not upload drawings for recognition purposes.

Recognition results support educational gameplay and progress evaluation only. For more detail, see our AI & Recognition System Disclosure.

8How We Use Information

• Service operation: providing educational functionality, saving progress, restoring unfinished drawings, and managing rewards and achievements.
• Performance & security: maintaining stability, detecting errors, fixing bugs, improving compatibility, and protecting against misuse.
• Purchases: verifying premium purchases, delivering premium content, and processing transactions.
• Advertising: displaying ads, managing ad frequency, and supporting ad-supported services (free version only).
• Legal compliance: complying with legal obligations, responding to lawful requests, and enforcing agreements.

9Legal Basis for Processing

Where the GDPR, UK GDPR, India’s DPDPA, or similar laws apply, processing is carried out on the basis of user or parental consent, legitimate interests, contractual necessity, and compliance with legal obligations. The specific basis may vary by jurisdiction and the nature of processing.

10Third-Party Services

11Sharing of Information

We do not sell personal information, and we do not knowingly sell children’s information. Information may be shared only with service providers assisting operations, payment processors, and advertising partners; to comply with legal obligations; to protect rights and security; or during a business transfer or restructuring where legally permitted. All sharing is conducted in accordance with applicable laws.

12Data Retention

Locally stored information remains on the device until deleted by the user, deleted by a parent or guardian, cleared via the App or device settings, or removed by uninstalling the App. Technical and operational information is retained only as long as reasonably necessary for legitimate business, legal, security, or compliance purposes.

13Data Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect information from unauthorized access, disclosure, misuse, alteration, and loss. App data is stored within the App’s private device sandbox. However, no method of electronic storage or transmission can guarantee absolute security.

14International Data Transfers

The App may be distributed globally, and information may be processed in countries different from the user’s country of residence (including by service providers such as Google, Apple, and Razorpay). Where legally required, appropriate safeguards will be implemented for international transfers.

15Your Privacy Rights

Because virtually all Draw & Learn data lives locally on the device, you have direct control.

Requests may be submitted using the contact details below.

16California Privacy Rights

Residents of California may have additional rights, including the right to know, delete, and correct, the right to opt out of certain sharing practices, and the right against discrimination for exercising privacy rights. We do not knowingly sell the personal information of children.

17European Economic Area & United Kingdom Rights

Users in the EEA and UK may have additional rights under the GDPR and UK GDPR relating to access, rectification, erasure, restriction, objection, and portability. Complaints may also be submitted to a competent supervisory authority.

18India Privacy Rights

Users in India may have rights under the Digital Personal Data Protection Act, 2023, including access, correction, erasure, grievance redressal, and withdrawal of consent. We process such requests in accordance with applicable law.

19Data Deletion Requests

Users and parents may request deletion of information by contacting us. Where information is stored solely on the device, deletion can be accomplished by clearing application storage, deleting saved content, or uninstalling the App. See our Data Deletion Policy for details.

20Changes to This Privacy Policy

We may update this Privacy Policy periodically. Updated versions will be posted within the App and/or associated websites and become effective upon publication unless otherwise stated. Please review this Privacy Policy periodically.

21Contact

22Google Play & App Store Compliance

Draw & Learn is designed to comply with applicable platform privacy requirements, including Google Play User Data policies, Google Play Families policies, and Apple App Store privacy requirements. The App minimizes collection of personal information and prioritizes local device storage wherever reasonably possible. Where third-party services are used, they remain subject to their own terms and privacy practices.