Privacy Statement for SimpleDraw

Last updated: August 19, 2025

SimpleDraw is an offline iOS application. The app’s core features work without an internet connection and we do not collect or store personal data on our servers. The app displays Google AdMob banner ads, which may process data independently. This policy is designed to be concise and aligned with global privacy principles (e.g., GDPR/UK GDPR, CCPA/CPRA, LGPD, PIPEDA).

1) Who we are

• Controller/Owner: SimpleDraw
• Privacy Contact: info@teamslah.com

2) What we do (and don’t do)

• Offline by design: Core features operate fully offline.
• No accounts: We do not require sign-up or login.
• No server storage: We do not operate backend servers for this app; we do not store personal data outside the device.
• No tracking by us: We do not collect analytics, precise location, contacts, photos, or other personal data, unless explicitly requested by a feature and permission is granted in iOS.
• Advertising: The only third-party data processing occurs through Google AdMob banner ads.

3) Data processed through AdMob (Google as an independent controller)

• AdMob may process device and ad-related data such as:
  • Advertising identifiers
  • IP address, coarse location, device information, and interaction with ads
  • Signals used for ad delivery, frequency capping, fraud prevention, and measurement
• Please review Google’s privacy documentation for details on how AdMob uses data and applicable user controls.

4) Legal bases (where required)

• Performance of contract: Provide core offline functionality.
• Legitimate interests: Security, fraud prevention, and showing non-personalized ads where permitted.
• Consent: Required in certain regions for personalized advertising and accessing identifiers.
• Legal obligations: Compliance with applicable laws.

5) Children’s privacy

• We do not knowingly enable personalized ads for children. Where the app is child-directed or likely to be used by children, AdMob is configured to serve age-appropriate non-personalized ads and to apply under-age-of-consent settings as required.
• Parents or guardians may contact us to request deletion of any information inadvertently collected via third parties.

6) Sharing and international transfers

• We do not sell personal information.
• We share data only through essential third parties necessary to provide ads (Google AdMob) and platform services (Apple OS-level services).
• AdMob may process data globally subject to its own safeguards and transfer mechanisms.

7) Your rights and choices

Rights will depend on local law and may include:

• Access, correction, deletion, restriction/objection, portability, and withdrawal of consent (for data we control).
• To make a request about data we control directly, email info@teamslah.com. For AdMob-specific data, use Google and Apple controls.

8) California privacy disclosure (CCPA/CPRA)

• Categories processed by AdMob may include identifiers (e.g., device IDs), internet/network activity, coarse location, and inferences.
• Purpose: ad delivery, measurement, fraud prevention, and security.
• Sale/Sharing: We do not sell personal information. Ad-related practices by AdMob may be considered “sharing” for cross-context behavioral advertising under CPRA. Where required, we provide a “Do Not Sell or Share My Personal Information” control or honor supported browser/app-level signals.

9) Data retention

• We do not maintain user-level data on our servers.
• AdMob’s retention periods are determined by Google’s policies and applicable law.

10) Security

• We follow reasonable technical and organizational measures aligned with the minimal data we handle directly.
• No method is 100% secure; we regularly review safeguards.

11) Third-party links and SDKs

• Ads may link to third-party content and are governed by those parties’ privacy policies.
• We integrate only essential third-party services required to provide ads.

12) International users

• AdMob and platform providers may process data in multiple countries. Where legally required, appropriate safeguards apply.

13) Changes to this policy

• We may update this policy from time to time. Material changes will be indicated via the “Last updated” date and, where required, in-app notice or renewed consent.