The Moondrop Entertainment, LLC privacy policy (“Privacy Policy” or “Policy”) was last modified on Oct 5, 2018, and was first published and effective November 16, 2012. In this Policy, Moondrop Entertainment, LLC will be referred to as “Moondrop”, “our”, “us” or“we.”

As used in this Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within Moondrop Entertainment LLC or Moondrop’s affiliates.

We are providing this Policy to inform you of our policies and procedures regarding the collection, use and disclosure of information on our Service. The term Services as used herein refers to the Moondrop mobile and web applications and the Moondrop websites www.drawpforschool.com and www.drawp.it.

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If we make material changes to how we use Personal Information collected from children under age 13, we will notify parents by email in order to obtain verifiable parental consent for the new uses of the child's Personal Information.

How Moondrop collects information

We collect information that you voluntarily provide to become a registered User of our Service, and when you or your child use certain aspects of our Service (e.g., entering an email address or a phone number on a form to send an SMS or email from yours or your child’s Moondrop account).

When you browse or use our Service, technological tools including "Log Data" and "Cookies" collect certain information, as explained in the following section.

Information Moondrop collects and how it is used

When you register with us through the Service to become a registered User of Moondrop, we will ask you for certain information about you that can be used to contact or identify you (“Personal Information”). Personal Information may include, but is not limited to, your name or parent’s name, child’s name, gender, profile photo, free-form biography, location/hometown, website and email address or parent’s email address.

We use your Personal Information (in some cases, in conjunction with your “Non-Identifying Information,” see below) to provide the Service to you. For example, we create your User account for your use of the Service based upon the Personal Information you provide.

If you are over 13, we may use your Personal Information to contact you with information and updates about Drawp. We use your Personal Information to respond to your questions and/or inquiries. If you no longer wish to receive these types of communications, you may opt-out at any time by following the link located at the bottom of each communication or by emailing us at support@moondropapps.com .

As part of the Service, Moondrop Users may communicate with other registered and nonregistered Users through use of Moondrop applications, e-mail, SMS, and Moondrop’s website. Please be aware that any personal information you choose to submit within these areas of the application may be used to send you unsolicited messages. If you do not wish to allow others to obtain personal information about you then you should not submit such information within these areas of the application.

When Users have selected the option to add a friend and provide us with that friend's email address and/or phone number, Moondrop retains that information to send Users’ creations to those email addresses and phone numbers on the Users’ behalf. These messages may contain an invitation to download Drawp, and will only be sent when Users indicate that they want to share creations. Users may choose to include drawings, voice recordings, and photos in their creations. Moondrop informs Friends when their information has been added by Users. Friends have the option to delete their information at any time, by contacting us at: support@moondropapps.com .

We also collect other information that you provide as part of registration and operation of Moondrop mobile applications and website that cannot reasonably be used to identify or contact you (e.g., without limitation, age and individual preferences) (“Non-Identifying Information”).

We do not ask you for, access, or track any location based information from your mobile device at any time while downloading or using our mobile application or services.

When you download and use our services, we automatically collect information on the type of device you use and operating system version. We use this information so that we are able to provide you with the correct version of the application and so that we may track how many users are on each operating system.

Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be personally identified or contacted. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information (for example, your viewing preferences)

We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Moondrop Users to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Service is used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.

Our Mobile Software allows Users to access and use the Service from mobile devices. We will receive information about your mobile device model, software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Mobile Software.

When you visit the Service, our servers automatically record information that you inputted (“Log Data”). This Log Data may include information such as the time spent on using the Service, information you posted on our Service, items sent to others, your preferences, access times and dates, and other statistics. We use this information to monitor and analyze use of the Service and the Service’s technical administration, to increase our Service’s functionality and userfriendliness, and to better tailor our Service to our Users’ needs.

Like many online services, Moondrop and our partners use technologies such as cookies, beacons, tags and scripts on our Service to collect information. These technologies are used in saving login information for future logins to the Service, enable certain features of the Service, better understand how you interact with the Service, monitor aggregate usage by Moondrop Users. They may also be used to analyze trends, and track users' movements around the site to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

The use of cookies by third parties is not covered by our privacy policy. We do not have access or control over these cookies.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile app.

Secure Storage

Moondrop's cloud storage Service is provided through AWS, DigitalOcean and Heroku, three of the world's largest cloud storage providers which utilize the highest level of security measures available to protect all data and materials stored in the users' accounts. More information about their security policies can be found here:
https://aws.amazon.com/privacy/
https://www.digitalocean.com/legal/privacy/
https://www.heroku.com/policy/security

We do not link the information we store in cookies to any other personal information other than your login information. We use Local Storage Objects (LSOs) such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

Moondrop's sharing of your information

We do not sell your personal information to third parties. Parent's are able to consent to our use of their child's personal information without having to also consent to our disclosure of their child's personal information to third parties as we do not share this type of information with third parties.

When you register through the Service and submit Personal Information to create a profile, other Moondrop Users may see your first and last name, as you entered them when signing up. If you choose to provide additional Personal Information in your profile, Moondrop Users may see such additional Personal Information, including, but not limited to, your photo and email address.

We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service related services (e.g., maintenance services, database management, for video management, customer support, web analytics and improvement of the Service's features) or to assist us in analyzing how our Service is used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We can disclose any information about you as required by law, to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process including, but not limited to, subpoenas, to protect the property and rights of Moondrop or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or prominent notice on our Web site or our mobile application of any change in ownership or uses of yours or your child's personal information, as well as any choices you may have regarding your personal information.

---

Partner	Information collected by or shared with partner	Purpose	Link to privacy policy
Google Analytics	Google Apps collects anonymous and strictly non-identifiable personal information from the website.	We use the service to monitor how adults are using the site. We do not use Google Analytics in the apps.	Partners Terms
Website Tools/Google Inc/google.com	The Google translate widget collects the following anonymous information: device information, log information, location information, local storage, cookies and anonymous identifiers.	The website tool we use is Google Translate. It is a widget that allows users to translate the page into different languages. We use this only in the website, not the app.	Privacy Policy
MixPanel	MixPanel collects anonymous aggregate data about actions taken inside the app.	We use this service to assess how users are navigating the app in aggregate and to improve the performance of the app.	Privacy Policy
fonts.googleapis.com	Google may collect anonymous information about the uses for their fonts (what language, the location, cookies and anonymous identifiers). We only use Google fonts on our website used by adults, and not on our apps used by adults and children.	We use the Google fonts api to add fonts to our webpage.	Privacy Policy
Google+ Widget	uses the Google+ API to retrieve your public posts, full name and profile picture. Google+ widget neither stores any of your information nor shares aggregate statistics about your Google+ activity with publishers, app developers, or connected sites.	Allow adult users of the site to post messages about drawp in their Google+ pages	Privacy Policy
Twitter widget	Twitter collects browser-related information that helps the buttons and widgets work properly and improves the Twitter experience. This information includes the web page visited and a cookie that identifies the user's browser. To protect our users' privacy, after a maximum of 10 days, Twitter starts the process of deleting or removing account identifiers from the page-visit data used to personalize Twitter content.	Allow adult users of the site to tweet about drawp on their Twitter accounts	Privacy Policy
UserVoice	UserVoice collects information about users from two sources: (i) information users affirmatively give to us; and (ii) information automatically collected when users visit any of the UserVoice Websites or use any UserVoice Services. For example, UserVoice may log information from users' computers and browsers, such as IP addresses, profile information, aggregate user data, browser type, software and hardware attributes, pages you request, and cookie information.	Allow adult users to start tickets on issues found in the app or website.	Privacy Policy
New Relic	New Relic collects information on server performance to monitor the backend health of the app.	New relic collects anonymous application data about performance. They only collect personal data about the app owner (Moondrop Entertainment).	Privacy Policy

---

Choices regarding information

If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided below.

Links to other sites and services

Our Service may contain links to other third-party websites and online services. If you choose to visit another website or online service by clicking on a link, you will be directed to that third party's website or online service. The fact that we may link to a website or online service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices.

We are not responsible for the privacy practices of such other services. We do not exercise control over third party websites and online services, and these third parties may place their own cookies or other files on your computer and collect data or solicit Personal Information and Non-Identifying Information from you. Other sites and online services follow different rules regarding the collection, use and/or disclosure of Personal Information and Non-Identifying Information.

This privacy policy applies to information collected by our site or our mobile application only.

External Storage

Users can access Dropbox, Google Drive, and OneDrive to store content created with Drawp, or import compatible content into Drawp. The services authenticate the users directly, and an authentication token identifying the user is stored in the local browser session profile. This information is automatically discarded once the user closes the current browser session.

Blog

If you wish to comment on our Drawp for Families Drawp.it blog you must be logged into your Facebook account, we are not responsible for any personal information you choose to post in these areas of the site. If you wish to request removal of any personal information you submit in the blog area you must contact Facebook directly to do so.

Social Media (Features) and Widgets

Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Single Sign-On

You can log into our website and mobile application using sign-in services such as Microsoft Single Sign-On, Google Sign In, Facebook Connect or an OpenID provider. These services will authenticate your identity, provide you the option to share certain personal information (such as your name and email address) with us, and to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this website or mobile application to your profile page to share with others within your network.

Access to Personal Information

If yours or your child's personal information changes, or if you no longer desire our service, and you wish to update or delete yours or your child's personal information collected from your child or refuse further collection and use of information collected from your child you may contact us at support@moondropapps.com or login to your account and make the updates. We will respond to your access request within a reasonable timeframe.

We will retain yours and your child's information as long as the accounts are active or as needed to provide services. If you wish to cancel either account or request that we no longer use the information to provide services, contact us at support@moondropapps.com . We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How Moondrop stores and protects information

We use commercially reasonable safeguards to preserve the integrity and security of information collected and maintained through the Service. However, we cannot ensure or warrant the security of any information you provide to us or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed by unauthorized persons. We do not request your credit card information, login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.

We will make any legally required disclosures of any breach of security, confidentiality, or integrity of store "personal data", to you insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Privacy Notice to our users in the European Union (“EU”), the European Economic Area (“EEA”) and Switzerland

We participate in the Privacy Shield Framework and we are listed in the Privacy Shield List https://www.privacyshield.gov/list .
We are committed to subject to the Principles for all personal data received from the European Union (the “EU”), the European Economic Area (the “EEA”) and Switzerland in reliance on the Privacy Shield.

In compliance with the Privacy Shield Principles, Moondrop Entertainment, LLC is committed to resolve complaints about your privacy and our collection or use of Personal Data about you. Persons from the European Union (the “EU”), the European Economic Area (the “EEA”) and Switzerland who have inquiries or complaints regarding this Privacy Policy should first contact us via email at: support@moondropapps.com .
Moondrop Entertainment, LLC has further committed to refer unresolved Privacy Shield complaints to JAMS (Judicial Arbitration and Mediation Services, Inc), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction you can invoke binding arbitration. Please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS (Judicial Arbitration and Mediation Services, Inc) are provided at no cost to you.
A violation of our commitment to Privacy Shield is subject to the investigatory and enforcement powers by the Federal Trade Commission.

When we act as a personal data controller or personal data processor respectively, we process personal data where we need to perform the contract we are about to enter into or have entered into with you, where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests, where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it. Where our legal basis is consent, you have the right to withdraw consent any time by contacting us at support@moondropapps.com .

In the context of an onward transfer to third parties of personal data of EU, EEA or Swiss individuals received pursuant to the Privacy Shield, Moondrop Entertainment LLC is liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

Privacy Notice to our users in the European Union EU, and European Economic Area EEA and Switzerland regarding access, control, and correction of your personal information

We support and respect your right to access, correct, request deletion or request restriction of our usage of your personal information as required by applicable law. We also take steps to ensure that the personal information we collect is accurate and up to date.

You have the right to know what personal information we maintain about you. We will provide you with a copy of your personal information in a structured, commonly used and machine readable format on request.

If your personal information is incorrect or incomplete, you have the right to ask us to update it.

You have the right to object to our processing of your personal information.

You can also ask us to delete or restrict how we use your personal information, but this right is determined by applicable law and may impact your access to some of our Services.

You can exercise any of the above rights where applicable by contacting us at support@moondropapps.com . For all inquiries or complaints you can contact support@moondropapps.com .

Contact Moondrop

If you have any questions about this Policy or any of the practices described herein, please call us at (305) 213-6298 or send us an email at support@moondropapps.com .

Moondrop Entertainment, LLC
156 2nd Street
Suite 419
San Francisco, CA 94105

---