At Doodle Buddy Labs our mission is to make digital art fun. In pursuit of our mission, we collect and use some information from our users. Being transparent about our use of user information and respecting their privacy is incredibly important to Doodle Buddy Labs, LLC (“we,” “us” or “our”).

This Privacy Policy applies when you use our software products, content, and websites (e.g., www.doodlebuddy.co) (collectively, “Services”). It describes the ways we use your information and your rights and choices concerning your information. For purposes of data protection laws, we are the “data controller” of your personal information. If you do not want us to collect, store, use, or share your information in the ways described in this Privacy Policy, you may choose not to use the Services.  

Doodle Buddy Labs, LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Doodle Buddy Labs, LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  Doodle Buddy Labs, LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit:                                                                                                      


INFORMATION COLLECTION AND USE

When you request information from us through our website, you may provide personal data about yourself that may include your name, email address, phone number, and other information that can directly identify you individually (collectively, “Personal Information”). We also collect Personal Information if you provide it to us as part of our customer support services.

For our Doodle Buddy mobile applications, we don’t collect Personal Information because there is no registration process, and we don’t otherwise collect any other Personal Information from the application.  However, Google and Appodeal, which provide some advertising and analytics services to us, may collect Apple’s unique device identifier (called “IDFA”) associated with your device. If you don’t want your IDFA to be collected for advertising, you may either 1) purchase Doodle Lab, available in the App Store, which explicitly does not collect IDFA for targeted advertising, or 2) on your iOS device “Settings” app, turn on iOS’s “Ask App Not To Track” feature for Doodle Buddy Labs products.  With Ask App Not To Track on, you will still see the same number of ads, but those ads will not be aligned with your interests. You can find more details about how our advertising and analytics partners use and collect data at:


On our websites and in our mobile applications, we and our business and advertising service providers use cookies and other similar technologies (e.g., beacons, pixel tags, clear gifs, and device identifiers) to recognize you and/or your device(s). We and our service providers use these technologies to collect and analyze certain kinds of technical information, which can include the following (and together with the IDFA, the “Anonymous Data”):

IP address;
the type of computer or mobile device you are using;
platform type (like Apple iOS or Android);
your operating system version;
your mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID);
application performance and debugging information;
your browser type and language;
referring and exit pages, and URLs;
the number of clicks on an app feature or web page;
the amount of time spent on an app feature or web page;
domain names;
landing pages;
pages viewed and the order of those pages.

We may also collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly, for example, to serve you advertising more tailored to your interests.


INFORMATION SHARING

We will share your Personal Information only to our service providers who need to know that information to provide services to us, and then only under written agreements not allowing any further use of that Personal Information and only for the purposes for which you’ve provided it.  

For Anonymous Information, we share that with third-party companies who perform services on our behalf, like analytics, analysis, hosting services, customer service, marketing, and advertising optimization. We will also share that information with our third-party business partners who assist us in delivering and optimizing our Services, such as our platform partners (Apple, Google, etc.), and may share it for other purposes related to our business. You can find more details about how our advertising and analytics partners use and collect data at:

We do not rent, sell or share any Personal Information for any other purpose except as expressly agreed upon by you and in the following circumstances:

As necessary, to identify, investigate, prevent or take action regarding illegal activities or suspected fraud or other abuse of the Services;
To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation, as permitted by law, or otherwise as required by law; and in the event that we go through a business transaction, such as a merger, an acquisition by another company, or a sale of all or a portion of our assets, your information may be one of the transferred assets.

By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information, including personal information, in and to the U.S. and other countries and territories, which may have different privacy laws from your country of residence.  If we have received your personal information under the Data Privacy Framework and subsequently transfer it to a third party service provider for processing, we will remain responsible if they process your personal information in a manner inconsistent with the Data Privacy Framework, unless we prove that we are not responsible for the event giving rise to the damage.


ACCESS

If you would like access to personal information that we have collected in order to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Principles, please contact privacy@doodlebuddy.co.  In order to process any corrections, amendments or deletions of personal information, you will need to provide sufficient identifying information as a security precaution. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or where the rights of persons other than the individual would be violated.


DISPUTE RESOLUTION

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Doodle Buddy Labs commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit the JAMS link below for more information or to file a complaint.  The services of JAMS are provided at no cost to you.




Doodle Buddy Labs is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).  An individual may, under certain conditions, invoke binding arbitration. Please see the EU-U.S. DPF website for more information on conditions giving rise to binding arbitration.


OPTIONS FOR LIMITING DISCLOSURE

We offer you a number of options and choices for limiting the use and disclosure of your personal data with regards to the data we collect:

Limit Ad Tracking. If you don’t want your IDFA (described above) to be collected for advertising, then on your iOS device “Settings,” you can turn on iOS’s “Limit Ad Tracking” feature. You will still see the same number of ads, but those ads will not be aligned with your interests.  

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Removing or rejecting browser cookies does not necessarily affect third party flash cookies used in connection with our services.  Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Doodle Buddy website.

Promotional Communications. You may opt out of receiving promotional emails or messages from Doodle Buddy Labs by following the instructions in those emails or messages. If you opt out, we may still send you non-promotional communications, such as those about our ongoing business relationship.


CHILDREN

To enable children to enjoy our drawing application, we’ve created Doodle Lab, available in the App Store, which adds more educational backgrounds and stamps, takes out some content not appropriate for children and removes banner advertising. Doodle Lab does not collect IDFA for advertising. All of our other Services are not intended for children under the age of 13 (or under 16 for children located in the European Union) (collectively, “Children”). We seek to ensure that we do not collect information from children. Except for Doodle Lab, children are not permitted to use these Services, and we do not knowingly collect any personal information from Children. If we learn that we have inadvertently gathered personal information that is not subject to a COPPA exception from a Child, we will take reasonable measures to promptly remove that information from our records.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Doodle Buddy Labs commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF to [INSERT name of alternative dispute resolution provider], an alternative dispute resolution provider based in [INSERT the United States, the European Union, the United Kingdom, and/or Switzerland (as applicable)].  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-data-privacy-framework for more information or to file a complaint.  The services of [INSERT name of alternative dispute resolution provider] are provided at no cost to you.


LINKS TO THIRD PARTY SITES

We may provide links and/or connections to third-party web sites or services from our websites. We are not responsible for the privacy practices or content of these third-party sites.


SECURITY

We take appropriate steps to ensure data privacy and security through various hardware and software methodologies. However, we cannot ensure or warrant against all risks with regards to the security of that information, so information you choose to transmit to us and which we store is provided to us at your own risk and we do not guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our safeguards.


DO NOT TRACK

Currently, we do not respond to “Do Not Track” browser features, but we may do so in the future as industry standards evolve.


CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. If we do, we will post the changes on our website at www.doodlebuddy.co and update the last updated date of this Privacy Policy. Such modifications will become effective on the day they are posted, subject to any alternative requirements of the Data Privacy Framework.

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PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Doodle Buddy Labs, LLC (“Doodle Buddy,” “we,” “us,” or “our”) provides this Privacy Notice pursuant to the California Consumer Privacy Act (“CCPA”) to inform California residents of the categories of personal information we collect and the purposes of collection.

INFORMATION WE COLLECT

“Personal information” under the CCPA is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

Since our “Doodle Buddy” and “Doodle Lab” mobile applications don’t require any user registration, we collect very limited personal information.  Only the following two categories of personal information are collected from our website and mobile applications:

• User Identification Information: Email address and full name, which we may collect if you submit a request to us; and
• Technical Information: such as device identifiers, which are collected not by us but by some of our analytics providers or advertising networks like Google (“Ad Networks”).  We don’t store any of that information.

We don’t actually collect any Technical Information.  The Ad Networks collect it from your device only if you use “Doodle Buddy” for iPhone or iPad.  If you use Doodle Lab, no Technical Information is collected for advertising purposes.

If you don’t want any of your personal information to be collected by Ad Networks for any advertising in our Doodle Buddy applications, then you must stop using Doodle Buddy.  You can use Doodle Lab instead for an additional charge, as authorized under Section 1798.125(a)(2) of the CCPA.

USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you contact us for help, we will use that information to respond to your request.
• To provide you with our products or services and ads within those products.
• To improve our website and apps and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA and our Privacy Policy.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

SHARING PERSONAL INFORMATION

We don’t share your personal information with anyone except as provided in our Privacy Policy.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We disclose your personal information for a business purpose to the following categories of third parties:

• Ad networks

YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.  

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Note that you may only make a verifiable consumer request for access or data portability twice within a 12-month period. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose:
• The categories of personal information that we’ve sold about you and the categories of third parties to whom the personal information was sold.
• The categories of personal information that we disclosed for a business purpose.  

For more information about how to contact us to provide you with information request, email privacy@doodlebuddy.com.

DELETION REQUEST RIGHTS

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

As discussed above, if you want us to delete your data, you have to send us a verified request for us to do so to privacy@doodlebuddy.co.  

Please note that the CCPA includes a number of exceptions that allow us to retain your personal data despite your deletion request, so we may retain your personal data under those exceptions.

VERIFICATION

If you’ve sent us a request through our website, we may be able to verify you via email.  However, if you’re a user of our mobile applications, we may not have sufficient data to verify who you are since we don’t require you to provide us with any registration information, and we don’t actually collect the data ourselves.

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CONTACT US

In compliance with the Data Privacy Framework, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Framework.  European Union and Swiss individuals with Data Privacy Framework inquiries or complaints should first contact us at privacy@doodlebuddy.co.

If you have any questions or concerns about this Privacy Policy, please contact us via email at privacy@doodlebuddy.co, or by mail at the following address:

Doodle Buddy Labs, LLC.
Attn: Legal Department
450 Hayes Street, Suite 4F
San Francisco, CA 94102

Last Updated September 24, 2023