Privacy Policy
ToDraw (“we”, “us”, “our”) operates the ToDraw application and website (the “Service”). This policy explains what we collect and why.
1. Information We Collect
Account data: email address and authentication identifiers.
Content you upload: pictures and the text descriptions you write (“User Content”) that you submit to generate lessons, coloring pages, and pictures. The photo of your finished drawing that you take at the end of a lesson stays on your device and is never uploaded.
Technical data: your IP address and basic request details (time, page, browser), used for rate limiting and kept in our hosting provider’s logs. We collect no analytics or usage profile.
When you contact us: your email address, what you write, and anything you attach, and the Support ID shown in the app, a random code that identifies no one on its own. A report about a result (the Report button) sends us the reason you pick, your note, the tool, the page, the time and that Support ID — no email address and no picture.
Purchase data: subscription status and purchase history (processed by Apple and, in the app, by RevenueCat, which receives the Support ID, your App Store receipts and basic device details it needs to validate them (device model, system version, country and IP address) — we never see or store your payment card details).
2. How We Use Your Information
To generate drawing lessons, coloring pages, and pictures from the pictures and descriptions you provide (performance of our contract with you).
To operate, maintain, and improve the Service.
To process subscriptions and prevent abuse (our legitimate interest in a safe service).
To answer your messages and reports.
To send essential service communications.
3. AI Processing
Images you upload and descriptions you write are sent to a third-party AI provider (OpenAI) solely to check them against content rules and to generate your lesson, coloring page, or picture. This processing takes place on servers in the United States, so using the Service involves an international transfer of your image. We use OpenAI’s business API, whose terms exclude our data from training their models; we do not use your content to train models either. The provider may retain API requests for up to 30 days to detect abuse, after which they are deleted (see §5).
Face data. Photos you upload may include faces. We do not perform facial recognition, do not extract or store facial geometry or any biometric identifiers, and do not use face data for identification or tracking. Images that contain faces are processed only to generate your lesson, are handled the same way as any other upload, and are deleted automatically within 30 minutes (see §5). We never share face data with third parties for their own purposes.
4. Sharing
We share data only with: infrastructure providers (Vercel for hosting; Supabase once accounts launch), AI providers (OpenAI), and payment processors (Apple, Google, and RevenueCat, which manages in-app purchases for us; a web payment provider once web purchases open). Reports reach our team through the team chat service we use for support, which receives the report’s text and Support ID. We use no third-party analytics or advertising SDKs today; an error-monitoring or analytics provider will be listed here before it is used. We never sell or share your personal data for advertising.
5. Data Retention
Images you upload and descriptions you write: kept on our servers only while your result is being generated and deleted automatically within 30 minutes. We do not keep a long-term copy. The AI provider may hold the request for up to 30 days for abuse monitoring (see §3).
Generated lessons, coloring pages, and pictures: held on your device (“My Art”), together with the picture and description they came from. While it is being made, a result is held in our server’s memory for up to 30 minutes so it can be delivered to you; after that we keep no server-side copy, which also means we cannot restore an item you have deleted. My Art, your credit balance, and your settings use your browser’s or the app’s own storage on your device; we use no tracking cookies.
Moderation results: when an automated content check rejects a request, we log only the rule it broke (never the picture or text), alongside the request’s technical data, in our hosting provider’s logs. Short-lived request counts used for rate limiting are held in memory only.
Account and purchase data: kept while your account is active, and deleted or anonymised within 30 days of an account-deletion request, except for records we are required to keep by law (for example tax, accounting and fraud-prevention records), which are retained only for as long as the law requires.
You can request deletion at any time via the contact below.
6. Your Rights
Depending on your region (GDPR/CCPA), you may access, correct, export, or delete your data, and you may complain to your local data-protection authority. Use the contact below.
7. Children
The Service is intended for users aged 13 and older, or the minimum digital-consent age in your country if that age is higher. It is not directed to children, and we do not knowingly collect data from anyone under 13. If you believe a child has provided data, contact us and we will delete it.
8. Security
We use industry-standard measures to protect your data but cannot guarantee absolute security.
9. Changes
We may update this policy and will post the new date above.
10. Contact
ToDraw — info@todraw.app. The legal entity and postal address will be published here before public release.