Simply Draw: Learn to Draw

"We may share Personal Information with service providers and third parties for our operational purposes to enable the provisions of our services and with other service providers who provide crucial functions as database management, maintenance, marketing, data processing and analytics customer support platforms, hosting service providers, payment processors, analytics partners, third party account providers, security and/or social media service."

The policy permits sharing personal information with a wide and vaguely defined set of third parties for broadly scoped 'operational purposes,' including marketing and analytics partners.

"We may use your IP address to provide you with our product on your device, to help us with server problem diagnosis and to administer the Services. An IP address is a numeric code that identifies your device on a network, or in this case, the Internet. We may also need to use your IP geolocation data in order to receive your general location and provide you with contents adjusted for your territory."

The app uses IP-based geolocation to determine user location and adjust content by territory, which constitutes passive location tracking.

"We may automatically receive and record information from your device and browser, including your cookie information, your country, regional and language settings, device model, operating system, mobile carrier and Apps and hardware attributes."

The app automatically collects device hardware attributes, mobile carrier info, and other device-level data that goes beyond what a music learning app would need for core functionality.

"Simply reserves the right to update and change this Privacy Policy from time to time without notice or acceptance by you, so please check this page frequently for updates and changes. However, if updates reflect a substantial or material change to this Privacy Policy, then we may send you an update notice via email. Your continued use of our Site or Apps indicates your acceptance to any change in this policy."

The company explicitly reserves the right to change the privacy policy without notice or acceptance, and treats continued use as consent to any changes.

"Non-personally identifiable information may be stored indefinitely. We may retain Personal Information for longer periods if it is still necessary to meet our legal obligations (e.g. in relation to claims) or to deal with complaints, queries and to protect our legal rights in the event of a claim being made."

Non-personally identifiable information is stored indefinitely, and personal information retention has open-ended exceptions that could justify keeping data for very long periods.

"We may use services (such as Google Analytics) to understand users' behavior. These tools may use cookies to collect information. We use this information only to manage and improve our Services, and to create new features and functionality."

The use of Google Analytics and similar third-party tracking services enables cross-service behavioral tracking of users through cookies and similar technologies.

"If you choose to do so, we will delete all your personal data from our systems, including backups within 30 days, unless there is a legitimate business interest to keep the data, such as to comply with legal obligations, to enforce agreements or to resolve disputes."

While a 30-day deletion timeline is provided, the broad 'legitimate business interest' exception means data may be retained indefinitely after account deletion for vaguely defined reasons.