Last updated August 13, 2025

This Privacy Notice for Ivan Gersonskiy ("we," "us," or "our"), describes

how and why we might access, collect, store, use, and/or share

("process") your personal information when you use our services

("Services"), including when you:

• Download and use our mobile application (Draw a Dog), or any other application of ours that links to this Privacy Notice

• Engage with us in other related ways, including any sales, marketing, or events

 

 

Questions or concerns? Reading this Privacy Notice will help you

understand your privacy rights and choices. We are responsible for making

decisions about how your personal information is processed. If you do not

agree with our policies and practices, please do not use our Services. If

you still have any questions or concerns, please contact us at

stantcitizen@gmail.com.

 

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you

can find out more details about any of these topics by clicking the

link following each key point or by using our table of contents below

to find the section you are looking for.

What personal information do we process? When you visit, use, or

navigate our Services, we may process personal information depending on

how you interact with us and the Services, the choices you make, and the

products and features you use. Learn more about personal information you

disclose to us.

Do we process any sensitive personal information? Some of the

information may be considered "special" or "sensitive" in certain

jurisdictions, for example your racial or ethnic origins, sexual orientation,

and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any

information from third parties.

How do we process your information? We process your information to

provide, improve, and administer our Services, communicate with you, for

security and fraud prevention, and to comply with law. We may also

process your information for other purposes with your consent. We process

your information only when we have a valid legal reason to do so. Learn

more about how we process your information.

In what situations and with which parties do we share personal

information? We may share information in specific situations and with

specific third parties. Learn more about when and with whom we share

your personal information.

How do we keep your information safe? We have adequate

organizational and technical processes and procedures in place to protect

your personal information. However, no electronic transmission over the

internet or information storage technology can be guaranteed to be 100%

secure, so we cannot promise or guarantee that hackers, cybercriminals, or

other unauthorized third parties will not be able to defeat our security and

improperly collect, access, steal, or modify your information. Learn more

about how we keep your information safe.

What are your rights? Depending on where you are located

geographically, the applicable privacy law may mean you have certain

rights regarding your personal information. Learn more about your privacy

rights.

How do you exercise your rights? The easiest way to exercise your

rights is by submitting a data subject access request, or by contacting us.

We will consider and act upon any request in accordance with applicable

data protection laws.

Want to learn more about what we do with any information we

collect? Review the Privacy Notice in full.

 

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR

PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL

INFORMATION?

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY

RIGHTS?

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE

COLLECT FROM YOU?

 

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you

register on the Services, express an interest in obtaining information about

us or our products and Services, when you participate in activities on the

Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we

collect depends on the context of your interactions with us and the

Services, the choices you make, and the products and features you use.

The personal information we collect may include the following:

• contact or authentication data

 

 

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and

accurate, and you must notify us of any changes to such personal

information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address

and/or browser and device characteristics — is collected automatically

when you visit our Services.

We automatically collect certain information when you visit, use, or

navigate the Services. This information does not reveal your specific

identity (like your name or contact information) but may include device and

usage information, such as your IP address, browser and device

characteristics, operating system, language preferences, referring URLs,

device name, country, location, information about how and when you use

our Services, and other technical information. This information is primarily

needed to maintain the security and operation of our Services, and for our

internal analytics and reporting purposes.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related,

diagnostic, usage, and performance information our servers

automatically collect when you access or use our Services and

which we record in log files. Depending on how you interact with us,

this log data may include your IP address, device information,

browser type, and settings and information about your activity in the

Services (such as the date/time stamps associated with your usage,

pages and files viewed, searches, and other actions you take such

as which features you use), device event information (such as

system activity, error reports (sometimes called "crash dumps"), and

hardware settings).

• Device Data. We collect device data such as information about your

computer, phone, tablet, or other device you use to access the

Services. Depending on the device used, this device data may

include information such as your IP address (or proxy server), device

and application identification numbers, location, browser type,

hardware model, Internet service provider and/or mobile carrier,

operating system, and system configuration information.

 

 

2. HOW DO WE PROCESS YOUR INFORMATION?

 

In Short: We process your information to provide, improve, and administer

our Services, communicate with you, for security and fraud prevention, and

to comply with law. We process the personal information for the following

purposes listed below. We may also process your information for other

purposes only with your prior explicit consent.

We process your personal information for a variety of reasons,

depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise

manage user accounts. We may process your information so you

can create and log in to your account, as well as keep your account

in working order.

• To save or protect an individual's vital interest. We may process

your information when necessary to save or protect an individual’s

vital interest, such as to prevent harm.

 

3. WHAT LEGAL BASES DO WE RELY ON TO

PROCESS YOUR INFORMATION?

 

In Short: We only process your personal information when we believe it is

necessary and we have a valid legal reason (i.e., legal basis) to do so

under applicable law, like with your consent, to comply with laws, to provide

you with services to enter into or fulfill our contractual obligations, to protect

your rights, or to fulfill our legitimate business interests.

 

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us

to explain the valid legal bases we rely on in order to process your personal

information. As such, we may rely on the following legal bases to process

your personal information:

 

• Consent. We may process your information if you have given us

permission (i.e., consent) to use your personal information for a

specific purpose. You can withdraw your consent at any time. Learn

more about withdrawing your consent.

 

• Legal Obligations. We may process your information where we

believe it is necessary for compliance with our legal obligations, such

as to cooperate with a law enforcement body or regulatory agency,

exercise or defend our legal rights, or disclose your information as

evidence in litigation in which we are involved.

 

• Vital Interests. We may process your information where we believe

it is necessary to protect your vital interests or the vital interests of a

third party, such as situations involving potential threats to the safety

of any person.

 

If you are located in Canada, this section applies to you.

 

We may process your information if you have given us specific permission

(i.e., express consent) to use your personal information for a specific

purpose, or in situations where your permission can be inferred (i.e.,

implied consent). You can withdraw your consent at any time.

 

In some exceptional cases, we may be legally permitted under applicable

law to process your information without your consent, including, for

example:

 

• If collection is clearly in the interests of an individual and consent

cannot be obtained in a timely way

 

• For investigations and fraud detection and prevention

 

• For business transactions provided certain conditions are met

 

• If it is contained in a witness statement and the collection is

necessary to assess, process, or settle an insurance claim

 

• For identifying injured, ill, or deceased persons and communicating

with next of kin

 

• If we have reasonable grounds to believe an individual has been, is,

or may be victim of financial abuse

 

• If it is reasonable to expect collection and use with consent would

compromise the availability or the accuracy of the information and

the collection is reasonable for purposes related to investigating a

breach of an agreement or a contravention of the laws of Canada or

a province

 

• If disclosure is required to comply with a subpoena, warrant, court

order, or rules of the court relating to the production of records

 

• If it was produced by an individual in the course of their employment,

business, or profession and the collection is consistent with the

purposes for which the information was produced

 

• If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the

regulations

 

• We may disclose de-identified information for approved research or

statistics projects, subject to ethics oversight and confidentiality

commitments

 

4. WHEN AND WITH WHOM DO WE SHARE YOUR

PERSONAL INFORMATION?

 

In Short: We may share information in specific situations described in this

section and/or with the following third parties.

 

We may need to share your personal information in the following situations:

 

• Business Transfers. We may share or transfer your information in

connection with, or during negotiations of, any merger, sale of

company assets, financing, or acquisition of all or a portion of our

business to another company.

 

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-

BASED PRODUCTS?

 

In Short: We offer products, features, or tools powered by artificial

intelligence, machine learning, or similar technologies.

 

As part of our Services, we offer products, features, or tools powered by

artificial intelligence, machine learning, or similar technologies (collectively,

"AI Products"). These tools are designed to enhance your experience and

provide you with innovative solutions. The terms in this Privacy Notice

govern your use of the AI Products within our Services.

 

Our AI Products

 

Our AI Products are designed for the following functions:

 

• Image generation

 

How We Process Your Data Using AI

 

All personal information processed using our AI Products is handled in line

with our Privacy Notice and our agreement with third parties. This ensures

high security and safeguards your personal information throughout the

process, giving you peace of mind about your data's safety.

 

6. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfill the

purposes outlined in this Privacy Notice unless otherwise required by law.

 

We will only keep your personal information for as long as it is necessary

for the purposes set out in this Privacy Notice, unless a longer retention

period is required or permitted by law (such as tax, accounting, or other

legal requirements). No purpose in this notice will require us keeping your

personal information for longer than the period of time in which users have

an account with us.

 

When we have no ongoing legitimate business need to process your

personal information, we will either delete or anonymize such information,

or, if this is not possible (for example, because your personal information

has been stored in backup archives), then we will securely store your

personal information and isolate it from any further processing until deletion

is possible.

 

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of

organizational and technical security measures.

 

We have implemented appropriate and reasonable technical and

organizational security measures designed to protect the security of any

personal information we process. However, despite our safeguards and

efforts to secure your information, no electronic transmission over the

Internet or information storage technology can be guaranteed to be 100%

secure, so we cannot promise or guarantee that hackers, cybercriminals, or

other unauthorized third parties will not be able to defeat our security and

improperly collect, access, steal, or modify your information. Although we

will do our best to protect your personal information, transmission of

personal information to and from our Services is at your own risk. You

should only access the Services within a secure environment.

 

8. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short: Depending on your state of residence in the US or in some

regions, such as the European Economic Area (EEA), United Kingdom

(UK), Switzerland, and Canada, you have rights that allow you greater

access to and control over your personal information. You may review,

change, or terminate your account at any time, depending on your country,

province, or state of residence.

 

In some regions (like the EEA, UK, Switzerland, and Canada), you have

certain rights under applicable data protection laws. These may include the

right (i) to request access and obtain a copy of your personal information,

(ii) to request rectification or erasure; (iii) to restrict the processing of your

personal information; (iv) if applicable, to data portability; and (v) not to be

subject to automated decision-making. If a decision that produces legal or

similarly significant effects is made solely by automated means, we will

inform you, explain the main factors, and offer a simple way to request

human review. In certain circumstances, you may also have the right to

object to the processing of your personal information. You can make such a

request by contacting us by using the contact details provided in the

section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

 

We will consider and act upon any request in accordance with applicable

data protection laws.

 

If you are located in the EEA or UK and you believe we are unlawfully

processing your personal information, you also have the right to complain

to your Member State data protection authority or UK data protection

authority.

 

If you are located in Switzerland, you may contact the Federal Data

Protection and Information Commissioner.

 

Withdrawing your consent: If we are relying on your consent to process

your personal information, which may be express and/or implied consent

depending on the applicable law, you have the right to withdraw your

consent at any time. You can withdraw your consent at any time by 

contacting us by using the contact details provided in the section "HOW

CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

 

However, please note that this will not affect the lawfulness of the

processing before its withdrawal nor, when applicable law allows, will it

affect the processing of your personal information conducted in reliance on

lawful processing grounds other than consent.

 

Account Information

 

If you would at any time like to review or change the information in your

account or terminate your account, you can:

 

• Contact us using the contact information provided.

• ​

Upon your request to terminate your account, we will deactivate or delete

your account and information from our active databases. However, we may

retain some information in our files to prevent fraud, troubleshoot problems,

assist with any investigations, enforce our legal terms and/or comply with

applicable legal requirements.

 

If you have questions or comments about your privacy rights, you may

email us at stantcitizen@gmail.com.

 

9. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile

applications include a Do-Not-Track ("DNT") feature or setting you can

activate to signal your privacy preference not to have data about your

online browsing activities monitored and collected. At this stage, no uniform

technology standard for recognizing and implementing DNT signals has

been finalized. As such, we do not currently respond to DNT browser

signals or any other mechanism that automatically communicates your

choice not to be tracked online. If a standard for online tracking is adopted

that we must follow in the future, we will inform you about that practice in a

revised version of this Privacy Notice.

 

California law requires us to let you know how we respond to web browser

DNT signals. Because there currently is not an industry or legal standard

for recognizing or honoring DNT signals, we do not respond to them at this

time.

 

10. DO UNITED STATES RESIDENTS HAVE

SPECIFIC PRIVACY RIGHTS?

 

In Short: If you are a resident of California, Colorado, Connecticut,

Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota,

Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island,

Tennessee, Texas, Utah, or Virginia, you may have the right to request

access to and receive details about the personal information we maintain

about you and how we have processed it, correct inaccuracies, get a copy

of, or delete your personal information. You may also have the right to

withdraw your consent to our processing of your personal information.

These rights may be limited in some circumstances by applicable law. More

information is provided below.

 

Categories of Personal Information We Collect

 

The table below shows the categories of personal information we have

collected in the past twelve (12) months. The table includes illustrative

examples of each category and does not reflect the personal information

we collect from you. For a comprehensive inventory of all personal

information we process, please refer to the section "WHAT INFORMATION

DO WE COLLECT?"

 

A. Identifiers

Contact details, such as real name,

alias, postal address, telephone or

mobile contact number, unique

personal identifier, online identifier,

Internet Protocol address, email

address, and account name

NO

 

B. Personal information

as defined in the

California Customer

Records statute

Name, contact information,

education, employment, employment

history, and financial information

NO

 

C. Protected

classification

characteristics under

state or federal law

Gender, age, date of birth, race and

ethnicity, national origin, marital

status, and other demographic data

NO

 

D. Commercial

information

Transaction information, purchase

history, financial details, and payment

information

NO

 

E. Biometric information Fingerprints and voiceprints NO

 

F. Internet or other

similar network activity

Browsing history, search history,

online behavior, interest data, and

interactions with our and other

websites, applications, systems, and

advertisements

NO

 

G. Geolocation data Device location NO

 

H. Audio, electronic,

sensory, or similar

information

Images and audio, video or call

recordings created in connection with

our business activities

NO

 

I. Professional or

employment-related

information

Business contact details in order to

provide you our Services at a

business level or job title, work

history, and professional

qualifications if you apply for a job

with us

NO

 

J. Education Information Student records and directory

information

NO

 

K. Inferences drawn

from collected personal

information

Inferences drawn from any of the

collected personal information listed

above to create a profile or summary

about, for example, an individual’s

preferences and characteristics

NO

 

L. Sensitive personal

Information NO

 

We may also collect other personal information outside of these categories

through instances where you interact with us in person, online, or by phone

or mail in the context of:

 

• Receiving help through our customer support channels;

 

• Participation in customer surveys or contests; and

 

• Facilitation in the delivery of our Services and to respond to your

inquiries.

 

We will use and retain the collected personal information as needed to

provide the Services or for:

 

• Category D - As long as the user has an account with us

 

Sources of Personal Information

 

Learn more about the sources of personal information we collect in "WHAT

INFORMATION DO WE COLLECT?"

 

How We Use and Share Personal Information

 

Learn more about how we use your personal information in the section,

"HOW DO WE PROCESS YOUR INFORMATION?"

 

Will your information be shared with anyone else?

 

We may disclose your personal information with our service providers

pursuant to a written contract between us and each service provider. Learn

more about how we disclose personal information to in the section, "WHEN

AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes,

such as for undertaking internal research for technological development

and demonstration. This is not considered to be "selling" of your personal

information.

 

We have not disclosed, sold, or shared any personal information to third

parties for a business or commercial purpose in the preceding twelve (12)

months. We will not sell or share personal information in the future

belonging to website visitors, users, and other consumers.

 

Your Rights

 

You have rights under certain US state data protection laws. However,

these rights are not absolute, and in certain cases, we may decline your

request as permitted by law. These rights include:

 

• Right to know whether or not we are processing your personal data

 

• Right to access your personal data

 

• Right to correct inaccuracies in your personal data

 

• Right to request the deletion of your personal data

 

• Right to obtain a copy of the personal data you previously shared

with us

 

• Right to non-discrimination for exercising your rights

 

• Right to opt out of the processing of your personal data if it is used

for targeted advertising (or sharing as defined under California’s

privacy law), the sale of personal data, or profiling in furtherance of

decisions that produce legal or similarly significant effects

("profiling")

 

Depending upon the state where you live, you may also have the following

rights:

 

• Right to access the categories of personal data being processed (as

permitted by applicable law, including the privacy law in Minnesota)

 

• Right to obtain a list of the categories of third parties to which we

have disclosed personal data (as permitted by applicable law,

including the privacy law in California, Delaware, and Maryland)

 

• Right to obtain a list of specific third parties to which we have

disclosed personal data (as permitted by applicable law, including

the privacy law in Minnesota and Oregon)

 

• Right to review, understand, question, and correct how personal data

has been profiled (as permitted by applicable law, including the

privacy law in Minnesota)

 

• Right to limit use and disclosure of sensitive personal data (as

permitted by applicable law, including the privacy law in California)

 

• Right to opt out of the collection of sensitive data and personal data

collected through the operation of a voice or facial recognition

feature (as permitted by applicable law, including the privacy law in

Florida)

 

How to Exercise Your Rights

 

To exercise these rights, you can contact us by submitting a data subject

access request, by visiting https://www.portraitcutters.com/draw-a-dog-

support, or by referring to the contact details at the bottom of this

document.

 

Under certain US state data protection laws, you can designate an

authorized agent to make a request on your behalf. We may deny a

request from an authorized agent that does not submit proof that they have

been validly authorized to act on your behalf in accordance with applicable

laws.

 

Request Verification

 

Upon receiving your request, we will need to verify your identity to

determine you are the same person about whom we have the information

in our system. We will only use personal information provided in your

request to verify your identity or authority to make the request. However, if

we cannot verify your identity from the information already maintained by

us, we may request that you provide additional information for the purposes

of verifying your identity and for security or fraud-prevention purposes.

 

If you submit the request through an authorized agent, we may need to

collect additional information to verify your identity before processing your

request and the agent will need to provide a written and signed permission

from you to submit such request on your behalf.

 

Appeals

 

Under certain US state data protection laws, if we decline to take action

regarding your request, you may appeal our decision by emailing us at

stantcitizen@gmail.com. We will inform you in writing of any action taken or

not taken in response to the appeal, including a written explanation of the

reasons for the decisions. If your appeal is denied, you may submit a

complaint to your state attorney general.

 

California "Shine The Light" Law

 

California Civil Code Section 1798.83, also known as the "Shine The Light"

law, permits our users who are California residents to request and obtain

from us, once a year and free of charge, information about categories of

personal information (if any) we disclosed to third parties for direct

marketing purposes and the names and addresses of all third parties with

which we shared personal information in the immediately preceding

calendar year. If you are a California resident and would like to make such

a request, please submit your request in writing to us by using the contact

details provided in the section "HOW CAN YOU CONTACT US ABOUT

THIS NOTICE?"

 

11. DO WE MAKE UPDATES TO THIS NOTICE?

 

In Short: Yes, we will update this notice as necessary to stay compliant

with relevant laws.

 

We may update this Privacy Notice from time to time. The updated version

will be indicated by an updated "Revised" date at the top of this Privacy

Notice. If we make material changes to this Privacy Notice, we may notify

you either by prominently posting a notice of such changes or by directly

sending you a notification. We encourage you to review this Privacy Notice

frequently to be informed of how we are protecting your information.

 

12. HOW CAN YOU CONTACT US ABOUT THIS

NOTICE?

 

If you have questions or comments about this notice, you may email us at

stantcitizen@gmail.com or contact us by post at:

 

Ivan Gersonskiy

28 Rosh Pina

Tel Aviv 6602619

Israel

 

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE

THE DATA WE COLLECT FROM YOU?

    

You have the right to request access to the personal information we collect

from you, details about how we have processed it, correct inaccuracies, or

delete your personal information. You may also have the right to withdraw

your consent to our processing of your personal information. These rights

may be limited in some circumstances by applicable law. To request to

review, update, or delete your personal information, please fill out and 

submit a data subject access request.