Last Updated Date: April 12th, 2024

This Privacy Policy ("Privacy Policy") applies to the processing of personal data (also known as "personal information") of users ("user" or "you") by PicsMe ("we" or "us") when you use the PicsMe mobile application ("app") or otherwise interact with us and this Privacy Policy is presented to you. "Services" refers to the service provided by PicsMe as described in the relative terms.

BEFORE USING PicsMe, PLEASE CAREFULLY READ AND THOROUGHLY UNDERSTAND THIS PRIVACY POLICY, AND MAKE CHOICES YOU DEEM APPROPRIATE. WE WILL ADHERE TO CURRENT LAWS AND REGULATIONS, PROCESS YOUR PERSONAL INFORMATION APPROPRIATELY, BASED ON LEGAL AND LEGITIMATE MEANS, AND IN ACCORDANCE WITH THE PRINCIPLES OF GOOD FAITH. TERMS IN THE PRIVACY POLICY THAT SIGNIFICANTLY RELATE TO YOUR RIGHTS ARE HIGHLIGHTED IN BOLD FOR YOUR ATTENTION.

IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE THE SERVICES.

1. Collection of Personal Data

PicsMe may process your personal data for the purposes specified in this Privacy Policy.

The personal data of users collected and used by PicsMe in particular, are as follows: your name and surname, e-mail address, phone number which we will receive once you contact PicsMe, facial feature data you have uploaded to PicsMe applications (PicsMe Apps) and identifier for advertisers designated in your mobile device used in accessing our services (The Identifier for Advertisers-IDFA), identifier for vendors/developers designated your mobile device (The Identifier for Vendors-IDVF) and Internet Protocol Address-IP Address).

2. Data Categories and Data Types

  1. Information You Provide. Personal information you may provide to us through the Services are as follows:

    1. Identity Information: Name and surname

    2. Contact Information: Phone number, e-mail address

    3. Process Security: Internet traffic data (network movements, IP address, visit data, time, and date information), device name, In-app purchase history, identifier for advertisers designated in your mobile device used in accessing our services (if you give permission, the Identifier for Advertisers-IDFA), identifier for vendors/developers designated your mobile device (The Identifier for Vendors-IDVF)

    4. Visual and Audio Records: Facial feature data

    5. Customer Transaction: Order information

    6. Marketing Data: IDFA, IDVF

  2. Information From Third-party Sources. We may collect your above mentioned data directly from you through electronic or physical mediums, your mobile device, third party applications or third party sources which you can access our application through these mediums such as Apple App Store, Google Play App Store, Amazon App Store (similar platforms together with "App Stores"), for the purposes of compliance with legal obligations, enhancing our services, administering your use of our services, as well as enabling you to enjoy and easily navigate our services.

  3. Automatically Collected Information. We may collect your Log Data generated while you are using our services/applications (through our products or third-party products). This Log Data may include information such as your device's Internet Protocol ("IP") address, device name, operating system version, the configuration of the app when utilizing our service/application, the time/date of your use of the service/application, and other statistics.

3. How We Use Your Information

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

1. Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

  1. Providing modification on a photo or a picture features, and other similar Services;

  2. Managing your information and accounts;

  3. Providing access to certain areas, functionalities, and features of our Services;

  4. Answering requests for customer or technical support;

  5. Communicating with you about your account, activities on our Services, and policy changes; and

  6. Processing your financial information and other payment methods for products or Services purchased.

  7. Administrative Purposes

We use your information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

Measuring interest and engagement in our Services;

Short-term, transient use, such as contextual customization of ads;

Improving, upgrading or enhancing our Services;

Developing new features and Services;

Ensuring internal quality control and safety;

Authenticating and verifying individual identities;

Debugging to identify and repair errors with our Services;

Auditing relating to interactions, transactions and other compliance activities;

Enforcing our agreements and policies; and

Complying with our legal obligations.

Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include email campaigns, custom audiences advertising, and "interest-based" or "personalized advertising," including through cross-device tracking. You may opt-out of our marketing communications as described in the section of "Your Rights" below.

Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

Share Content Externally. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your contacts through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your contact to use our Services.

4. Data Storage and Protection

Personal data may be processed by both automated and non-automated means and may be stored at our premises and on our service providers' servers.

4.1. International data transfer

PicsMe is intended to be used only by individuals in the United States. We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

4.2. Security

We adopt technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, we may also adopt data encryption and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk.

5. Data Retention

Personal data processed including identification and contact information, identifiers and Internet and network activity information (such as IP address, device model, device type, OS version, device language, device name, country set in the device settings, information about your interactions with the app, and unique identifiers, including IDFA), other information necessary to enable you to use the app, and information collected for legal reasons will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than 3 years from the termination of the agreement.

PicsMe will ask you to upload images of yourself and select a gender in order to generate images of you in different styles. Such visual data you upload to PicsMe will be stored for the purpose of providing you with our service. If you delete your PicsMe account, any visual data you uploaded to PicsMe will be deleted within 3 months.

Additionally, any identification and contact information you provide us (such as name, social media handle, or email address, when requested), information about your interactions with the app, inferences we generate and other related information about your usage of the app will be kept until you withdraw your consent to such processing. However, should you not withdraw your consent, personal data will be kept:

for any visual data you upload to PicsMe, for no more than 3 months from the upload of the images, and

for the remaining outlined data categories, for no more than 3 years from the termination of the agreement, and

except for any legal obligation that sets a longer data retention period, at the end of these periods, the personal data processed will be deleted or anonymized.

As mentioned in the "Your Rights" section. You have the right to request that PicsMe delete any of your Personal Information that we collected from you and/or retained through account deletion. Unless subject to a certain limited exception, once PicsMe receives and confirms your verifiable data deletion request, we will delete (and direct our service providers to delete) your personal information from our records. (Please note that deleting the PicsMe App will not automatically result in deletion of your account data.)

6. Sharing Your Personal Data

We may share or disclose your personal data to the following categories of recipients:

Services Providers. Vendors carrying out activities that are related or instrumental to our business and operational activities such as outsourced data processors appointed in writing in accordance with Applicable Privacy Laws or acting as autonomous data controllers (such as IT or storage service providers, mobile measurement partners, suppliers of mobile marketing services, and advertising networks and platforms such as Google AdMob).

Business Transferees. If we carry out a corporate transaction or operation (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions), your personal data may be disclosed to our advisers and any prospective purchaser's advisers and may be one of the assets that is transferred to another owner.

Authorities and Others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Public, judicial or police authorities, within the limits established by applicable laws.

Personal data will not be disclosed for any reason other than those stated above unless such disclosure is deemed necessary for the fulfillment of a legal obligation or if we request your consent.

7. Third Party Websites and Applications

The PicsMe app may include links to other websites or services operated by third parties. The activities described in this Privacy Policy do not apply to data processed by such third-party websites and services. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website's own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

8. Advertising

This app may contain third party advertisements and links to third party sites. PicsMe does not make any representation as to the accuracy or suitability of any of the information contained in those advertisements or sites and does not accept any responsibility or liability for the conduct or content of those advertisements and sites and the offerings made by the third parties.

Advertising keeps PicsMe and many of the websites and services you use free of charge. We work hard to make sure that ads are safe, unobtrusive, and as relevant as possible.

Third party advertisements and links to other sites where goods or services are advertised are not endorsements or recommendations by PicsMe of the third-party sites, goods, or services. PicsMe takes no responsibility for the content of any of the ads, promises made, or the quality/reliability of the products or services offered in all advertisements.

9. Payment Details

In respect to any credit card or other payment processing details you have provided us, we commit that this confidential information will be stored in the most secure manner possible.

10. Your Rights

In this section, we describe the rights and choices available to all users.

Access or update your data. If you have registered for an account with us through the Services, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Declining to provide information. We need to collect personal data to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Withdraw your content or terminate your account. You can choose to withdraw certain content through your account. If you wish to request to terminate your account, please do so within the App settings.

Deletion request rights. You have the right to request that PicsMe delete any of your Personal Information that we collected from you and/or retained through account deletion. Unless subject to a certain limited exception, once PicsMe receives and confirms your verifiable data deletion request, we will delete (and direct our service providers to delete) your personal information from our records.

Do not sell my personal data. California consumers have the right to opt-out of the "sale" of your Personal Information for monetary or other valuable consideration. If you are a California Consumer and would like to exercise your right to Opt-Out of Sale or Sharing, please contact us at: [email protected]

11. Kids' Privacy

We do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

12. Changes to Our Privacy Policy

We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Services and policies. Unless otherwise required by law, we will notify you (for example, via email or in-app notification) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. THEN, IF YOU CONTINUE TO USE THE SERVICE, YOU WILL BE BOUND BY THE UPDATED PRIVACY POLICY. IF YOU DO NOT WANT TO AGREE TO THIS OR ANY UPDATED PRIVACY POLICY, YOU CAN DELETE YOUR ACCOUNT.

13. Contact Us

If you have any questions, feedback, or complaints regarding this Policy, or if you wish to contact us, please use the following methods:

Contact us: [email protected]