Picoro Mobile – Privacy Policy

Picoro Mobile Ltd (referenced below as "Picoro", “We”, “Us” or “Our”, as applicable), respects your privacy and is committed to protect the Personal Information that you share with us. This policy describes the scope of Personal Information collection in respect of using Picoro's application and/or services (respectively, the “App” and the "Service(s)"). By using the App and/or Services, you acknowledge that you have reviewed both our Terms and Conditions and this Privacy Policy and agree to be bound by them. Please be aware that this Privacy Policy does not apply to the practices of any third parties to whom Picoro may disclose Personal Information (as defined below) pursuant to the terms of this Privacy Policy. This Privacy Policy may be occasionally updated. If we make any substantial changes in the manner we use your Personal Information, then we will provide a proper notice.

1. DATA AND PERSONAL INFORMATION WE COLLECT

Personal Information - Personal Information in this Privacy Policy refers to any information that may be used to identify an individual. The Personal Information types are collected in accordance with your use and may include:

Full name, gender, e-mail and/or physical addresses, phone number, date of birth, contact information, title and nickname, occupation and industry, personal interests, media of various types including photos, videos, audio recordings and/or text messages, comments and correspondence and other information when needed to provide a service you requested.
Any information provided by you via your use of the App and/or Services or when you interact with us.

Other Information - We may also receive and/or collect other types of data and information about you via our App and/or Services, including User Content which is provided by you, or on your behalf, to us via the App and/or Services, and other information about your mobile device or any other device and system, software, your usage of the App, location data, time zone, Internet Protocol (IP) address, language preference, and the date and time of this activity, etc. We may also receive either non-personal or public information from you and/or third parties in connection with market and demographic studies and/or data that we may use to supplement Personal Information provided directly by You. We may have access to content on your mobile device, which is needed to provide Picoro's services, which may include providing access for your contact information of other data subjects stored on your phone. For avoidance of doubt, any non-personal information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists. In addition, you acknowledge that you are not required under applicable law to provide us with any of your Personal Information, and that you provide such information at your free will and consent.

2. LEGAL BASIS FOR PROCESSING

Our collection and processing of Personal Information is based on the following:

To the extent that we use the Personal Information to improve the APP or for analysing statistics, the basis for collection of data is our legitimate interest to conduct such improvements and analysis. Our need to carry out the above processing of information is mostly for the purpose of providing our services on the APP or for the purpose of customer support and inquiries.
To the extent that we use the Personal Information for advertising or promotional activities, we will request your specific, freely-given, unbundled, informed and separate consent to such uses.

3. HOW DO WE USE YOUR INFORMATION

We may use the information (including the Personal Information) and data collected by us for the same purpose the information was provided to us and in connection with the reason for which it was provided, including in order to:

Provide you with access to the App and/or Services, or any functionality thereof, including for purposes of improving the quality of the App by formulating, customizing and enhancing the User's experience;
To administrate and improve our App and Services, or any other product under development, for our internal records and/or for statistical analysis.
Connect you to third-Parties and to allow you to share User Content with your Contacts, other Picoro's users or other third parties;
Respond to your submissions, questions, comments, requests, and complaints and provide you with customer service, technical assistance and support, subject to our sole consideration and internal policies;
Send you updates, security alerts, support and administrative notices and otherwise facilitate your use of, and our administration and operation of the App and/or Services;
Monitor and analyze usage and trends, and to personalize and improve the App and/or Services.
Send you product information, marketing information, and promotional content and/or offers that we believe may be of interest to you. This may be based on a profile that we compile based on your Personal Information, geographical location, device information, and other information regarding your prior use of our App and/or Services. We do so only if you have given your explicit, free and informed consent for such purposes. In line with the GDPR we will always give you the opportunity to opt-in to our promotional services and without your consent we will not add you to our mailing list to receive direct marketing or promotional information.

4. INFORMATION SHARING AND DISCLOSURE

Picoro is committed to protecting your privacy and will not share or disclose information about you, unless otherwise permitted under the following terms and/or circumstances:

When we have your consent to share the information;
When we need to share your information to provide the product and/or service you have requested as part of our contractual relationship;
When we need to send the information to companies who work on behalf of Picoro to provide a product and/or service you have requested as part of our contractual relationship (we will only provide those companies the information they need to deliver the product and/or service, and they are prohibited from using that information for any other purpose);
We may share your Personal Information in order to facilitate the provision of software updates, product support and other services to you (if any);
For the purpose of analysis and statistics, provided that such disclosure is done anonymously and is non-personal identifiable;
In the event of sale or transfer, in whole or in part, of Picoro or any Picoro affiliate’s shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing;
When we want to keep you updated on the latest product and/or service announcements, software updates, special offers or other information we think you’d like to hear about either from us or from our business partners (unless you have opted-out of these types of communications), only if you gave your explicit, free and informed consent to such processing activities, as detailed above.
We may share your Personal Information with certain social networking Apps, if you allow or perform such sharing through the App and/or Services;
If required to do so by applicable law, or in the good-faith belief, that (i) disclosing such information is necessary to comply with any applicable law or respond to any court order, search warrant or equivalent, or where in reasonable belief an action is needed in order to protect the personal safety of any individual; and (ii) such disclosure is appropriate or necessary in order to enforce the Terms and Conditions, take precautions against liabilities, investigate and defend against any third party claims or allegations, assist government enforcement agencies, protect the security or integrity of its App and servers and protect our rights and property.

For the above purposes, Personal Information may be transferred to recipients in countries around the world (which may be located outside the EU/EEA, European Economic Area) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring Personal Information to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision by the European Commission, we use Standard Contractual Clauses approved by the European Commission to ensure a sufficient level of protection for your Personal Information. Other than as described above, any other transfer of your Personal Information to third parties will be subject to your consent.

5. USER CONTENT

The User Content uploaded by you to the App or shared with others, including, but not limited to, photo, videos, audio recordings, or text messages, will be available or accessible to those other users and to us. As long as your User Content is shared with others, it will be deemed to be non-confidential and you hereby waive any privacy rights with respect thereto.

6. COOKIES

We may use industry-wide technologies such as cookies (a string of information that can be stored on your device, if your device is set to permit storage of cookies), or other similar tracking technologies, which store certain local information on your device to help us learn more about how you use our App and/or Services and enhance your experience. you may adjust your device or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the App or take full advantage of all of our Services and/or offerings. It is easy to prohibit and/or delete the cookies, inter alia, via settings option of your device.

7. DATA RETENTION & SECURITY

Picoro stores the Personal Information if it is necessary to fulfil the purpose for which the information has been collected. This means that Picoro deletes your Personal Information when such information is no longer necessary. Statistics and analysis which have been anonymised may be saved thereafter.
All information described above may be stored on our servers which are mounted on Cloud Services' servers on datacenters located in the EU/EEA.
We will take commercially reasonable measures in providing secure transmission of your information across the internet to our servers, and in securing the data which relates your information while at rest.
We rely on the security measures taken by the Cloud Service Provider for the physical security, the integrity, redundancy and the data protection of the data which relates your information.
However, you should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our and/or the Cloud Service Provider security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security and privacy of your Personal Information or other content you transmit using the App and/or Services, and you do so at your own risk. We encourage you to exercise discretion regarding the Personal Information you choose to disclose.

8. USE OF THE APP BY CHILDREN

Children under the age of 12 may NOT provide us with any Personal Information. If a parent believes that his or her child has submitted any Personal Information to us, he or she can contact us via e-mail at: [email protected], and we will delete the information upon learning that it relates to a child under the age of 12.

9. THIRD PARTY PLATFORMS

Our App may contain links to platforms operated by other entities. We do not share your Personal Information with those entities and are not responsible for any of their practices, including privacy practices. Although we choose our business partners carefully, please be aware that if you choose to use such links, such third party’s own rules and privacy policy will apply and govern your activities and any information you disclose while interacting with them. We encourage you to learn about the privacy policies of any third-party apps you visit.

10. DATA SUBJECT RIGHTS

You may at any time request the rectification or erasure of your Personal Information. Please note however that deletion could mean that Picoro cannot process your requests or provide you any requested Services. You have the right to request a copy of your Personal Information from our record. You have the right to request a limitation of the use of your Personal Information or the termination of use of your Personal Information. If you wish to delete or modify your Personal Information or any User Content, you can do so within the settings of your account, when possible, or you can send us an e-mail with your request to: [email protected] and we will make reasonable efforts to modify or delete any such Personal Information within a reasonable period of time, and pursuant to any applicable privacy laws. This actions also apply if you wish to modify, cancel or opt-out of your account.
Note that unless you instruct us otherwise, we may retain and use your Personal Information and User Content after termination of your account, for as long as reasonably required for the purposes of which such Personal Information and User Content was collected, including without limitation, for future analytics and analysis, comply with our legal or business requirements or obligations, to resolve disputes, to enforce our Terms and Conditions and/or to enable the user to reinstate his/her account, all as permitted under any applicable privacy laws. Notwithstanding the foregoing, Personal Information and User Content may be kept by us for a period exceeding that if it is required to do so to satisfy any applicable law, regulation, legal process, subpoena or governmental request.
Aggregate and/or anonymous information derived from your Account and/or use of the App and/or Services may remain on our servers indefinitely.

11. PRIVACY INQUIRIES

Picoro is responsible for the processing of your Personal Information, and requests to exercise your rights as stated above shall be addressed to [email protected]. If you are a resident of the EU/EEA and have a complaint regarding the processing of your Personal information by Picoro, you are entitled to report such dissatisfaction to the applicable supervisory authority in your country of residence.