Privacy policy

Privacy policy

Date of Revision: [07/2022]


Welcome to PicSo (the “APP”). We are committed to protecting and respecting your privacy. We take your privacy seriously and we will collect, process and use your personal information to provide the services only after obtaining your consent.

Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy. Please note that your use of our APP is also subject to our Terms of Service.

Scope; Third Party Sites

This Privacy Policy applies only to information we collect at and through the APP. Our APP may also contain links to third party sites that are not owned or controlled by us.Please be aware that we are not responsible for the privacy practices of such other third party sites. We encourage you to be aware when you leave our APP and to read the privacy statements of each and every website that collects personal information.

1. Information we collect

1.1 Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information. “Voluntarily provided” information refers to any information you knowingly and actively provide us when using our APP and its associated services, we will ask for your consent when we collecting your information, “voluntarily” means you may also choose not to provide such information to us, it depends on your own. “Automatically collected” information refers to any information automatically sent by your device in the course of accessing our APP and its associated services, this automatically collected information is necessary for us to provide the APP services, and we will collect this information to a minimum extent as necessary.

1.2 Information we collect under different functions:

a. When you upload your avatar, photos, videos or save your Creations (“Creations”, as defined in clause 1.3d) in your device, we need to retrieve the camera, media library/album, memory card modification of your hardware devices to collect the photo information that you want to upload or save in your device. If you not allowed us to retrieve such information, you will not be able to use the above services.

b. When you use the creating function, the contents you inputted and the according generated content (“User Generated Content”, as defined in clause 1.3 d) will be stored in our server for 7 days, you can delete the above information at any time. Please note that we will no longer store your User Generated Content after 7 days, all stored contents will be automatically deleted in our server after 7 days.

c. When you use the sharing function, your device will automatically detect the presence of third-party software that can be used in your device (such as Instagram). After you voluntarily choose the third-party software that you want to share with, your information will be collected and distributed by that third party software, and you should take care to check the privacy policy and terms of that third party software.

1.3 Types of Information we collect

a. Log Data

When you access our servers via our APP, we may automatically log the standard data provided by your device. It may include your device's Internet Protocol (IP) address, your device type and version, your activity within the APP, time and date, and other details about your usage. Additionally, when you encounter certain errors while using the APP, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

b. Personal Information

We may ask for personal information: When you use APP functions, you are required to log in — which may include one or more of the following:

  • • Email
  • • The third-party profiles of Apple or Google

When you contact us — which may include one or more of the following:

  • • Email
  • • Your log data (for debug)

c. User Account

In order to use the APP, you can register your account by using a third-party's account, such as Apple, Google (each “Connected Platform” and collectively, the “Connected Platforms”), or you can apply for registration directly from the APP.

  • (1) The third-party's account.  If you register by using a Connected Platform's account through a Connected Platform, you have agreed to provide us with certain permissions to receive certain data and information collected by such Connected Platform, which may be different for each of the Connected Platforms. We collect the data and information that we need to authenticate your registration with the Connected Platform where you are registered, as well as to enable you to use the APP safely and securely.

    Any personal information that you share through the Connected Platform will also be covered by the Connected Platform's privacy policy. Please note that any information you disclose in your public activities, along with your screen name or ID, or any image or photo, becomes public, and therefore, not protectible as confidential.

  • (2) Email Address. If you apply for registration directly from the APP, we need to collect your email address from the registration form, and then send a verification code to your email address in order to complete your registration.

d. User Generated Content

We consider “user-generated content” to be materials (text, image or video content) voluntarily supplied to us or created by our users for re-publishing on other third-party social media channels (hereinafter referred to as “User Generated Content” or “Creation”). All User-Generated Content is associated with the account or email address used to submit the materials.

Please be aware that any content you submit for the purpose of publication will be public after posting. Once published, it may be accessible to third parties not covered under this privacy policy.

e. Payment data.

Purchase transactions are done through the Google Play Store and Apple App Store, you shall carefully read their payment terms, terms of services, private policies and any other related terms. We do NOT collect your payment information directly.

f. Device Information.

We may collect information about your mobile device and internet connection, including your device's unique device identifier, operating system, browser type, and mobile network information.

2. How We Collect It

When you access, and use the APP, we may obtain the collection of information with different kinds. Please note, the technologies for collection are entirely from the third parties and the technologies they use for automatic information collection may include:

  • a. Cookies (and similar technologies). When you visit our APP we send one or more “cookies” to your computer or other device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.
  • b. Web Beacons. Pages of the APP may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related APP statistics.

3. How We Use Your Information

3.1 We collect information from you for the following purposes:

  • a. Fulfill any other purpose for which you provide it, and for the purpose of acquiring services provided by the APP.
  • b. Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • c. We may notify you when APP updates are available, and of changes to any products or services we offer or provide through it.
  • d. We may send you information about surveys, sweepstakes, promotions, and contests, as well as newsletters or other communications.

3.2 The usage and device information we collect helps us to improve our services and to deliver a better experience by enabling us to:

  • a. Estimate our audience size and usage patterns.
  • b. Recognize you when you use the APP.
  • c. Optimize and upgrade the APP, improve the fluency for APP usage.
If we decide to change the purposes of processing specified above, we will inform you of such changes PRIOR to using your personal information within the newly set purposes and ask for your separate consent if required by the applicable laws.

3.3 Please be aware that no system or network is risk-free even in light of all reasonable measures we have taken to protect your information. In cases where unforeseeable events take place, including without limitation, phishing, viruses, identify theft, other cyber-attacks, and server damages due to war or other events beyond controls, we will use our best efforts to protect your information, but we will take no liabilities for any risks, losses, or damages arising out of, in connection with, or as a result of said unforeseeable events. After where such unforeseeable events start, we will inform you of the basic situation, potential impact, and remedial measures we have taken regarding the events, in a timely and reasonably accessible manner. If further report obligations arise a result of regulatory authorities of applicable laws, we will be required to disclose such incident and relevant details to authorities as well.

4. Third-Party Information Collection

4.1 When you use the APP, certain third parties may use automatic information collection technologies to collect information about you or your device. Third parties that we use to collect data regarding APP users include:

  • a. Firebase Crashlytics , which helps track, prioritize, and fix APP stability issues.
  • b. Google Ads , which collects information to identify where download comes from.
  • c. Google, which help verify your identity and provide social login options to access our APP.
  • d. Apple , which help verify your identity and provide social login options to access our APP.

These third parties may use tracking technologies to collect information about you when using this APP.

4.2 We do NOT control these third parties' tracking technologies or how they may be used. Please read their privacy or data policies carefully to protect your information and privacy. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

5. Data Retention and Transfer

5.1 The “Creations” will be stored in our server for only 7 days, once exceed 7 days, it will be automatically deleted by us. Contents you post, including but not limited to your avatar, nickname, will be stored on a remote server until you voluntarily delete them.

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.


5.2 The APP is maintained in the Hong Kong Special Administrative Region (“HKSAR”), and you understand that data stored in the HKSAR may be subject to lawful requests by the local courts or law enforcement authorities.  Any information you provide via the APP may be stored, processed, transferred between, and accessed from the HKSAR and other districts or countries, which may not guarantee the same level of protection as the one in which you reside. You hereby explicitly consent and agree to such transfer, storing and/or processing of your information outside the district or country in which you reside.

5.3 If you are from the EU, it is important for you to know that the transfer of your data to the recipients in these countries is secured either by the participation on the basis of standard contractual clauses adopted by the European Commission and compliant with the EU data protection laws. By using our Services, you agree to such transfer and processing within the purposes set herein.

6. Disclosure of Your Information

6.1 We may disclose personal information that we collect or you provide without restriction under these circumstances:

  • a. To our subsidiaries and affiliates, where your consent is hereby expressly given.
  • b. To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • c. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our APP users is among the assets transferred.
  • d. To fulfil the purpose for which you provide it.
  • e. For any other purpose disclosed by us when you provide the information.
  • f. With your consent where applicable laws require so.
  • g. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • h. To enforce our rights arising from any contracts entered into between you and us.
  • i. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers or others.

7. How You Can Manage or Delete Your Information

7.1 You have a right to access to your personal data and right to data portability. This means you have a right to request from the APP towards your personal data in a structured, commonly used and machine-readable format.

7.2. You have a right to request from the APP to rectify your personal data. This means you can require all the inaccurate personal data concerning you being corrected. You can also complete the personal data if needed.

7.3 Withdraw your consent. You can withdraw your consent for the collection and processing of your personal data by us at any time by contacting us at: [email protected] without affecting the lawfulness of processing based on consent before its withdrawal. After we receive such withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data, unless otherwise is set by law.

7.4 You may share your Creations by using the APP for display on social media networks and other websites. We cannot control the actions of third parties with whom you may choose to share your Creations. Therefore, we cannot and do not guarantee that your Creations will not be viewed by unauthorized persons, and we have no control or liability with regard to how your Creations may be used by others once you have posted or otherwise transmitted it. Therefore, your Creations is posted and transmitted to others AT YOUR OWN RISK.

7.5 To delete your information, you can:

  • a. Find and delete specific information.

    We provide you with some tools that you can use to delete certain information. For example, you can use the “Delete” button to delete your “Creations”. Please carefully learn about what will happen after you choose to delete or remove content.

  • b. Permanently delete your account. -if you decide to permanently write off your user account, please click the “Delete Account” button, we will delete all your data in the APP, including but not limited to all Creations, purchase records. Once your account is deleted permanently, you will not be able to undo the "deleted account" or regain your data.
  • -if you have used an email address to register with the APP, once delete your APP account, you can no longer use such email address to log in.

8. European Privacy Rights

8.1 If you are a resident of the European Union, you will benefit from any mandatory provisions of the law of the country. You may have certain additional rights with respect to your personal information under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”). Nothing in this Agreement, including the paragraph above, affects your rights to rely on such mandatory provisions of local law.

8.2 You may contact us at [email protected] to exercise any of the above rights. We may request specific information from you to confirm your identity, and in some circumstances, we may charge a reasonable fee for access to your information.

8.3 If you believe that our processing of your information is inconsistent with your data protection rights under the GDPR and we have not adequately addressed your concerns, you have the right to lodge a complaint with the data protection supervisory authority of your country.

9. Children's Policy

9.1 General age limitation. The APP is not intended for children under 18 years (in certain cases this age might be different due to legal requirements in the jurisdiction of your place of domicile, collectively, “Minimum User Age”) of age, and we do not knowingly collect personal information from children underMinimum User Age . If you are under the age of Minimum User Age, please do not attempt to register for this APP or provide any personal information about yourself to us. If we learn we have collected or received personal information from a child under Minimum User Age without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under Minimum User Age, please contact us at [email protected].

9.2 Age limitation for EU residents. Due to requirements of the EU General Data Protection Regulation you shall be at least 18 years old in order to use our Services. To the extent prohibited by applicable law, we do not allow use of the Service by the EU residents younger than 18 years old, unless with the parent's/guardian's permission.

10. Changes to Our Privacy Policy

We may update our privacy policy from time to time for duly providing our services as well as complying with the applicable laws. Additional notifications will be displayed or otherwise communicated to you. So please periodically visit this privacy policy page to check for any changes. If you do not agree with the revised privacy policy, you have the right and should immediately stop using the APP.  If within a reasonable time after notifications of update, your continual use of the Services will be considered as having accepted all the amendments made, unless there is an obligation imposed on the APP by an applicable law to obtain your explicit consent to the amendments.

11. How to Contact Us

To ask questions or comment about this privacy policy and our privacy practices, contact us at: [email protected].

Contact Us