Privacy Policy

Last Modified: Dec 03, 2021

By continuing to use Pixocial, you agree and consent that your personal information collected by Pixocial may be transferred, stored and processed to the United States of America and some other jurisdictions for the purposes discussed in this privacy policy. We are aware that laws in these countries do not provide the same level of data protection as do the laws of the European Union. In particular, there may be a different level of protection with regard to fundamental principles as provided by the European Data Protection Law, such as the principle of purpose limitation, lawfulness, fairness and transparency, as well as the potential absence of a right to access, rectification, erasure and/or restriction of processing. If you do want to know more, you may send an email to [email protected] (please quote “Pixocial” in your email title).

Your privacy is important to us.

Pixocial Technology (Singapore) Pte. Ltd. ("Pixocial Technology", "we", "us" or "our") is dedicated to protecting the privacy of our users ("users" or "you"). This Privacy Policy (the "Policy") is meant to explain our practices regarding how we collect, store, use, manage and protect your user information (including your personal information) as a controller and/or business under applicable data protection laws during your use of Pixocial application (“Pixocial”) including all its features (the "Services").

Please note that the scope of this Policy is limited solely to your user information (including your personal information) processed by Pixocial Technology (Singapore) Pte. Ltd. when you are using Pixocial. In this Policy, "personal information" refer to any information or combination of information that can be used to identify, contact or locate a discrete individual to whom the collected information pertains.

Please note that it is mandatory for you to provide certain categories of data (as specified at the time of collection). In the event that you do not provide any or sufficient data marked as mandatory, we may not be able to provide you with Pixocial service.

If you have any questions regarding this Policy or any privacy-related matters, please contact our Data Protection Officer via email at [email protected]pixocial.com (please quote “Pixocial” in your email title).

Information Provided by You

In order to provide and improve the Services, we will collect and process your personal information and user information in accordance with this Policy. If you do not provide this information, we may be unable to provide you with our products or Services. You should ensure that all personal information and user information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with all or some of the Services.

Please also note that the Pixocial app provided to you contains our service provider’s Application Programming Interfaces (APIs) or Software Development Kits (SDKs), which have tracking tools of such service providers. These third parties may use APIs and SDKs on Pixocial to collect, store, use, and manage user information. The third parties may provide Pixocial Technology with certain statistic data which must be based on certain user information, and these third parties decide which kind of user information is needed in order to get the statistical data, they also decide the means of the processing of user information.

Face Recognition

In order to provide the Services, we use face recognition technology to recognize faces in photos and camera experiences. We may detect and use facial marks to provide face recognition contents and facial manipulation features. Our Services may utilize calculation results of ARKit from Apple in relation to depth of facial mapping information, which may require to use your facial recognition features in order to ensure the face image processing effect and perform feature analysis using the algorithm. The information we collect cannot be used for identifying a specific person, and is used to provide the mentioned features only. When the content recommendation is finished or upon the closing of the application, the facial mapping information is discarded. These information is not shared with any third parties.

We will neither use the results for other purposes, nor capture any data in the file nor upload data to the server for recording purposes.

Device Information

When you use our Services on your mobile device, we collect information about your device including, where applicable, its International Mobile Equipment Identity ("IMEI"), Identifier for Advertising ("IDFA") and Identifier for Vendor ("IDFV"), Integrated Circuit Card Identifier ("ICCID"), Android ID, Media Access Control ("MAC") address, model and resolution, which will be used by us to calculate the number of devices that use our products and Services and analyze data on device models and graphics adaptation. Pixocial Technology also need unique count analytics information such as Daily Active Users (DAU), Daily Active Devices (DAD), Monthly Active Users (MAU), Monthly Active Devices (MAD) and features such as Retention, Funnels, Crash, and others.

Installed Applications

We may also access your App list and collect the application package names of the applications installed on your device. Such information will only be collected when a user initiates a sharing of photos from Pixocial to a third-party platform. If you elect to use any third-party application in connection with Pixocial, you should also review its respective privacy policy. We do not control the third-party platforms’ use of your personal information, which is governed by that third party’s privacy policy and terms and conditions.

Crash Data

We need data to count the number of users which can help Pixocial Technology improve Pixocial, meanwhile, we need the data to bring you better user experience. For the purpose of above, we will collect your universally unique identifier (“UUID”). Firebase will collect your Instance IDs. By collecting such information can the third party provide Pixocial Technology with unique product analytics. You may choose not to share this information. To do so, open settings on your Pixocial app, tap Personalization & Data and turn off the switch of Product Analytics.

For more information about Firebase, please click https://firebase.google.com/support/privacy/.

Communication and Feedbacks

We would love to hear from you and talk with you, but before we do, we need to get your approval for use of your name, email address and IP address you may provide as you send the feedback. We need your name, email address to better assess your feedback and identify the problems if you're reporting one.

When you send feedback or report a problem to us via email, we will also automatically collect certain log information stored in Pixocial (“Log Information”). Log Information may include (i) details on when and how often you use the Services, (ii) device statistics, including critical operation paths, errors, crashes, language and time zone. This Log Information is used to assess your feedback and identify the problem if you’re reporting one and is NOT USED to identify our users individually.

Advertisement

We may partner with an ad network third party to display advertising within the Pixocial app. Our third-party partners may provide you advertising based on your personal data such as device identifiers and location information. For the purpose of the above, we or an ad network third party may collect your Advertising ID for advertising and user analytic purposes. If your device does not have Advertising ID, we may use other persistent identifiers. If you wish to opt out of interest-based advertising, you could open settings on your Pixocial app, tap Personalization & Data and turn off the switch of Personalized Ads. Please note you will continue to receive generic ads.

Our partner ad networks are Facebook SDK (for more information please click https://developers.facebook.com/docs/ios or https://developers.facebook.com/docs/android), MoPub (for more information please click https://www.mopub.com/legal/privacy/), Google-Mobile-Ads (for more information please click https://policies.google.com/privacy/) and AppMonet (for more information please click https://appmonet.com/privacy-policy/).

Information Sharing and Disclosure

We make sure the third parties will not share with or disclose to other third parties (other than our service providers) your personal information in whole or in part except for the purposes of:

(i) protecting the security of others or their property;

(ii) preventing or dealing with Internet fraud;

(iii) safeguarding the legitimate rights and interests of Pixocial Technology;

(iv) taking action in line with our purposes as described in the "The Information We Collect" section, provided that recipient of any such disclosure by us is also bound by this Policy and can provide adequate protection for your information; and/or

(v) complying with laws and regulations or requests by government departments or judicial authorities, which are typically designed to uphold Internet security and the rights, property and safety of us, our users and third parties.

Information Security

We and third parties will take reasonable measures to prevent the loss, improper use of, unauthorized access to or disclosure of information. For example, some of our Services will use encryption techniques (such as SSL) to protect your personal information. However, you understand and accept that (in the Internet industry) even though we and third parties will take all possible security measures, we cannot always guarantee that your information is 100% secure. We and third parties do not accept liability for unintentional disclosure. You understand and accept that the system and communication network used by you to access our Services may fail due to factors beyond our control.

Information Access and Control

We will take all reasonable and appropriate technical measures to ensure that you can access, update and correct your personal information or other personal information provided to us by you when using our Services. Before you access, update, correct or remove such personal information, we may verify your identity in order to protect the security of your account. You may access to your information by sending your request to [email protected].

Data Retention and Correction, Update and Deletion

Subject to applicable laws and regulations and the fulfillment of our business purpose, the third parties will retain your information (including your personal information) for such period as is required for us to continue to provide you with our Services. If you wish to exercise your rights under CCPA, GDPR or other applicable laws, or wish the third party to correct, update or delete your personal information, you may send an email to [email protected](please quote “Pixocial” in your email title). We will process your request within a reasonable period of time after receiving your email or mail, and will make third parties cease collecting, using and disclosing your personal information thereafter, subject to certain exceptions prescribed by law. To protect your privacy, we will take steps to verify your identity before fulfilling your request. Please note that if you withdraw your consent or delete your personal information, your use of some of our Services may be influenced.

Information about Children

The third parties will not knowingly collect or request personal information from children under 16 (or any other age stipulated by law applicable to your region). If you are under 16, please do not send your personal information to us or third parties, including your name, address, phone number or email address. If you believe we may have any information about children under 16, you may send an email to [email protected] (please quote “Pixocial” in your email title). If we learn that we have collected personal information from children under 16 (or any other age stipulated by law applicable to your region), we will promptly take steps to delete such information.

Governing Law

This Policy is established, comes into force, and will be enforced and interpreted under the laws of Singapore, without regard to its conflict of law provisions. Any disputes arising hereunder will also be resolved in accordance with the Terms of Service. We do not represent or warrant that this Policy complies with the privacy law of any jurisdiction. Therefore, you should not interpret this Policy in accordance with such law.

Amendments to this Policy

You agree that we may update this Policy according to relevant laws and regulations or based on Pixocial Technology’s business decisions, and you agree to be bound by any such revisions hereto. We will post any significant changes to this Policy on Pixocial or notify you by other means accordingly.

If You Are a Resident of California

The California Consumer Privacy Act (“CCPA”) provides California residents with the right to know what categories of personal information we have collected about them:

We use this information to provide and improve the Services and for the purposes set forth above.

If you are a resident of California, you have the right to: (i) receive a copy of personal information that you have provided to us, or ask us to send that information to another company; and (ii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law.

The California Consumer Privacy Act also provides California residents with the right to opt out of the “sale” of their personal information. Under the CCPA, a “sale” is broadly defined as making available personal information to a third-party for valuable consideration. It does not necessarily mean money was exchanged for the transfer of personal information.

For purposes of the CCPA, a “sale” may include using targeted advertising services to deliver targeted advertising on the Services or other sites. Like most mobile applications, we use these services, which enable us to provide the Services and relevant offers to you. As a result, Pixocial Technology may “sell” the following categories of personal information: identifiers (e.g., advertising IDs); internet activity; geolocation data; and inferences drawn to create a profile.

California residents may opt-out of the “sale” of their personal information by turning off the switch of “Do Not Sell My Personal Information” under the tab of “Personalization & Data”. California residents also have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the California Consumer Privacy Act.

If you are a resident of California, every year we will provide you free of charge with an opportunity to obtain a list of third parties to which we have disclosed or with whom we have shared your personal information for their direct marketing purposes during the previous year. If you are a resident of California and wish to obtain this list, you may send an email with the subject "Pixocial - The right to privacy of a California resident" to [email protected].

Additional Information for users in the European Union

If you are in the European Union the following applies in addition to the information given in this Privacy Policy above.

Controller

The Controller for the purposes of Art. 4 no. 7 GDPR with respect to the processing outlined in this Policy is Pixocial Technology (Singapore) Pte. Ltd. You may contact us via e-mail at [email protected] (please quote “Pixocial” in your email title.).

Representative

Our representative in the European Union is Rivacy GmbH, you may contact our representative via e-mail at [email protected] or via registered mail at Rivacy GmbH, Mexikoring 33, 22297 Hamburg.

Legal Basis of the Processing

The legal basis for the processing of your personal data listed in section “Device Information” is the performance of a contract with you or the taking of steps at your request prior to entering into a contract (Art. 6 para. 1 lit. b) GDPR). The provision of this information is necessary. Without such information we cannot provide you the respective services.

The legal basis for the processing of your personal data listed in section “Crash Data” is our legitimate interest in optimizing our products and services (Art. 6 para. 1 lit. f) GDPR). The provision of this data is not necessary to enter into a contract.

The legal basis for the processing of your personal data listed in section “Communication and Feedbacks” is the performance of a contract with you or the taking of steps at your request prior to entering into a contract (Art. 6 para. 1 lit. b) GDPR). The provision of this information is necessary. Without such information we cannot provide you the respective services.

The legal basis for the processing of your personal data listed in section “Advertisement” is our legitimate interest in optimizing our products and services and to provide you with location-based advertisement (Art. 6 para. 1 lit. f) GDPR). The provision of this data is not necessary to enter into a contract.

Your rights as a Data Subject

As a data subject in the European Union you have the following rights with regard to the processing of your personal data:

Right of access

As a data subject you have the right to obtain confirmation from us as to whether we are processing your personal data (Art. 15 para. 1 GDPR). If so, you also have the right to obtain access to the personal data and the information listed in Art. 15 para. 1 GDPR. This includes information regarding the purposes of the processing, the categories of personal data that are being processed and the recipients or categories of recipients to whom the personal data have been or will be disclosed.

Right to rectification

As a data subject, you have the right to rectification set out in Art. 16 GDPR, i.e. to have your inaccurate data processed by us rectification and incomplete personal data completed.

Right to erasure (“right to be forgotten”)

As a data subject, you have a right to obtain from us the erasure of your personal data and we are obliged to erase your personal data without undue delay when one of the reasons listed in Art. 17 para. 1 GDPR applies. This can be the case, for example, if personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed (Art. 17 para. 1lit. a) GDPR).

If we have made the personal data public and are obliged to erase it, we are also obliged, taking account of available technology and the cost of implementation, to take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of those personal data (Art. 17 para. 2 GDPR).

The right to erasure (“right to be forgotten”) does not apply if the processing is necessary for one of the reasons listed in Art. 17 para. 3 GDPR. This can be the case, for example, if the processing is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims (Art. 17 para. 3 lit. a) and e) GDPR).

Right to restriction of processing

As a data subject, you have a right to obtain from us the restriction of processing if one of the conditions provided in Art. 18 para. 1 GDPR applies. This can be the case, for example, if you contest the accuracy of the personal data. In such a case, the restriction of processing lasts for a period that enables us to verify the accuracy of the personal data (Art. 18 para. 1 lit. a) GDPR).

Restriction means that stored personal data are marked with the goal of restricting their future processing (Art. 4 para. 3 GDPR).

Right to data portability

As a data subject, you have a right to receive your personal which you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance from us if the processing is based on consent pursuant to point Art. 6 para. 1 lit. a) GDPR or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR and the processing is carried out by automated means (Art. 20 para. 1 GDPR).

To verify whether our processing is based on consent pursuant to point Art. 6 para. 1 lit. a) GDPR or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR please refer to the section “Legal Basis of the Processing” of this Privacy Notice above.

In exercising your right to data portability, you also generally have the right to have your personal data transmitted directly from us to another controller if technically feasible (Art. 20 para. 2 GDPR).

Right to object

As a data subject, you have a right to object under the conditions provided in Art. 21 GDPR.

Right to object on grounds relating to the particular situation of the data subject

As a data subject, you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on Art. 6 para. 1, lit. e) or f) GDPR including profiling based on those provisions.

To verify whether our processing is based on Art. 6 para. 1, lit. e) or f) GDPR, please refer to the section “Legal Basis of the Processing” of this Privacy Notice above.

In the event of an objection relating to your particular situation, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Right to object to direct marketing

Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, we no longer process your personal data for these purposes.

Right to withdraw consent

Where our processing of your personal data is based on your consent, you have the right, pursuant to Art. 7 para. 3 GDPR, to withdraw your consent at any time. The withdrawal of your consent does not affect the legitimacy of the processing that occurred based on your consent until the withdrawal.

To verify whether our processing is based on consent pursuant to point Art. 6 para. 1 lit. a) GDPR or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR please refer to the section “Legal Basis of the Processing” of this Privacy Notice above.

Right to lodge a complaint with a supervisory authority

As a data subject, you have a right to lodge a complaint with a supervisory authority under the conditions provided in Art. 57 para. 1 lit. f) GDPR.

Additional Information on Your Rights as a Data Subject

For further information on your rights as a data subject please refer to Art. 12 to 21 GDPR, which can be accessed here: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.