Privacy Policy

Introduction

When you use the Picin application you entrust your data to us, including your personal data.


What data do we collect and process?

The Picin App collects and processes personal data (such as your name or date of birth) and other types of data.


Information you provide

When registering with Picin, you provide the following information: two photographs, your name, e-mail address, and date of birth. You may also provide additional information and personal data in the Picin application, such as your height and weight, whether or not you are in a relationship, photographs, etc. The Picin application also allows you to set personal preferences when searching for suitable connections, such as age and distance.


Sensitive personal data

Although we do not intentionally collect or process any sensitive personal data, registration on the Picin application or use of the Picin application could be considered as sensitive personal data. As optional data in the Picin application, you may also provide information about whether you are in a relationship or about your sexual identity or sexual orientation. Please remember that photographs that you post on Picin may reveal information about yourself as well.


Information from other social sites

The Picin application allows you to link your account in Picin to accounts from other social sites, specifically Instagram. When linking to an account on Instagram, Picin acquires information from your account including but not limited to your Instagram ID and access to your photographs on Instagram.


Facial Recognition data

Picin utilizes a third-party to conduct our facial recognition. Each time you use Picin we send your most recent profile photo to be verified against the facial template data of previous photos you have submitted. Picin then receives a notification whether a match has occurred and the accuracy of the match. Picin never shares any of your personal account details with the third-party (e.g. your email, name, etc.) and the data associated with your specific facial template data is never shared directly with Picin, so there is never a direct link between these two data sets.


Localization data

Localization data, i.e. information about your current location, are important for the proper functioning of the Picin application, especially when searching for suitable connections in your vicinity. Picin requests that you provide access to the localization data on the mobile device that the Picin application is installed. If you allow access to your localization data, we are then able to collect and process information on your location.


Log and Usage Data

We keep your personal information only as long as we need it for legitimate business purposes such as fraud prevention and enhancing users' safety and security.
In practice, we retain your information if:

1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);

2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

4. the information must be kept for our legitimate business interests.


Message content

The Picin application allows you to chat with other users on the Picin application or to send information to us as the operator of the application. When you use the messaging function, the amount of personal information you share is at your own risk. In all of these cases, we may collect and process the content of these messages.


Information we collect when you use the Picin application

We collect and process information about how you use the Picin application. This information includes, for example, the language setting of your mobile device or information about how you have used our services, for example, whether you have marked a profile of another user as “Like” or “Dislike”, so that we can connect you when there is mutual agreement.


Voluntary nature of personal data

Providing any personal data is completely voluntary. However, if you want to use the Picin application, you must at least provide the minimum scope of information specified in the section “Information you provide” during registration on the Picin application. Providing other information is completely voluntary for the user. “Information we collect when you use the Picin application” is always collected when using the Picin application.


How we use the information we collect

We use the information we collect for operating the Picin application, for improving and developing new services, and for protecting our company and the users of the Picin application. In addition, we use this information for marketing and commercial purposes so that we can offer you relevant products and services from our company and third parties. Thus, we can send you a commercial communication (such as an SMS, MMS, e-mail, etc.) using the electronic contact you provided to us. You are entitled at any time, even when sending individual messages, to decline any other commercial communication. We can use the data we collect for the following purposes in particular:

Operating the Picin application and providing related services,

Managing your profile, providing customer support, and communicating with you,

Making an analysis relating to how you use the Picin application and what products and services you are interested in, including collecting and assessing data in analytic tools, such as Google Analytics, and

Creating, displaying, and monitoring advertisements adapted to your interests.

We use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

We use your personal information to provide and deliver products and services customers request.

The Picin application displays your profile created in the Picin application, especially your name, photographs, age, and distance, and any other information acquired from your profiles on other social sites that you have given the Picin application access to. When displaying your profile in the Picin application, we respect the privacy settings for your profile and restrictions on displaying certain information.

Our automatized systems analyze your data and content (including photographs and the contents of communication with other users) so that we can offer you connections and content directly relevant to you, for example, adapted results of searches for connections with other users, and so that we can provide security – our systems, for example, automatically detect sexually explicit photographs or allow you to report harassment by other users.

We are able to connect all of the personal data we collect on the Picin application with information (including personal data) from other services associated with the Picin application. If you decide to purchase any of our premium services, your payment information will be processed and retained securely for the prevention of fraud and for audit/tax purposes.


TO WHOM DO WE DISCLOSE THE INFORMATION WE COLLECT?


Disclosure to other users of the Picin application

Your profile in the Picin application is visible to other Picin application users.

When displaying your profile in the Picin application, we respect the privacy settings of your profile and the restrictions on certain information.

If you “Like” another user and this user “Likes” you, thus making it a “Match”, this other user is informed of this, and you can initiate communication with this user using the chat function in the Picin application.

When authorizing the connection of your profile to other social sites, such as Instagram, other information is also visible, such as photographs and interests, and also information that you have in common with another user that browses your profile, such as common friends or interests.


Third-party disclosure – personal data processors

We can provide information that we collect, including personal data, only in the necessary scope to third parties that provide us with services, in particular, cloud data centers, services for automatic evaluation of the content of photographs or communication, etc.


Other disclosure

We could be required to provide your personal data under law or for fulfilling mandatory duties (e.g. for criminal, court, or administrative proceedings), or for emergencies. We are authorized, if necessary, to disclose your personal data in order to protect our rights or the rights of third parties or in order to protect users of the Picin application. We are authorized, if necessary, to disclose your personal data also for transactions relating to our company or its assets, such as corporate transformations, the sale of companies, or the sale of their assets. In such a case, we ensure the confidentiality of all personal data.


Access to and updating personal data

We provide you access to your personal data each time you use the Picin application. You may change or update any of the personal data at any time in Settings. You may also cancel your profile in the Picin application at any time in Settings – Account – Privacy. After you delete your profile in the Picin application, some of the data may still be stored in our databases or the databases of our partner due to technical or business reasons. You may also request information about processing your personal data by sending a request to the email address: support@picin.me

If you believe we are processing your personal data in contradiction with law, you may request an explanation by sending a request to the email address: support@picin.me or request that we remedy this situation by blocking, making changes to, supplementing, or deleting personal data.


Period for granting consent to processing personal data and recalling consent

You grant us consent to process personal data for the duration of your profile in the Picin application and use of the Picin application, provided you do not recall your consent at an earlier time as described below.

You are authorized to recall this consent to process personal data at any time. In such case, delete your profile in the Picin application and send us a request to recall your consent to processing personal data by emailing support@picin.me. After recalling your consent, we will ensure that all of the data from your profile in the Picin application are deleted as soon as possible.


Protection and security of personal data

We make every effort to protect you from unauthorized access or unauthorized changes, publication, or deletion of the information we collect. We disclose personal data only to employees and contractual partners who need to process the data on our behalf. All employees and contractual partners are bound by the duty to uphold confidentiality. We protect personal data with the help of advanced encryption technologies. We regularly inspect and update the process of collection, storage, and processing of information in order to prevent unauthorized access to our systems. However, we are not liable for any unauthorized infringement by third parties, as a result of which these parties obtain unauthorized access to your profiles or personal data and misuse these data or disclose them to third parties.


Data Storage

By using the App, you acknowledge that Picin is a global app operating through servers located in a number of countries around the world, including the United States. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence.


Children’s Privacy

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the blocking mechanism available through the service.


Changes to the privacy policy

Our privacy policy may be amended from time to time. The current version of the privacy policy, all changes, and all previous versions will be available on these web pages. If it involves significant changes, we will prepare for you a summary and explanation. You express your consent to these changes to the privacy policy by continuing to use the Picin application after notification of the changes and their effective date. If you do not agree to the changes, discontinue your use of the Picin application and delete your profile from the Picin application.


About Us

Your access to the App, as well as this Privacy Policy are governed and interpreted by the laws of the Commonwealth of Massachusetts, USA, other than such laws, rules, regulations and case law that would result in the application of the laws of a jurisdiction other than the Commonwealth State of Massachusetts. By using the App, you are consenting to the exclusive jurisdiction of the courts of the United States and the Commonwealth of Massachusetts. You agree that such courts shall have in personam jurisdiction and venue and waive any objection based on inconvenient forum. You agree that you will not file or participate in a class action against us. The Terms are provided in English. You agree that the English language version of the Terms will govern your relationship with us.


How to contact us

Should you have any questions or comments relating to the privacy policy, please contact us at the following email address: support@picin.me




Version 1.0, valid on 11 October 2019