Privacy Policy

Last updated: August 23, 2024

Your privacy is important to us.

We’re Wegital HK Limited (“We” or “Us”), the company of Pica AI with this Privacy Policy, we’ll explain how we process the personal information of Users (“User” or “You”) of the Pica AI mobile application (“App”), the Pica AI official website (http://pica-ai.com, “Site”) or those who otherwise interact with us (collectively the “Services”).

Please note that the scope of this Policy is limited solely to your personal information collected or received by Pica AI when you are using our Services. In this Policy, “personal information” refers to any information or combination of information that can be used to identify, contact, or locate an individual to whom the collected information pertains.

The following bullets highlight a few key details about our Services and security measures:

• Pica AI provides photo- and video-enhancing services. It enhances photos by sharpening photos, removing focus blur, and improving resolution. Also, it gives you the ability to swap faces in photos and videos.

• Pica AI's technologies are not used to identify or authenticate people in photos or videos.
• You retain control over the photos and videos you upload, enhance, and generate using Pica AI. We don’t sell, trade, or claim ownership of any of your photos or videos.
• Your photos and videos uploaded by you aren’t used to train our AI technologies but your generated content may be used to do that.
• Your photos and videos are safeguarded with appropriate security measures, following privacy and data protection laws and industry standards. This includes encryption and cloud storage for enhanced security.

By using our services, you are agreeing to this policy and the collection, use, processing, retention, disclosure, and sharing of your user information, including your personal information, in the manner provided in this policy. If you do not agree with any of the terms of this policy or any subsequent changes to this policy, please do not use our services. Your use of our Services constitutes a contract between you and us, which includes the Terms of Service and the Privacy Policy.

Types of data and how data is used

The following activities are always performed when you use our Services. It means that if you decide to access the Services and use the features, your personal data will be used for the purposes listed in this section. If you choose not to provide your personal data, you won’t be able to use the Services.

a) Service delivery

We use your personal data to enable you to use our Services, and to provide you with its functionalities. Examples of using the Services include enhancing your photos and swapping faces. Examples of the functionalities provided include the information shown to you about the Services.

Categories of data. The following data is used:

• User identifiers (such as Apple ID)
• Mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users) (applicable to App only)
• Device information (such as device model, device type, OS version, device language, device name, and region)
• Information about your subscription
• Information about your interaction with the App and the Site
• Photos and videos you upload, and photos and videos generated by the app (such as enhanced photos). To use our Services, the App needs access to your library and camera. You need to expressly allow this access through the request pop-up that appears on your device. Until you decide to upload photos, the photos don’t leave your device and are not stored on our servers.
• Metadata extracted from the photos that you upload for enhancement (for example, gender, age, skin tone)
• Information about faces in the photos and videos you upload, including, for example, information that estimates the location and shape of facial features (”Face Data”). Depending on the applicable law of your jurisdiction,  Face Data may be considered biometric data.  We use Face Data only to enhance your photos and create the AI photos and videos you request unless you specifically consent to other processing of this data. In no instance does Pica AI process Face Data to identify or authenticate people in photos or videos you upload.

Legal basis. These activities are based on our contract with you. However, if you upload photos and/or videos that include people other than yourself, the activities described above are based on your legitimate interest in using our Services. The processing of Face Data to perform these activities is based on your consent. If you upload images that include minors, you as the holder of parental responsibility also consent to the processing of Face Data related to them.

b) Customer support

We use your personal data to send you administrative and technical updates and to process and respond to your customer support requests and any other communications you send us.

Categories of data. The following data is used:

• Identifiers (such as name and email address)
• The content of your communication

Legal basis. These activities are based on our contract with you.

c) Service improvement

Your personal data may be used to improve and develop our products and Services. For example, we may process your data to conduct statistical analyses or other research activities to optimize our features and provide you with new ones.

Categories of data. The following data is used:

• User identifiers (such as Apple ID)
• Mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users) (applicable to App only)
• Device information (such as device model, device type, OS version, device language, device name, and region)
• Information about your subscription
• Internet and network activity information (such as IP address, and information about network usage, Internet connectivity, latency, failures, crashes, and error logs)
• Information about your interaction with the App and the Site
• Inferences we generate and other related information about your use of and experience with the App and the Site (such as your responses to in-service surveys and your feedback)
• Metadata extracted from the images that you upload for enhancement (for example, gender, age, skin tone)

Legal basis. These activities are based on our legitimate interest in improving our products.

d) Troubleshooting

We use your personal data to ensure the quality and the proper functioning of our Services by analyzing, preventing, and correcting failures and bugs, and to prevent the illicit use or misuse of the Services.

Categories of data. The following data is used:

• User identifiers (such as Apple ID)
• Mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users) (applicable to App only)
• Device information (such as device model, device type, OS version, device language, device name, and region)
• Internet and network activity information (such as IP address, and information about network usage, Internet connectivity, latency, failures, crashes, and error logs)
• Inferences we generate about your usage of the App and the Site

Legal basis. These activities are based on our legitimate interest in ensuring the quality and the proper functioning of our Services.

e) Profiling

We analyze information about you and the way you use the Services to create your user profile. We use the user profile to improve our products, develop new features, and provide you with relevant offers and a customized in-service experience. For example, we may use your data in conducting user experience research activities.

Categories of data. The following data is used:

• User identifiers (such as Apple ID)
• Mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users) (applicable to App only)
• Information about your interaction with the App and the Site
• Inferences We generate about your use of and experience with the Services
• Your answers to the surveys and the data included in such answers

Legal basis. These activities are based on our legitimate interest in improving and customizing our services.

f) Extraordinary circumstances: For compliance with legal obligations

Your personal data may be used to comply with our legal obligations, including requests from public authorities, and to prove that we have complied with them, such as in the event of a request from a public authority.

Categories of data. We may process any kind of information that may be required by law or under the instructions of public authorities.

 

Legal basis. When this activity is required by a specific legal obligation, your personal data may be used to the extent required to comply with the legal obligation itself. When the applicable law leaves some discretion in assessing the appropriate way to comply with it, your personal data is used based on our legitimate interest to prove our compliance.

g) Extraordinary circumstances: For defense

Your personal data may be used to establish, exercise, or defend our rights and those of our employees, and to carry out corporate transactions or operations. For example, your data may be processed in the event of bankruptcy, merger, acquisition, reorganization, and sale of assets or assignments, as well as the due diligence related to any such transactions.

Categories of data. We may process any kind of information necessary to ensure the correct execution of the activity.

Legal basis. This activity is based on our legitimate interest to establish, exercise, or defend our rights, and to carry out corporate transactions or operations.

Retention of your information

We retain the data we collect for different periods depending on what it is, and how we use it:

• Some data you can delete whenever you like, such as your personal info or the content you create or upload, like photos and videos. We’ll keep this data in your account until you remove it or choose to have it removed.
• We keep some data until you delete your account, such as information about how often you use our Services.
• And some data we retain for longer periods when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping.

When you delete data, we follow a deletion process to make sure that your data is safely and completely removed from our servers or retained only in anonymized form. We try to ensure that our Services protect information from accidental or malicious deletion. Because of this, there may be delays between when you delete something and when copies are deleted from our active and backup systems.

The information collected by us about the use of our Services is usually transferred to our servers in the USA and stored there. It’s worth noting that since we have offices in the People’s Republic of China and the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), the information we collect could be visited and processed in the abovementioned regions.

Recipients of your data

Your personal data may be transmitted to trusted and reliable third parties. This happens only when there are lawful grounds for the transmission. We don’t sell your data, including your photos and videos, to third parties under any circumstances.

The types of third parties to which your data may be transmitted are as follows:

• Third parties that carry out activities related to our business and operations. Such parties can operate on our behalf as data processors (for example, IT or storage service providers).
• Advisors and new owners, in the event that we carry out a corporate transaction or operation such as a merger, acquisition, reorganization, sale of assets or assignments, and as a part of the associated due diligence.
• Public, judicial, or police authorities, within the limits established by applicable laws.
• Other parties as necessary (for example, competent authorities), if we have reason to believe that your actions are inconsistent with our user agreements or policies or that you’ve violated the law, or if it’s necessary to protect our rights, property, and safety or that of our users, the public, or others.

Additionally, we may share your personal data if it’s required for the fulfillment of a legal obligation, or if you give us your consent to do so.

We may share your personal data with the following third parties:

Names or the Categories of the Third Party	Privacy Policies	Purpose of Sharing
Facebook	https://www.facebook.com/privacy/policy	Use your Facebook account to login
Google	https://policies.google.com/privacy	Use your Google account to log in and purchase content or subscribe
Apple ID	https://www.apple.com/legal/privacy/en-ww/	Use your Apple account to log in and purchase content or subscribe
Stripe	https://stripe.com/zh-us/privacy	Purchase content or subscribe on the Site

Your Rights

You can always retain control of your personal data. Depending on your location, you have certain rights in relation to your data that you can exercise at any time and without charge, in accordance with the limitations and exceptions stated by the applicable privacy laws. These include the following:

• Right to access and receive a copy of information about the processing of your personal data (access).
• Right to request that your personal data be updated, rectified, or integrated (rectification).
• Right to request that your personal data be deleted (erasure).
• Right to request that processing of your personal data be restricted (restriction of processing).
• Right to receive a portable electronic copy of your personal data (data portability).
• Where we rely on our legitimate interest to process your personal data, you have the right to object to such processing in whole or in part (objection). In particular, you have the right to object to the processing of your personal data for direct marketing, including profiling.
• Where we rely on your consent to process your personal data, you have the right to withdraw your consent (consent withdrawal). If you do so, the processing carried out before your withdrawal will remain valid, but thereafter we’ll no longer process your data for that purpose.

You also have the right to complain before the applicable regulator in the jurisdiction where you reside, if you think we’ve violated the applicable privacy laws and we haven’t addressed your request.

How to Exercise Your Rights

To exercise your rights, you can submit a request on the Feedback page. If you want to submit a request by email or if you have any other questions about privacy or data protection, you can contact us at support@pica-ai.com. You need to describe your request with sufficient details that allow us to understand and respond to it. You may only make a verifiable consumer request for information within a calendar year.

We may take some reasonable steps to verify your identity before responding to your request, such as asking you for information and making sure it matches the data available to us. If you submit a request to exercise a right as an authorized agent, we may ask you to provide proof of your authorization or we may contact the subject of the confirmation request, in accordance with applicable privacy laws.

We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period by email, telephone, or other electronic means.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You won’t be discriminated against for exercising your privacy rights.

Information about Children

We 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 such age, please do not send your personal information to us, including but not limited to your name, address, phone number, or email address. If you believe we may have any information about children under 16 (or any other age stipulated by law applicable to your region), you may report on the 「Feedback」 page or send an email to support@pica-ai.com. 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 and terminate the associated account.

Changes to this privacy policy

We may modify, integrate, or update—in whole or in part—this Privacy Policy. We’ll notify users of any modification, integration, or update in accordance with applicable privacy laws.

If we make modifications, we’ll notify you by revising the date at the top of this privacy policy, and, under certain circumstances, we may also notify you by additional means (such as via email, pop-up, or push notification).