Privacy Policy | PiciMe

1. Roles and responsibilities

Picime is the "controller" of the database containing personal information about its potential customers and clients. With respect to such information, we assume the responsibilities of a controller (to the extent applicable by law), as set out in this policy. Our service providers that process such information act as a "processor".

Picime is a "processor" of the personal information of subjects, in connection with processing performed as part of the services they ordered. In such a case, our clients are the "controllers" of these databases. Such processing will be carried out in accordance with Picime's Data Processing Agreement ("DPA"), and our service providers will be considered "sub-processors".

For the avoidance of doubt, each client is solely responsible for providing adequate notice to visitors and users whose personal information may be processed, and for obtaining all consents required under the privacy-protection laws in force in Israel. Picime will make reasonable efforts to assist with this obligation, as set out in the DPA.

2. Collection of personal information

The information we process may be collected by automated means, received directly from you, collected through third-party services and analytics tools, or during events that we organize or take part in. Such data may include:

• Contact details: contact details and areas of interest, as well as needs, preferences and characteristics relevant to the potential engagement.
• Interactions and communications: correspondence with us (sales, user experience, support and training), chats, surveys, feedback, calls, video recordings and transcripts.
• Website usage information: technical usage data, user agent, IP addresses, device and browser data, traffic data, approximate geographic location, activity logs, session recordings, bugs, and cookies and pixels.
• Account details: email address, name, and where necessary a hashed password, phone number or other information for verification and access control.
• Payment details: address, tax identification number, company name (if relevant), the last 4 digits of the credit card, expiration date, card type or payment tokens. Information relating solely to a non-human entity is not considered personal information.
• Service usage information: license identifier, version and IP address, service settings (number of photos, language, theme, number of subjects, approval or cancellation of message sending), website address, and the number of templates and posts created.
• Visual information: as part of the services, we may receive personal information of subjects captured by visual means (cameras). The photos may include details beyond the subjects' image, depending on the circumstances.
• Biometric information which may include: face scans of subjects and high-quality photos of them.

3. How we use personal information

In Israel, "consent" is the legal basis for processing personal information in the ways described in this policy. Your consent to the Terms of Use and to this Privacy Policy will be deemed your consent to processing personal information for all the purposes set out here. To withdraw consent, you may contact contact@picime.com. In general, we use the information to:

• make available, operate and provide the services, and enable integrations with third parties that you choose;
• facilitate payment and billing and enable the purchase of services;
• provide assistance and technical support, and to test, monitor and diagnose issues;
• improve and personalize the services, including through artificial intelligence and machine-learning capabilities;
• understand how the services are used and improve the user experience;
• manage advertising, marketing and sales campaigns, and display ads more effectively;
• contact you with service messages and promotional messages (in accordance with sections 9 and 10);
• support and improve information security and prevent fraud or prohibited activity;
• create aggregated and anonymous statistical data;
• comply with our legal, regulatory and contractual obligations.

4. Where personal information is processed

We and our authorized service providers store and process personal information in various locations where we operate, including in Israel, the European Union and the United States, as required for the proper provision of the services or by law. Picime and its providers are committed to protecting personal information in accordance with this policy, industry-standard practices and the law. For transfers to countries that do not offer an adequate level of protection, we will conduct a risk assessment and take appropriate steps to mitigate it.

5. Personal information retention period

We retain personal information for as long as there is a reasonable need to provide the services and maintain the relationship, comply with legal and contractual obligations, or defend against potential disputes, all in accordance with the law. Except as required by law or under agreements, we are not obligated to retain the information for any particular period, and we may securely delete it at any time. We do not store payment details — they are transmitted directly to the payment provider; we retain only a token that cannot be re-identified. For questions: contact@picime.com.

6. Personal information security

We and our service providers implement systems, applications and procedures to secure personal information, in order to minimize the risks of theft, damage, loss or unauthorized access and use. These measures provide robust security in accordance with industry-standard practices. However, we cannot guarantee absolute protection of information stored with us or with third parties. In the event of a data breach, we will cooperate fully with the appropriate authorities to remedy it and prevent recurrence.

7. Disclosure of personal information

We may share personal information with: service providers (server hosting and CDN, data analytics, marketing and advertising, information and cyber security, billing and payment processing, email and SMS distribution, face recognition and image object-recognition services, support and customer relationship management, and business, legal and financial advisors); affiliated companies, agents and trusted business partners; and account administrators in multi-member plans. Sharing may also occur for the purpose of protecting rights and safety, in the event of a change of control (merger/acquisition), or for compliance with the law in response to a lawful request. Anonymous information that cannot be identified may be shared. Third-party websites and services are subject to their own privacy policies and not to this one.

8. Cookies and tracking technologies

Picime and our service providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. Cookies are small text files stored in the browser — "session cookies" are deleted when the browser is closed, and "persistent cookies" are kept for longer periods. You can manage your preferences through your browser settings; disabling them may impair your use of the services.

We use Google Analytics to collect information about the use of the services, without merging it with identifying data. In addition, we may use tools such as Microsoft Clarity (heatmaps and session recordings), Google Ads / Remarketing, Meta Pixel and similar tools, for measurement, advertising and experience improvement — subject to your consent to the extent required by law.

9. How we will contact you

Service delivery: we may send important messages regarding the services (changes, billing issues, login attempts, password resets, unusual-activity alerts). You cannot opt out of service messages that are an integral part of using the services. Promotional communications: subject to your explicit consent, we may notify you about new features, offers, events and opportunities, via SMS, phone, mobile or email. To be removed from the mailing list, you may contact contact@picime.com.

10. Data subjects' rights

You have the right to request access to the personal information about you and to correct inaccurate information in databases where we are the controller or a processor. These rights are not absolute — there may be cases where the law permits or requires us to refuse part of the request, in which case we will notify you of the reasons. We may require additional information to verify the request. To exercise your rights: contact@picime.com.

11. Further information and contact

Updates and amendments: we may update this policy from time to time by posting a revised version in the services; the revised version will take effect from the date of its posting, and prior notice will be given of material changes.

Minors: the services are not intended for children under the age of 18. We do not knowingly collect personal information from children; if we become aware of such use, we will act to block it and delete the information. For inquiries: contact@picime.com.

Questions, concerns or complaints: you may contact us at any time at contact@picime.com.