Effective: 2023/07/03

Your privacy and data security are extremely important to us. We are committed to the responsible management, protection, and use of your personal information.

This Privacy Policy (the “Policy”) serves to explain what information Wegital HK Limited (“Pica AI”) and its affiliates and subsidiaries (collectively, “we”, “us”, or “our”) collect, and how we use and protect your information when you use any mobile applications that we develop and are available for download in the Google Play Store.

1. What Information Do We Collect?

i. Device information

• We collect your device and network connection information in order to provide you with a better experience when you use our app.
• This information depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use, and may include:

• SDK/API/JS code version, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent device identifier, the terminal manufacturer, the terminal device operating system version, the location of the language, the time zone and the network state (Wi-Fi and so on), the CPU, and the battery use, Screen resolution, Memory usage, Storage usage, sim operator, sim card country, Application release status in google play, Ad loading strategy, Ad platform and advertising placement id. Phone height and width, sim operator name, os version.
• We store the information collected through the Android ID tied to the device you are using. In this way, we can retain your advertising behavior while you are using the app. We will treat this information as personal information

ii. Data about your use of the Services

• number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on particular pages, the date and time of your request, number of the app opened and some viewed pages.
• hardware and software identification
• data on user downloads，such as what app you downloaded and your average download speed.
• data on the quality of your Service, such as interaction of your devices with our Services, including IP address, crash reports,system activity,and the date,time,and referrer URL.
• package name
• first open time timestamp
• app brand
• app net status
• firebase_device_id
• app model
• sim country
• system language etc
• your approximate location information
• Advertisers may store or read cookies

The data may be passed to the certified third-party statistical platform: Firebase, Google Analytics, Facebook Analytics, AppsFlyer and our internal data statistics system .

The above information is only used to improve the product experience and will not be sold to any third parties for any other purposes. We will not use this information for purposes other than improving the product experience and ad performance.

Besides,we may collect your following information for the purpose of providing you with the Magic Avatars feature and enhancing your user experience:

• Photos and (or) videos that you upload to Pica AI, for example to use the magic avatars feature. Please note that we always delete all metadata that may be associated with your photos and (or) videos by default (including, for example, geotags) before temporarily storing them to our systems.

Some editing features may use TrueDepth API (developed by Apple) technologies that provide information about facial position, orientation, and topology. Such information is used only on-device and is never stored on our servers. For more information about TrueDepth API processing of your photos and videos, you may visit the following link.

We can access your photos and videos only after you grant us permission to access your camera or your devices’ photo library. You provide such a permission through the request that appears on your mobile device (it may differ depending on your device operating system). You may revoke permission to access your camera or photo library through the settings on your mobile device, and here’s how to do it.

If you use an iOS device:

Step 1. On your iPhone or iPad open the Settings app.

Step 2. Scroll down and tap “Privacy”.

Step 3. Tap “Camera” or “Photos”.

Step 4. Next to Pica AI, toggle the permissions switching on or off.

If you use an Android device:

Step 1. On your device open the Settings app.

Step 2. Tap “Apps”.

Step 3. Tap “Pica AI”. If you can’t find it, tap “See all apps”. Then, choose Pica AI.

Step 4. Tap “Permissions”.

Step 5. To change a permission setting, tap it, then choose “Allow” or “Don’t allow”.

Special Instructions for Photo Information. The protection of your personal privacy and data are of utmost importance to us in designing and providing our services.  When you use the Personalized Magic Avatar feature, our AI algorithm will analyze the photos you upload and use the data to learn your facial features in order to generate personalized avatars. We will immediately and permanently delete your photos and facial features once the avatars are generated by our AI algorithm, i.e., we do not keep any of the photos you upload, nor do we keep any AI generated facial features.

Most data processing activity occurs only on your device, and the images you generate are stored on our servers for you to access and download at any time by logging in. You can permanently delete these images at any time; after deletion, they are no longer stored on our servers.

Your photo data will only be used in the avatar generation process and will not be used for any other purpose, nor will we share, sell, or transfer your information to any third party.

Information about your gender: When you use our Magic Avatars feature, we ask you about your gender. This information is used by the AI model solely to generate the Avatars in accordance with the indicated gender: for example, if you choose to identify your gender as a female, then you will receive conventionally more feminine-like Avatars.

Your email: When you create an account with Pica AI, we ask you to provide your email that will be further used for your sign-in process.

iii. Monetization and Analytical Information from Other Sources

Third-party SDKs integrated in our app may access your information, including:

• Google Advertising ID
• Demographic data (e.g. determination of your IP address)
• Data to fight against fraud (e.g. click fraud in advertising)
• Data associated with your device (e.g. device type, technological information, country)
• Data to do advertising, marketing and analysis
• Advertisers may store or read cookies

The information collected by third-party SDKs is governed by the providers of these SDKs and we have no control over such third parties. The third-parties include monetization partners, such as Google Admob, Facebook Audience Network and also analytical tools partners, such as Firebase, Google Analytics, Facebook Analytics, AppsFlyer and our internal data statistics system. The links to the above-mentioned platforms’ privacy policy are attached in the section “Third-party Privacy Policy”.

iv. Android Advertising ID

We use your Android advertising identifier in order to provide you with customized advertisement experience. It is used exclusively for advertising and analytics. Please note that the advertising identifier does not contain any user sensitive information that can be used to identify you as a user or your device. It is not connected to personally-identifiable information or associated with any persistent device identifier (for example: SSAID, MAC address, IMEI, etc.).

v. Other Information

We may collect information that you directly and voluntarily provide to us. The information includes but is not limited to: your email address, the content of feedback, and the content of the questionnaire answered by you.

vi. Designated Countries

For all information listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.

2. How Do We Use the Information?

i. To improve and optimize the Services

To provide better Services to you, we have a legitimate interest to collect and process necessary data to:

• Update and develop the Services
• Develop and improve your experience
• Manage the relationship with you
• Customize your service experience
• Respond to your comments and questions and provide support to you
• Provide offers in the Services as well as in other websites and services
• Send related information (e.g. updates, security alerts, support messages) to you

ii. To provide the Services

To provider the Services, we process data necessary to:

• Allow you to use the Apps and the Services
• Operate the Services
• Provide and deliver products and services that you request

iii. To carry out activities related to advertisements and marketing

To send you personalized advertising and marketing materials, we may use the information collected from you such as ad identifiers, age, country, region, gender, language, games played by you, information related to the interaction of you with the Services and with other users, and so forth.

We may also use various third party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.

Hence, we have a legitimate interest to process necessary data to:

• Track the content you access in connection with the Services and your online behavior
• Deliver, target and improve our advertising and marketing materials
• Pass the information collected from you to third party advertising and marketing partners

By accepting this Privacy Policy and downloading or continuing to use the Services, you consent to us and our advertising and marketing partners collecting and using information about you to personalize advertising and marketing materials and to improve your experience unless you opt out of receiving this service.

We encourage you to review the privacy policies of our third party advertising and marketing partners so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third party whether accessed through the Services or otherwise.

iv. To secure the Services

Ensuring security in the course of performing the Services is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. To achieve this purpose, we also request our suppliers who process personal information on our behalf to take appropriate security measures.

In order to keep the Service safe, to fight fraud and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

• Analyze and monitor use of the Services
• Prevent cheating, crime or fraud
• Take action against fraudulent or misbehaving users

Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the Services. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the Services may be collected and used by others. As such, you should take care of the information shared online. Please also be reminded that any questions, answers, comments, submissions that you post in the forum will be publicly available.

v. Designated Countries

For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.

3. What Information Do We Share?

As mentioned above, your personal information may be shared with our third-party partners. We may disclose your personal information to our business partners, including advertisers, publishers, and data tracking companies. These business partners may use your personal information to show you advertisements, measure your ad/site interaction, and better understand the site and app traffic usage or user behavior in order to improve their services. Such partners’ use of the information that we disclose to them will be governed by their privacy policies.

4. What Are the Important Permissions We Request?

Depending on the context of your interactions with us, we may ask you to provide certain permissions in order to let our app perform properly. You may choose to opt-out anytime, but please note that not giving us these permissions can result in malfunctioning of our app. The permissions we ask are listed below:

• Storage

• read the contents of your USB storage
• modify or delete the contents of your USB storage

• Location

• approximate location (network-based)
• precise location (GPS and network-based)

• Wi-Fi connection information

• view Wi-Fi connections

• Camera

• take pictures and videos

• Phone

• read phone status and identity
• Dial a call

• Others

• receive data from Internet
• full network access
• close other apps
• control vibration
• measure app storage space
• install shortcuts
• install apps
• view network connections
• reorder running apps
• draw over other apps
• prevent device from sleeping
• uninstall shortcuts
• run at startup
• connect and disconnect from Wi-Fi
• enable Do Not Disturb Mode
• read sync setting
• enable and Disable Sync Setting
• access Bluetooth Setting
• bluetooth pair
• ignore battery optimize
• request uninstall apps
• set wallpaper
• use Fingerprint hardware
• start foreground service
• expand and collapse status bar
• use full screen intent
• google play billing
• google Play Install Referrer API

5. Legal Basis of Your Personal Data

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes).

In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our app.

6. Your Rights

We provide you with the rights described below when you use our Services. Please contact us at support@pica-ai.com if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:

• Where denial of access is required or authorized by law;
• When granting access would have a negative impact on other's privacy;
• To protect our rights and properties;
• and Where the request is frivolous or burdensome.

i. Right to withdraw consent

If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

ii. Right of access and rectification

If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.

iii. Right to erasure (the “Right to be Forgotten”)

You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

iv. Right to restriction

You have the right to restrict our processing your personal information where one of the following applies:

• You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;
• The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;
• We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or
• You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.

We will only process your restricted personal information with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.

v. Right to object to processing

You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

vi. Right to data portability

If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

vii. Notification to third-parties

If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.

viii. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

ix. Right to lodge a complaint

If you believe we have infringed or violated your privacy rights, please contact us at support@pica-ai.com, so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

8. Residents of California, Virginia, Colorado, Utah, and Connecticut may have statutory rights under state comprehensive privacy law including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).

• Right to request the categories of Personal Information collected about you. Pica AI will provide, where relevant and required by law, the types of data we collect.
• Right to request the categories of sources from which your Personal Information is collected. Pica AI will provide, where relevant and required by law, the types of tools and organizations we use to collect data.
• Right to request the business or commercial purpose for collecting your Personal Information. Pica AI will provide, where relevant and required by law, the purposes to collect data.
• Right to request the categories of third parties to whom Personal Information is disclosed, and the categories of Personal Information disclosed. Pica AI will provide, where relevant and required by law, information regarding the other organizations that may receive your Personal Information.
• Right to request the specific pieces of Personal Information collected about you. Pica AI will provide, where relevant and required by law, your Personal Information.
• Right to request that Personal Information collected about you be deleted. We may keep Personal Information for legal reasons but will accommodate deletion requests when required. Please be aware that erasing some Personal Data may affect your ability to Use Pica AI .
• Request that your inaccurate Personal Information be corrected. If you believe your Personal Information is not correct you may provide Personal Information to replace the erroneous data.
• Request that Pica AI does not sell or share your Personal Information. Each state may interpret a “sale” of Personal Information differently, however, if you are a resident of the states above or Nevada and request that your Personal Information not be sold Pica AI will honor that request. Individuals in California may request their information not be shared with any third party.

Please keep in mind that in case of a vague request to exercise any of the aforementioned rights we may engage with you in a dialogue to ask for more details if so needed to complete your request. In case this is impossible, we reserve the right to refuse granting your request.

Following the provisions of the applicable law, we might also ask you to prove your identity (for example, by requesting your user or some other proof of your identity) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties is violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.

Please note that we will process your request within 1 month after receiving it. We may extend this period by two months where necessary, taking into account the complexity and number of the requests. If we extend the response period, we will let you know within one month from your request. We will not discriminate against you for exercising your rights under the law.

7. How You Exercise Your Rights

To exercise your rights described above, please submit a verifiable consumer request to us . Only you or your authorized agent may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for information twice within a 12-month period. A verifiable consumer request must:Provide sufficient information that allows us to reasonably verify your identity and make us confirm we collected personal information about you.Describe your request with sufficient details that allows us to understand and respond to it.

We cannot respond to your request accurately if we cannot verify your identity.

8. How We Respond Your Request

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.

9. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Such discrimination include: denying you our services; charging you different prices or rates for our services; providing you a different level or quality of our services; suggesting that you may receive a different price or rate for services or a different level or quality of services.

10. Data collection instructions for minors

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions. For users aged 13~16, they have the right to opt in, and if you are the parent or guardian of users who are aged 13~16, you can also contact us.

11. Children's Privacy

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

12. Changes to the Policy

Any information that is collected is subject to the Policy in effect at the time such information is collected. We may, however, modify the Policy from time to time. If such change has been made, we will provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our app or services following the change of the Policy will mean you accept those changes.

13. Contact Us

If you have any questions or concerns about the Policy, you may contact us at email: support@pica-ai.com.