PICO Privacy Policy (ToB)
Last Updated: 11 Sep 2024
PICO Immersive Pte. Ltd. (“PICO,” we”, “our”, or “us”) provides innovative virtual reality products and services through our websites, applications ("apps"), content, hardware, and services (collectively, the “PICO Service(s)”). This Privacy Policy ("Policy") explains how we collect, use, share, and otherwise process your personal data in connection with PICO Services.
We are the controller responsible for your personal data. Please take a moment to familiarize yourself with our privacy practices, and contact us at privacy@picoxr.com if you have any questions.
Please note that this Policy only applies to the PICO Services. When you use third-party products and services that are designed for use with PICO Services, such as third-party apps and solutions available for your PICO device, processing of your personal data by such third parties is not controlled by PICO and may be subject to their privacy policies. We are not responsible for, and make no representations regarding, such policies, functionality, or content or any other practices or operations of such third parties.
Further, if you are using a PICO Service managed by your employer or other organization, then the organization can manage your device and account, including your default settings, and may have access to your personal data collected via the PICO Services ("Enterprise Controlled Data"). For example, the organization can see the username and email address of the PICO account which you use on the device, as well as the name of your team within your organization. The organization will also have access to some other information in connection with your device, such as the headset’s serial number, battery status, CPU usage, WiFi and Bluetooth information. These organizations are independent controllers of the Enterprise Controlled Data they collect and process, and any such Enterprise Controlled Data that PICO may process on behalf of these organizations shall be in accordance with their privacy policies. Please note that this Policy does not cover the processing of Enterprise Controlled Data by PICO.
When you use the PICO Services, such as when you create a PICO account, contact our customer support team, use the PICO product, or participate in an online survey, we collect your personal data, including:
Information You Provide to Us.
o Account Information. When you register an account to use the PICO Services, you will provide information such as your username, profile photo, email address, the country you are located in, and your date of birth.
o Transaction Information. If you add your payment information to your profile or make purchases on or through the PICO Services, we collect information you provide such as your payment information, purchase activity, shipping and contact details.
o Government-Issued ID. In certain jurisdictions, we may ask for a government-issued ID in limited circumstances, including when processing a refund request, or as required by law.
o Correspondence. When you communicate with us, we receive details and information you provide to us, such as the content of your communications, including interactions with customer support, and any content or information you submit through in-app or website feedback.
o Other information. If you submit any other information when using any PICO Service, we will receive it.
Information Automatically Collected.
We collect information automatically when you use the PICO Services, including:
o Your engagement with PICO Services. We receive information about you when you use the PICO Services, including when you log in and out of PICO Services; which apps you download or add to your wishlist; and the time/date you launch those apps on the device. We also receive information about how you use the apps on the PICO headset, for instance, we receive information about your PICO Browser usage such as which browser features you use. When you make a choice in the PICO headset settings, we will also record your choice.
o Device and network information. We collect information about the type of device you're using to interact with the PICO Services, such as a headset, PC, TV, or mobile phone; the configuration of the device, such as the device brand and model, name and version of the operating system, and screen resolution; your network, such information about your local wireless network and your IP address; and how your device is performing, such as the battery level. We also collect certain identifiers that are unique to you or your device, including device identifiers such as the serial number of the PICO headset, your PICO user ID, and other identifiers.
o Information collected via cookies. We use cookies and similar technologies to operate and provide the PICO Services. For example, we use cookies to remember your language preferences, and for security purposes. To learn more about our use of cookies, please see our Cookies Policy. We will obtain your consent to our use of cookies where required by law.
o Location. We collect your approximate location based on your device and network information, such as your device’s IP address.
o Sensor Data. We may collect information about how you interact with the device via device sensors (“Sensor Data”), to provide and improve PICO Services requested by you or your organization (if you are using an enterprise-managed device). For example, your device may collect and process your eye direction and movements and the distance between your eyes in order to calibrate the headset display to you. We do not use this data to uniquely identify or recognize you. If you or your organization choose to use the automatic fit adjustment feature, Sensor Data on the device may be used to load these saved fit settings to ensure your headset display is aligned optimally.
o Troubleshooting information. We collect troubleshooting information such as crash logs which may contain your user ID, device ID, IP address, CPU usage, amount of time it takes to load a feature, power consumption information, frame rate, and whether you use a certain feature.
Information from Other Sources.
PICO may receive personal data about you from business partners and from other lawful sources, such as:
o advertisers, measurement, and data partners, who may provide us with information about the actions you’ve taken outside of the PICO Services, online or in person;
o third-party services (for example, if you log-in to the PICO Services using a third-party service), which may provide your account information such as your email address;
others, including other users of the PICO Services, such as when you are mentioned in another user’s content, complaint, appeal, or feedback;
o publicly available sources.
2、Our Use of Your Personal Data
We use your personal data as follows:
To provide the PICO Services. We use the information we collect to provide you with the PICO Services. For example, we use this information to:
o Provide you with PICO Services, including troubleshooting and improving the PICO Services; providing and improving first-party apps; providing an optimized and life-like experience; and creating and administering accounts for you;;
o Make sure your device is fitted and calibrated optimally for better comfort, visual clarity, and VR experience, including by calculating the distance between your eyes on-device to ensure your headset display is aligned optimally;
o Communicate with you about PICO Services, including to notify you about your transactions, account, or any changes to our terms, conditions, and policies; and
o Provide technical support.
To improve the PICO Services. We also use the information we collect to improve the PICO Services. For example, we use the information to:
o Analyze usage data and metrics;
o Understand users’ feedback about the PICO Services;
o Identify and address technical issues, including crashes and other malfunctions, on the PICO Services;
o Conduct and learn from research about the ways in which you interact with the PICO Services; and
o Improve and develop our PICO Services, including training our systems and algorithms.
For security and fraud prevention. We use the information we collect to verify accounts, devices, and activities, combat harmful conduct, detect and prevent technical or security issues, including fraudulent activity, enforce our terms, conditions, and policies, and promote the safety and security on and off the PICO Services.
To comply with applicable law. We may also use your personal data for other purposes as allowed under applicable law.
For example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request when we are required to do so by applicable law.
For any other purposes disclosed to you at the time we collect your information or with your consent, or as allowed under applicable law.
3、How we Disclose Your Personal Data
We may disclose your personal data with the following partners and third parties:
● Affiliates. As a global company, the PICO Services are supported by a number of affiliated entities within our corporate group. We share your personal data with affiliated entities to enable them to provide us important functions such as cloud hosting, security, research and development, analytics, and customer and technical support.
● Service providers. We may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including your personal data, in connection with delivering the PICO Services. The service providers are obligated to handle your personal data consistent with this Privacy Policy and according to our instructions. They cannot use your personal data for their own purposes and must delete or return your personal data once they've fulfilled our request.
● Partners. From time to time, we may partner with third parties to provide services or other offerings. We require our partners to protect your personal data.
● Corporate transactions. Your personal data may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control, or acquisition of all or a portion of our business.
● With your consent. We may disclose your personal data to others at your direction or with your consent.
● For legal reasons. We may disclose information about you where permitted by applicable law if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions, exercise or defend legal claims, or to protect our operations or users.
4、Your Choices and Rights
You have the following choices with respect to your personal data. Depending on the nature of the choice you would like to exercise, we may need to verify your identity before honoring your request.
● Access or update personal data. You may request to access or update your personal data by emailing us at the email address provided in the ‘Contacting us’ section of this Policy.
● Delete your data. You may request to delete your personal data by emailing us at the email address provided in the ‘Contacting us’ section of this Policy. If you delete the information we identify as required or mandatory to provide the PICO Services, we may not be able to provide all or part of the PICO Services.
● Withdrawing your consent. If you have provided consent for us to collect, use, or share your personal data, you can revoke it by changing your choice in the relevant device or app settings, or by emailing us at the email address provided in the ‘Contacting us’ section of this Policy. We will process, validate, and respond to such requests as required by applicable law. If you revoke your consent, we may not be able to continue to provide all or part of the PICO Services.
● Others. Depending on the jurisdiction in which you reside, you may also have a right to oppose, request a copy of your authorization, limit our collection and use of your personal data, and potentially other rights. In the event that you wish to make a complaint about how we process your personal data, please contact us at privacy@picoxr.com. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.
5、Transferring Your Personal Data
We provide the PICO Services on a global basis. This means that the information that we collect from you may be transferred to, and stored at, a destination outside of the country you reside in, including in Singapore where we are based. It may also be processed by staff operating outside your country who work for us, for one of our service providers or one of our partners. We will treat your personal data securely and in accordance with this Policy and applicable law. When we store your information in countries outside of the country where you live, we ensure that all necessary measures to protect your data will be taken, including the use of appropriate transfer mechanisms when required, according to the applicable law.
6、Data Security
Security of your personal data is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your personal data from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.
For security and privacy reasons, we request that you abstain from disclosing personal information, including passwords, credit card numbers, or other confidential data during chat interactions. Our commitment to safeguarding your privacy is unwavering, but the security of personal information also relies on safe user practices.
7、Data Retention
We retain your personal data for as long as necessary to provide the PICO Services and for the purposes set out in this Policy. We also retain personal data when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing our website and app service, and enhancing the safety, security and stability of our website and app service), and for the exercise or defence of legal claims. The retention periods may differ depending on the type of information and the purposes for which we use the information.
8、Information Relating to Minors
PICO Services are not directed at children under 13 years of age or under the equivalent minimum age threshold in the relevant jurisdictions. To provide users younger than 18 with an age-appropriate experience, certain features are not available. If you believe that we have collected personal data from or about a child under the relevant minimum age, please contact us at privacy@PICOxr.com. If we learn that we have collected personal data from or about a child under the relevant minimum age, we will delete it as soon as reasonably possible.
9、Changes to This Policy
We may amend or update this Policy from time to time. If we make changes to this Policy, we will provide notice of such changes as appropriate, such as by sending you an email notification to the address you have provided, and/or providing notice through the PICO Services. If we make an administrative change, we will update the "Last Updated" date at the top of this Policy.
10、Contacting Us
If you have questions about this Policy, please contact us by email at privacy@picoxr.com.
11、Jurisdiction-Specific Terms
In the event of a conflict between the provisions of the below Jurisdiction-Specific Terms that are relevant to your jurisdiction from which you access or use the PICO Services, and the rest of this Policy, the relevant jurisdictions’ Jurisdiction-Specific Terms will supersede and govern the data processing.
11.1 Brazil
If you are using PICO Services in Brazil, the following additional terms apply:
Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.
We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:
• confirmation of whether your data are being processed;
• access to your data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or erasure of data;
• portability of personal data to a third party;
• object to the processing of personal data;
• information of public and private entities with which we shared data;
• information about the possibility to refuse providing personal data and the respective consequences, when applicable;
• withdrawal of your consent
• request an analysis of decisions taken exclusively based on the automated processing of personal data that affect your interests, including decisions taken to define your personal, professional, consumer, or credit profile, or aspects of your personality.
Verifying your identity. For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, to verify your identity, and to guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.
Limitations to your rights. In certain situations, we may have legitimate reasons not fulfilling some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with an erasure request when the maintenance of your data is required to comply with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.
In case of doubt about your privacy, your rights or how to exercise them, please contact us using the information in the "DPO" section. If you have any questions about the processing of your personal data, we would like to clarify them.
Access logs. We maintain your access logs to the application, confidentially, in a controlled and secure environment, in order to comply with legal obligations.
International Transfer of Data. We share your personal data globally with companies of our business group to carry out the activities specified in this Policy. We may also subcontract the processing of data involved in the Services or share your personal data with third parties located in other countries. Your personal data may therefore be subject to privacy laws other than those applicable in your country.
Whenever we transfer your personal data to third parties located in other countries, we will ensure that these companies comply with applicable data protection laws and we will take all reasonably necessary measures to ensure the existence of adequate safeguards to protect your personal data and to ensure that it is processed safely.
Language. The Policy may have been prepared in the English language and the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.
DPO. If you wish to contact the Data Protection Officer, please contact us: dpobrasil@bytedance.com.
11.2 Canada
If you are using the PICO Services in Canada, the following additional terms apply.
Information Relating to Children and Teens. Please note that residents of the Province of Quebec are only permitted to use the PICO Services if they are at least 14 years old.
Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal data, and to withdraw consent to our collection, use, and disclosure of your personal data. To exercise these rights, you may contact us using the contact information set out above. We may require certain personal data for the purpose of verifying the identity of the individual making the request or that they are authorized to act on your behalf of another individual in such matters.
Your Choices. You can unsubscribe from our marketing emails at any time by following the opt-out or unsubscribe instructions enclosed in the messages, or by submitting a request to the email address provided in the ‘Contacting us’ section above.
Internal Policies and Access Controls. We implement and maintain internal policies and technical measures to restrict access to your personal data within our organization. Access to personal data within our organization is limited to employees who need the information to perform their job functions. For example, our customer support team may have access to certain types of information during our interactions with you, such as responding to complaints and inquiries.
Data Retention Practices. We have procedures in place to limit the retention periods as set out in the “Data Retention” section above. When personal data is no longer needed for these purposes or is no longer required to be retained by law we take appropriate steps to dispose of it securely in accordance with our internal procedures.
Transfer Outside Your Jurisdiction. We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal data outside of Canada (and, for residents of Quebec, outside of Quebec), including in Singapore and other foreign jurisdictions where we or our service providers are located. For information about how we or our service providers (including service providers outside Canada) personal data, please contact us using the contact information set out above. We and our service providers may disclose your personal information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate.
11.3 EEA, UK and Switzerland
The information provided in this section applies to individuals in the European Economic Area, United Kingdom and Switzerland, which we refer to in this notice collectively as “Europe”.
Legal bases for processing. We use your personal data only as permitted by law. Our legal bases for processing your personal data described in this Policy are described in the table below.
Your rights. If you are located in Europe, in addition to the rights set out in section 4 "Your Choices and Rights", you also have the following rights in relation to your personal data:
Right of portability. If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format.
Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
Right to objection. You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case.
To make such requests, contact us at the email address provided in section 9 "Contacting Us".
You also have the right to lodge a complaint with your local supervisory authority, but we encourage you to first contact us with any questions or concerns.
| Processing purpose | Legal basis |
| To enable us to administer, operate, and provide the PICO Services to you, including to create your account; process your transactions; and provide you with troubleshooting. | The processing is necessary to perform the contract governing our provision of the PICO Services or to take steps that you request prior to signing up for an account to use the PICO Services. |
| To make sure your device is fitted and calibrated optimally for better comfort and VR experience. | The processing is necessary for our legitimate interests, namely, to identify and resolve issues with the PICO Services and to improve the PICO Services. |
| To understand how you use the PICO Services, including reviewing user feedback, to monitor, improve and develop the PICO Services and conduct product development. | The processing is necessary for our legitimate interests, namely, to identify and resolve issues with the PICO Services and to improve the PICO Services. |
| To share your information with third party platforms to provide you with features, such as content sharing when you integrate your PICO account with a third party service. | The processing is necessary for our legitimate interests, namely to provide you with a seamless experience, allow you to interact with third-party games, apps and service through the PICO services and your content to be shared on other platforms, enable third parties to authenticate users, and optimise your experience. |
| To comply with any legal obligation, including where necessary to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority. | This processing is necessary in order to comply with our legal obligations. |
| To communicate with you, including to notify you about changes to the PICO Services, provide customer support to you and send you other service-related messages. | The processing is necessary for the performance of a contract with you. |
| To send you marketing communications in accordance with your preferences. | The processing is necessary for our legitimate interests, namely to promote new developments and features of our PICO Services. We will obtain your consent to send you messages where required by law. |
| To enforce our terms, conditions and policies, including to ensure that you are old enough to use the PICO Services. | The processing is necessary for the performance of a contract with you. |
| To help us detect abuse, fraud, and illegal activity on the PICO Services. | The processing is necessary for our legitimate interests, namely, to ensure that the PICO Services are safe and secure. |
Cross-border transfer. We have taken appropriate safeguards to ensure that your personal data will remain protected and require our third-party service providers and partners if applicable to have appropriate safeguards as well. For onward transfers of your personal data, we ensure that: (i) the personal data is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.
UK GDPR Representative: Cosmo Technology Private Limited, whose registered office is at 2 Temple Back East, Temple Quay, Bristol, BS1 6EG, United Kingdom.
EU GDPR Representative: Mikros Information Technology Ireland Limited, whose registered office is located at Mespil Business Centre, Mespil House, Sussex Road, Dublin 4, Ireland.
11.4 South Korea
If you are using our services in South Korea, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.
Data security. We work hard to protect the PICO Services and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal policies for data protection, limitation of access to personal data on a need-to-know basis and control of access to the facilities where personal data is processed.
Data retention. We destroy personal data for which the purposes of collection as consented to by you have been achieved, or for which the periods of use as consented to by you or as provided in this Privacy Policy have expired; provided, however, we will continue to store your personal data for any statutorily-prescribed periods, where applicable.
Children. The PICO Services are not intended for use by children under 14 years of age.
Destruction of personal data. We destroy your personal data in a manner that renders it unrestorable by the relevant department.
Entrustment and/or overseas transfer of personal data. We entrust your data to our affiliates and service providers, some of whom are located outside of Korea, subject to your consents or notifications to you, if applicable. We inform you as the table below of the entrustment for processing or overseas transfer of your personal data by electronic means that takes place when we collect it. The retention period permitted to the transferee may vary according to the use of the PICO Services and the relevant terms, laws and regulations. We transfer your personal data with security measures as appropriate for the operation of the PICO Services. The entities receiving and processing your data are committed to using and storing personal data in compliance with domestic and international regulations and to taking all available physical and technical measures to protect personal data.
TransfereePurpose of TransferItems of personal information transferredAkamai Technologies, IncCDN cache servercontent filesLocal representative pursuant to the Personal Information Protection Act. Please send your inquiries concerning privacy issues in South Korea to our local representative pursuant to the Personal Information Protection Act. Contact details are as follows.
11.5 United States
If you are using PICO Services in the United States, the following additional terms apply:
Your Rights and Choices. Depending where you live, you may be entitled to certain rights with respect to your personal information, as described below:
Sale and Sharing. For United States users, PICO does not “sell” or “share” your personal data with third parties for purposes of cross-context behavioral advertising or targeted advertising, where restricted by applicable law.
Sensitive Personal Information. Although some of the information we collect may be considered sensitive personal information, we only process such information in order to provide the PICO Services and within other exemptions under applicable law.
Other California Rights
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our products do not support Do Not Track requests at this time.
11.6 Argentina
If you are using our services in Argentina, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.
Your rights and options. According to Law No. 25,326, Regulatory Decree No. 1558/2001 and the provisions and/or binding resolutions issued by the Agency for Access to Public Information ("AAIP"), you have the following rights with respect to your personal data: access, rectification and deletion regarding data protection. You can exercise your rights by sending your request to privacy@picoxr.com free of charge.
We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the AAIP. You can contact AAIP through the site: https://www.argentina.gob.ar/aaip/datospersonales/derechos. The refusal to provide requested data or providing them inaccurately may result in limitations on access to certain functionalities or specific resources, in addition to potentially generating a less personalized experience on the platform, without tailored features and content, thereby affecting the receipt of relevant content.
Limitations on your rights. In certain situations, we may have legitimate reasons for not complying with some of your requests. For example, we may choose not to disclose certain information to you where disclosure could adversely affect the protection of the rights and interests of third parties. Whenever this is the case and we are unable to fulfill a request you make, we will let you know the reasons why we are unable to fulfill your request.
Language. The Policy may have been prepared in both English and Spanish. If you are a user located in Argentina, you should consult the Spanish version, which will prevail.
11.7 Australia
Certain entities in our corporate group, located outside of Australia, are given limited remote access to your information so that they can provide certain functions, as described in the section on "How We Disclose Your Personal Data."
11.8 Indonesia
If you are using our Services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.
Age, Parental and Guardian Consent. By accessing and/or using our Services, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship:
If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing and/or using the Services.
Your Choices. You may withdraw your consent to our disclosure of personal data to third parties. Upon your request, we will display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of PICO’s features and functionality.
You may request that we: (i) disclose the history of personal data that we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting us to erase and dispose of your personal data, you may not be able to use some of PICO's features and functionality.
To exercise any of your rights, contact us at: privacy@picoxr.com.
Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.
Data retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.
After you have terminated your use of our Services and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.
11.9 Israel
If you are using our services in Israel, these additional terms apply. You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged PICO's Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.
11.10 Japan
If you are using our Services in Japan, please refer to our Japanese Language Privacy Policy.
11.11 Mexico
If you use our services in Mexico, the following additional terms apply. In the event of a conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.
How we use your personal data. Almost all of the purposes of the processing data indicated above in the main section of this Privacy Policy are necessary purposes.
How we share your personal data. We may share your personal data with a third party for purposes other than processing on our behalf. We will obtain your consent to such disclosure as required by applicable laws.
By providing us with your personal data and using our Platform, you agree to transfers that require your consent. You can always revoke your consent and exercise your rights as outlined below.
Language. The Policy may have been prepared in the English language and in the Spanish language. If you are a user located in Mexico, you shall refer to the Spanish version, which shall prevail.
Your Rights. You have the following rights with respect to your personal data: access, rectification, cancellation, opposition, revocation of consent, limitation of use and disclosure of your data. You may exercise your rights by sending your request to privacy@picoxr.com. To learn about the applicable requirements and the procedure for exercising your rights, please contact us at the above email address. If you are under 18 years of age, you may exercise your rights through a parent or guardian. Requests to exercise for your rights will be resolved as soon as possible according to the nature of your request.
Verifying your identity. For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties; to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.
Limitations on your rights. In certain situations, we may have legitimate reasons for not complying with some of your requests. For example, we may choose not to disclose certain information to you where disclosure could adversely affect the protection of the rights and interests of third parties. Whenever this is the case and we are unable to fulfill a request you make, we will let you know the reasons why we are unable to fulfill your request.
11.12 South Africa
If you are using our Services in South Africa, the following additional terms apply:
You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged this Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.
11.13 Türkiye
If you are using our Services in Türkiye, the following additional terms:
Data Controller Representative. You may contact our data controller representative in Türkiye by email to handle questions and complaints in connection with the processing of your personal data if you are in Türkiye.
Legal bases for processing your personal data. We rely on the following legal bases while processing your personal data in accordance with Article 5 of the Law No. 6698 on Protection of Personal Data:
Your rights. According to Article 11 of the Data Protection Law, you have the following rights with respect to your personal data:
If you would like to exercise your rights, please contact us at privacy@picoxr.com.
The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.
Amendments. The following sections of the Policy do not apply to individuals in Türkiye:
The following sentence at the end of the second paragraph of the introduction section: If you do not agree with this Policy, you should not access or the Platform or Services.
The following sentence at the end of the Summary section: By accessing or using the Platform and our related websites, services, applications, products and/or content available on the Platform (collectively, the “Services"), you acknowledge that you have read and understood the practices described in this Policy, and hereby consent to us collecting, using, processing, disclosing or transferring your personal data in accordance with this Policy.
The following sentence at the end of the first paragraph of the Cookies section: By accessing or using the Platform and Services, you consent to our use of Cookies.
Language. This Policy is available in English and Turkish. If there is any inconsistency or different interpretation between the English and Turkish versions, the Turkish text shall prevail.
11.14 United Arab Emirates
If you are using the Services in the United Arab Emirates (“UAE”), the following additional terms apply:
How we share your personal data
In addition to the main text of this Policy, by using the Services in the UAE you agree to the terms of this Policy and consent to our sharing of your personal data in line with the main text of this Policy.
Governing law and dispute resolution
By using our Services in the UAE, this Policy will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Policy: