This is the privacy policy, as updated from time to time (this "Privacy Policy"), of Pictoso, Inc. ("Pictoso" or "we" or "us"). The individual clicking the "I Accept" button when signing-on to the App ("you") agree to be bound by this Privacy Policy. Capitalized terms used but not defined in this Privacy Policy have the meanings specified in the PictoSo Terms of Use: http://api.pictoso.com/tos . PictoSo respects your privacy and is committed to protecting your personal information. We will comply with this Privacy Policy and applicable U.S. privacy law when we gather information from users of the Services.

Collecting your Information.

When you use the Services, you acknowledge and agree that you will have to provide PictoSo the following User-provided and usage-based information:

  1. Your username, password, phone number, push notification name (if applicable) when you register for a PictoSo account;
  2. Billing information (if applicable);
  3. Profile information that you provide for your user profile (e.g., first and last name, picture, phone number);
  4. User Content (e.g., photos, comments, and other materials) that you post to the Services;
  5. Communications between you and PictoSo. For example, we may send you Services-related Short Message Services ("SMS") (e.g., account verification, changes/updates to features of the Services, technical and security notices). Note that you may not opt out of Services-related SMS;
  6. Information about your physical location, generated when the App is installed;
  7. Information about your Albums (defined pursuant to the Terms of Use); and
  8. Information concerning terms and conditions contained in agreements into which you may have entered, through the App or otherwise.

You expressly acknowledge and agree that in order to provide the Services, PictoSo may periodically access your contact list and/or address book on your mobile device to find and keep track of mobile phone numbers of other users of the Services. You hereby give your express consent to PictoSo to access your contact list and/or address book for mobile phone numbers in order to provide and use the Services.

PictoSo does not collect Content stored on the Private Albums (defined below).

Analytics information:

  1. We may use third-party analytics tools to help us measure traffic and usage trends for the Services. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving the Services. We collect and use this analytics information with analytics information from other users so that it cannot reasonably be used to identify any particular individual user.

Cookies and other similar technologies

  1. When you use the Services, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use PictoSo and provide features to you. We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

Log file

  1. Log file information may be automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.
  2. When you use our Services, our servers may automatically record certain log file information, including your web request, Internet Protocol ("IP") address, your physical location, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from SMS sent to our users which then help us track which SMS are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.

Device identifiers and Metadata:

  1. When you use a mobile device like a tablet or phone to access our Services, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers". Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device.
  2. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by PictoSo. A device identifier may deliver information to us or to a third party partner about how you browse and use the Services and may help us or others provide reports or personalized content and ads. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.
  3. Metadata is usually technical data that is associated with user content. For example, Metadata can describe how, when and by whom a piece of user content was collected and how that content is formatted.


In addition to other uses of your information described under this Privacy Policy, we may use your information to:
  1. Allow you to access your information once logged in;
  2. Remember your previously entered information;
  3. Maintain a record of contractual terms to which you have consented, either through the App or otherwise;
  4. Improve, test and monitor the Services;
  5. Develop and test new products and features;
  6. Diagnose and fix technical problems related to the Services;
  7. Update the App on your device; and
  8. Other promotional or technical activities.

Sharing your Information

We may share your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that PictoSo is part of, or that become part of that group ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Services (including by providing analytics) and Affiliates' own services (including by providing you with better and more relevant experiences).

We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Services to you or provide services to you independently ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services or such independent services under reasonable confidentiality terms.

We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.


You must notify PictoSo immediately of any breach of security or unauthorized use of your mobile phone. Although PictoSo will not be liable for your losses caused by any unauthorized use of your account, you may be liable for the losses of PictoSo or others due to such unauthorized use.


If we sell or otherwise transfer part or the whole of PictoSo or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information as described under Section 1.1 above, and any other information collected through the Services may be among the items sold or transferred. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.


We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena), except for information stored by users on the App's private passcode-protected albums ("Private Albums"), if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.


Your information collected through the Services may be stored and processed in the United States or any other country in which PictoSo, its Affiliates or Service Providers maintain facilities.

By registering for and using the Services you consent to the transfer of information to the U.S. or to any other country in which PictoSo, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

We use commercially reasonable safeguards to help keep the information collected through the Services secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, PictoSo cannot ensure the security of any information you transmit to PictoSo or guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed.

Special Note to International Users

PictoSo and the Services are intended for and directed to users in the United States. If you are a user accessing the Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from United States laws, please be advised that through your continued use of the Services, which are governed by Delaware law, this Privacy Policy, and our Terms of Service, you are transferring your personal information to the United States (or any other country in which PictoSo, its Affiliates or Service Providers maintain facilities) and you expressly consent to that transfer and consent to be governed by Delaware law for these purposes.

Opting out or removing your information

You can update your account at any time by logging in or unsubscribing from SMS communications (other than Services-related communications) from PictoSo by replying "OPT OUT" to the number which sent you the SMS.


PictoSo may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of PictoSo or the Services after any modification to this Privacy Policy will constitute your acceptance of such modification.

By clicking "I Accept" when signing-on to the App you expressly acknowledge and agree to be bound by the terms and conditions of this Privacy Policy, and further acknowledge that you are legally competent to enter into this agreement with PictoSo Inc.