Privacy Policy

This Privacy Notice explains how your personal information is collected, used and disclosed by Accemo Software Limited. (“ Accemo,” “ we ,” “ us ,” or “ our ”). This Privacy Notice applies to our websites and our mobile apps for iPhone, Windows or Android mobile devices, including the PicsCam mobile app. By accessing or using the Services, you signify that you have read and understood our collection, storage, use and disclosure of your personal information as described in this Privacy Notice and agree to our Terms of Service .

When we use the term “ personal information ” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

1. OUR COLLECTION OF PERSONAL INFORMATION

Sometimes we collect personal information automatically when an individual interacts with our Services and sometimes, we collect personal information directly from an individual. At times, we may collect personal information about an individual from other sources and third parties, even before our first direct interaction. For example:

Information you provide to us directly . If you choose to create an account or otherwise use the Services, we may collect your name, username (which can be your e-mail address, phone number or Apple ID), password, your goals and your gender. We may collect personal information, such as your e-mail address when you provide feedback or otherwise communicate with us. We may also collect personal information, such as your payment method, through our third-party payment processors, including the Apple App Store and Google Play App Store.

Location Information. We collect information about the city and country in which you are located, and we may approximate your location by your IP Address.

Information we receive from third parties. From time to time, we may receive information about you from third parties and other users, such as your Apple ID or your billing record. We may also collect information about you that is publicly available.

Other information. We may collect additional information if you contact us or otherwise interact with us directly, such as by participating in a contest or promotion. We may also collect any communications between you and Accemo.

2. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION

As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual’s device, browsing actions and site usage patterns automatically when visiting or interacting with our Services, which may include log data (such as internet protocol (IP) address, UUID, model device model, operating system version, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Services and any errors that may occur during the visit to our Services), analytics data (such as the electronic path taken to our Services, through our Services and when exiting our Services, as well as usage and activity on our Services) and location data (such as general geographic location based on the log data we or our third-party providers collect).

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “ cookies ”) to automatically collect this personal information.

We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and online services; (b) provide and monitor the effectiveness of our websites and online services; (c) monitor online usage and activities of our websites and online services; (d) diagnose errors and problems with our websites and online services; (e) otherwise plan for and enhance our online services; and (f) facilitate the purposes identified in the “ Our Use of Personal Information ” section below.

We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver ads and information about products and services that may be of interest to you.

Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described above.

We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see the “ Third Party Data Collection and Online Advertising ” section below.

3. OUR USE OF PERSONAL INFORMATION

We may use personal information we collect:

• To operate, maintain, and provide to you the features and functionality of the Services, including provide software updates, product support, product enhancements and other services to you related to the Services;

• To provide you with products or services that you request or in which you express interest;

• To remember your information so you will not have to re-enter it during a subsequent visit; recognize and contact you across multiple devices; provide, improve, test, enhance, update and monitor the Services; or diagnose or fix technology problems;

• To improve, market or promote Accemo’s products and services (including the Services), for research and product development, and to perform analytics;

• To communicate directly with you, such as to send you email messages and push notifications in connection with the Services or your account (e.g., account verification, change or updates to features of the Services, technical and security notices). We may also use your information to permit you to communicate on social media or invite others to join the Services.

• To customize the advertising and content you see;

• To alert you to product upgrades, special offers, updated information and other new products and services offered by Accemo and our third-party partners;

• To respond to comments, questions or requests for customer service;

• To display advertisements, including advertisements from third parties;

• To address a violation of the Terms of Service, rules, regulations or policies of Accemo relating to the Services;

• To defend, protect or enforce our rights or applicable contracts and agreements;

• To prevent, investigate or provide notice of fraud or unlawful or criminal activity;

• For any other purpose we may describe when you provide the information.

4. OUR DISCLOSURE OF PERSONAL INFORMATION

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Your Controls ” section below.

We may disclose personal information to the following:

Third parties at your request. For example, you may have the option to share your activities on the PicaCam mobile app with your friends through email, text or on various social media sites;

Other companies and brands owned or controlled by Accemo and other companies owned by or under common ownership as Accemo, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Notice;

Third parties with whom we partner to provide contests and sweepstakes, which will usually be identified by name in the Official Rules of the contest or sweepstakes;

With third party marketing or promotional partners, who may use your information for their own purposes as well as for the benefit of our marketing and promotional activities;

Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, providing payment processing, or providing analytic services;

The public when you provide feedback or User Content. For example, if you comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our social media pages;

Other parties in connection with a Accemo transaction, such as a merger, sale of Accemo assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another Accemo entity or third party, or in the event of a bankruptcy or related or similar proceedings;

Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of the Services; and/or (c) to exercise or protect the rights, property, or personal safety of Accemo, our visitors, or others; and

Your personal information may be disclosed or transferred as required under a law or a regulation.

We may also share information with others in an aggregated or otherwise de-identified form that does not reasonably identify you directly as an individual.

5. YOUR CONTROLS

How to control your communications preferences: From time to time we may contact you with information about our products and services, including sending you email marketing messages and asking for your feedback on our products and services. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).

Modifying or deleting your information: If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at gethearty@gmail.com. We may not be able to modify or delete your information in all circumstances.

6. THIRD PARTY DATA COLLECTION AND ONLINE ADVERTISING

We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider. Please see “ Your Choices About Online Ads ” below, to learn more about interest-based advertising.

Social Media Widgets and Advertising . Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.

Third Party Partners . The following is a sample of the third-party service partners we work with to provide advertising services. We will strive to update this list if or when we work with new partners which offer you choices about the collection of your information, but as partners change and new technologies become available, this list is likely to change over time and may not always reflect our current partners.

We use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/ . You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/ .

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences , or by visiting NAI’s online resources at http://www.networkadvertising.org/choices .

Your Choices About Cookies

If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.

Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Your Choices About Online Ads

We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info . If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices , or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.

If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices .

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

7. CHILDREN’S PRIVACY

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information .

8. LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

9. REGION-SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at gethearty@gmail.com

10. CHANGES TO OUR PRIVACY NOTICE

We may modify or update this Privacy Notice from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided. If you object to any changes, you may close your account. Continuing to use the Services after we publish changes to this Privacy Notice means that you are acknowledging you understand the changes.

11. HOW TO CONTACT US

If you have any questions about this Privacy Notice or other privacy-related matters, please contact us at gethearty@gmail.com