Last updated: 6 November 2019

Privacy Policy

We value your ("User," "You," or "Your") privacy and recognize the sensitivity of your personal information. We are committed to protecting your personal information and using it only as appropriate to provide you with the best possible service, products, and opportunities, as described in this Privacy Policy.

This Privacy Policy explains the online information practices of Glority Global Group Limited (collectively, “Company,” “Glority,” “Glority LLC,” “we,” “us,” or “our”) which hosts the website of http://www.picturethisai.com/ and the mobile application PictureThis (collectively, the “Application”). We think it is important to explain what information We collect, what We do with it and to describe the rights you will have with respect to the data.

Please note that when using the Application, this Privacy Policy should be read in conjunction with our Terms of Use. By accessing the Application, you acknowledge that the Privacy Policy and the Terms of Use govern your use of the Application.

The controller of your personal information is Glority. The Company may provide products and services through its affiliated companies, including Hangzhou Glority Software Limited. The affiliate acts as a Data Controller with respect to personal information processed, used, and stored as a part of services and activities conducted by the Glority affiliate. Certain services and activities may be conducted by several Glority affiliates.

Privacy and personal data protection principles vary from one country to another. When you access or visit a third party website or application, you are subject to the privacy policy of that website or application. Please read the third party’s privacy policy to determine the privacy practices that apply to information or data maintained by the website or application.

I. What Information We Collect and How It Is Used

We may collect and hold personal information related to you that is necessary for the purpose of conducting our business, including (without limitation) to deliver products, services or information, improve our services to offer better experience, and to fulfill our regulatory obligations. We will tell you when we ask for your information whether it is a statutory or contractual requirement to give us the information and the consequences of not providing the information.

To undertake above goals, we may collect the following personal information related to our users:

User profile: If you are a visitor to the Application, creating a user profile is optional. If you register for a user account with the Application, we may collect certain information such as your e-mail address, username and password. You can also use your Facebook account to register with us. Note, however, that we do not collect information from Facebook.

User content: We will collect any user content you create, share, or post to the Application, which may include information contained in your user account, as well as photos or other image files and associated metadata. Please note that other users of the Application may be able to download and extract any images shared publicly on the Application. You should avoid uploading images with embedded location data included.

Do not include financial account numbers, social security numbers or any other sensitive or confidential information in your submissions to the Application.

We may also collect information that you submit when you contact the customer support, or otherwise submit information to the Company, including email address, and other information submitted during your use of the Application.

Location Information: Depending on your device settings or permissions, we may collect your location information using geo-location technology. If you consent to our use of location data, we may use your location data for the purpose of improving plant identification services and finding nearby plants.

Financial Data: We utilizes Apple and Google to process all financial transactions and Glority is not provided with any personal data related to your transaction.

Device and Internet Usage: If you download the Application, we may collect information from your device, including identifiers to help us identify your device’s hardware and operating system. Device information may be accessed using industry standard identifiers such as those approved by your device operating system manufacturer.

Cookies: Cookies are small files which, when placed on your device, enable the Platform to provide certain features and functionality. We and our service providers use cookies to automatically collect information, measure and analyze which pages you click on and how you use the application, enhance your experience using the application, improve our services. Cookies may include information such as your login or registration identification, user preferences, time spent on a website and pages visited. We may also use third-party tracking technology to record similar information regarding you and your activity on the Application. Google Analytics may collect your IP address, data related to the device/browser, or other information about your use of the Application and may do so using cookies. Google Analytics’ data practices are governed by the Google Privacy Policy, as it may be amended from time to time. By using the Application, you consent to our use of Cookies.

Additionally, we allow our service providers (including analytics vendors and advertising networks) to collect information about your online activities through cookies. These third parties may use this information to display advertisements on our application and elsewhere online tailored to your interests, preferences, and characteristics. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

Some devices may offer a “Do Not Track” feature. The Application does not respond to “Do Not Track” signals.

II. How Information Is Used

Purpose Legal Basis
To provide support and to respond to your requests and enquiries We have a legitimate interest to respond to your requests and inquiries for ongoing business administration
To personalize your visits to the Application and to assist you while you use the Application We have a legitimate interest in providing and improving the Application
To deliver the Application’s services
To improve the Application by helping us understand who uses the Application and how it is being used
To share data with our service providers, such as those that host data for us, including Amazon Web Services We have a legitimate interest in using vendors to provide business services
To share data with our affiliates We have a legitimate interest in improving our services
To market our products and services as well as enable third parties to provide advertisements to you via the Application We have a legitimate interest in promoting our products and services and generating advertising revenue, and give you choices about whether or not to use our advertising supported free application option
To respond to law enforcement organization, or other government officials where we have a legal obligation, including complying with legal demands and complying with production and court orders. We will notify user of the information request or submission as, and if, allowed. We have a legitimate interest in complying with applicable legal or regulatory obligations
The day to day running and management of the business including to monitor, maintain and improve the processes, information and data, technology and communications solutions and services we use; protect our legal rights and interests; and share such personal information with third parties that acquire or are interested in acquiring all or part of our assets or shares, or that succeeds us in carrying on our business; We have a legitimate interest to manage our business including to maintain ongoing operations and to improve and strengthen our operations

Your Right to Object - Please note that you have a right to object to processing of your personal information where that processing is carried out for our legitimate interest.

III. Information That Is Not Covered By This Privacy Policy

We may allow you to communicate with other users of the Application and post information using message boards and other similar features available through the Site. NONE of the information that you provide using these features is protected by this Privacy Policy. You should consult the privacy practices of these third parties before sharing your information with third parties.

IV. Data Retention

We retain your personal information for as long as it is necessary and relevant for our business. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services and operate the business; (ii) the type of personal information collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the personal information (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

V. Data Rights

You have the right (subject to certain limitations) to: (i) request access to personal information we hold about you; (ii) the correction of your personal information when incorrect, out of date or incomplete; (iii) request that we delete your personal information; (iv) opt-out of any marketing communications that we may send to you and to object to us using / holding your personal information if we have no legitimate reason to do so; and (iii) the portability of personal information i.e., ask for a copy of your personal information to be provided to you, or a third party, in a digital format. Where we are relying on your consent to handle your personal information, you have the right to withdraw your consent to this use at any time. We do not sell personal information to third parties for their own business/commercial uses.

All such requests should be made using the contact details set out below. Please note that if you request that your personal information be deleted, you may no longer be able to access or use certain parts of the Application. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, we may extend this period by two months and we will tell you why. We may request proof of identification to verify your request. For more details in relation to your rights, including how to exercise them, please contact us using the contact details below.

You also have the right to lodge a complaint about the handling of your personal information with an EU data protection authority or other relevant regulator.

California residents may request certain information about our disclosure of personal data during the prior calendar year to third parties for their direct marketing purposes. We do not share your personal data with third parties or corporate affiliates for their direct marketing purposes.

VI. Security

We maintain security standards and procedures designed to prevent unauthorized access to your data by anyone, including our staff. We use commercially reasonable means such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your personal information. The Company and our staff and any third parties hired to provide support services will be required to observe our privacy standards and to allow us to audit them for compliance. However, no information security defenses are impenetrable, and we cannot guarantee the security of our applications, servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.

VII. International Audience

The Application is hosted in the United States. Therefore, personal information collected from you, including via the Application, will be transferred to the United States. Such transfer may not provide a similar level of protection to that provided by countries in foreign jurisdictions. As discussed above, we have a legitimate interest in utilizing service providers in the United States to provide you with the services.

Please do not use the Application if you do not agree to the transfer and processing of your personal information in the United States or if it is illegal to do so in your home country.

VIII. Children’s Privacy

We do not knowingly collect personal information from children under the age of 16, and in the event that we learn that a child under the age of 16 has provided information on the Application, we will delete that information as soon as possible.

IX. Changes

This Privacy Policy sets out our current policies and demonstrates our commitment to your privacy. We may change the content or services found on the Application at any time, and consequently our Privacy Policy may change at any time in the future and will be updated from time to time. Whenever we make changes to this Privacy Policy that are important for you to know about, we will post the updated Privacy Policy at this link.

X. Your Queries

If you have any queries regarding privacy issues or if you wish to exercise your data rights as described above, email us or visit any of our branches for more information. To ensure that we carry out your instructions accurately, to help us continually improve our service and in the interests of security, we may monitor and/or record your telephone calls with us.

Our contact information:

Glority LLC

Address: 11/F., Capital Centre, 151 Gloucester Road, WaiChai, Hong Kong.

Contact email: support@picturethisai.com