Pico Photos • Legal

Pico Photos – Privacy Policy

Last Updated: 18 Jan, 2026 This Privacy Policy explains how Pico Photos (“Service”), operated by Fiber@Home Ltd., Bangladesh (“Company”, “we”, “our”, “us”), collects, uses, discloses, stores, and protects personal data when you use our mobile applications, websites, and related services. This Privacy Policy is designed to comply with: • Bangladesh Personal Data Protection Ordinance (PDPO) 2025 • EU General Data Protection Regulation (GDPR – Regulation (EU) 2016/679) This policy should be read together with our Terms & Conditions and Refund & Return Policy.

1. Data Controller & Contact Details

Data Controller: Fiber@Home Ltd., Bangladesh Email: privacy@picophotos.com Where required by law, a Data Protection Officer (DPO) will be appointed and contact details will be published.

2. Scope & Applicability

This Privacy Policy applies to all users of Pico Photos, including free and paid subscribers, across Android, iOS, and web platforms.

3. Categories of Personal Data Collected

We may collect the following categories of personal data: A. Account Information • Name (optional) • Email address • Phone number (optional) • Profile photo (optional) B. User Content • Photos and videos uploaded • Associated metadata (timestamps, device info, location if enabled) C. Technical & Usage Data • IP address • Device identifiers • App usage logs • Crash reports D. Payment Data • Transaction references and subscription status (Note: Full payment details are processed and stored by authorized payment gateways.) E. AI-Generated Data • Face clusters • Object and scene tags • Search indexes

We process personal data on the following legal bases: • Consent (account creation, optional features) • Contractual necessity (service delivery) • Legal obligation (regulatory compliance) • Legitimate interests (security, fraud prevention, service improvement)

5. Purpose of Processing

Personal data is processed to: • Provide secure storage, backup, and retrieval • Enable AI-assisted organization and search • Manage subscriptions and billing • Communicate service-related information • Ensure platform security and reliability • Comply with legal and regulatory obligations

6. Data Storage, Residency & Transfers

All user data is stored within Bangladesh in controlled data center environments. Cross-border data transfers are not performed unless legally required or explicitly consented to, and appropriate safeguards will be applied.

7. Data Retention

Personal data is retained for as long as the account remains active. Upon account deletion: • Data enters a limited retention period (up to 30 days) • Thereafter, data is permanently erased from active systems and backups

We do not sell personal data. Data may be shared only with: • Payment processors (billing only) • Infrastructure and hosting partners • Legal authorities where required by law • Authorized internal personnel under strict access controls

You have the right to: • Access your personal data • Rectify inaccurate data • Request deletion (right to erasure) • Restrict or object to processing • Data portability • Withdraw consent at any time • Lodge a complaint with a data protection authority

10. Children’s Data

Pico Photos is not intended for users under 18 without parental consent. We do not knowingly collect children’s data unlawfully.

11. Security Measures

We implement technical and organizational measures including: • AES-256 encryption at rest • TLS 1.3 encryption in transit • Role-based access control (RBAC) • Logging and monitoring • Regular security reviews

12. Personal Data Breaches

In the event of a personal data breach, we will assess risk and notify affected users and regulators in accordance with PDPO and GDPR requirements.

13. Automated Processing & AI

AI features assist with photo organization and search only. No automated decisions produce legal or similarly significant effects on users.

14. Cookies & Tracking

We use essential cookies for authentication and security. Analytics technologies may be used to improve service performance. Users can manage cookies through application or browser settings.

15. Policy Updates

We may update this Privacy Policy periodically. Material changes will be communicated through the Service. Continued use constitutes acceptance of the updated policy.

16. Contact & Complaints

For privacy-related inquiries or requests: Email: privacy@picophotos.com You also have the right to lodge a complaint with the relevant supervisory authority.