Privacy Policy

Last updated: June 22, 2026

We value the privacy of our users and are committed to protecting personal data in accordance with the Brazilian General Data Protection Law (Law No. 13,709/2018 - LGPD).

This Privacy Policy clearly and transparently describes how Pickley processes and protects the information necessary for its operation. By using the Pickley application, you acknowledge and agree to this policy, which explains how your information and data may be used.

When you use Pickley, certain technical information required for the operation of the application may be processed as described in this policy.

1. What information does Pickley collect:

1.1. Device Data:

• advertising identifiers;
• unique device identifiers;
• device language;
• device region (not GPS-based);
• operating system version;
• device model and version;
• number of application usage sessions;

1.2. Photo Library

Pickley requests access to the device's photo library exclusively to allow users to view, organize, and perform actions on their photographs. User photos, videos, and any other media remain stored locally on the device and are not collected, transmitted, stored, or processed by Pickley servers. The access granted by the user is used solely to enable the application's features.

2. Purpose of Data Collection and Use:

We value user privacy and therefore all data and information collected by the Pickley application are and will be treated as confidential. Such information will only be used for the purposes described herein and previously authorized, with the objective of continuously improving the user experience.

Under this policy, your data may be used for:

• Advertising: This application uses Google AdMob advertising services to display advertisements. AdMob may collect and process certain information, including device identifiers, IP addresses, application usage information, and other data necessary to provide, measure, and improve displayed advertisements. Google and its partners may use this information to display personalized or non-personalized advertisements according to the user's settings and permissions. For more information about how Google processes personal data, please consult its Privacy Policy.


• Telemetry: Pickley and/or its service providers may use technical and non-directly identifiable device identifiers for statistical, analytical, diagnostic, and application improvement purposes. These identifiers are not used to directly identify the user.
  
  
  • The information collected may include:
  • advertising identifiers;
  • unique device identifiers;
  • device language;
  • configured device region;
  • operating system version;
  • device model and type;
  • number of application usage sessions;
  • information related to application performance and stability.

This information is used in aggregate form and limited to the minimum necessary for the purposes described in this policy, and is not used by Pickley to individually identify users.

3. Information Sharing:

We may share aggregated and non-individualized data with service providers required for the operation of the application.

In exceptional circumstances, and whenever legally required, we may share data and information strictly requested to comply with legal obligations.

Such sharing occurs, whenever possible:

• in anonymized form;
• limited to the minimum necessary.

We may also share information:

• when required by law;
• to protect our legal rights.

We do not sell, rent, or commercially distribute your personal data.

3.1. Service Providers:

List of service providers, purposes of data sharing, legal bases, and links to their respective privacy policies:

4. Legal Bases for Processing:

Data processing is carried out based on the following legal grounds:

• Legitimate Interest: for the continuous improvement of the application.
• Consent: when required by law or when the user expressly authorizes specific data processing.

5. International Data Transfers:

Your data may be transferred to and stored on servers located inside or outside Brazil, particularly in the United States, where third-party service providers may be located. We recommend that you review the privacy policies listed in section 3.1 to better understand how these providers process your data.

6. Updates to this Policy:

We reserve the right to modify this policy whenever necessary in order to provide greater security, convenience, and continuous improvements to your experience. For your convenience, the date of the latest update is indicated at the beginning of this document. If relevant changes require new authorizations, a new privacy policy will be published and your consent may be requested again through notices within the application.

7. Applicable Law:

This document shall be governed by and interpreted in accordance with the laws of the Federative Republic of Brazil.

8. Data Subject Rights:

Under the Brazilian General Data Protection Law (LGPD), users may request information regarding the processing of their personal data, including:

• confirmation of the existence of processing activities;
• access to available information;
• correction of incomplete, inaccurate, or outdated data;
• withdrawal of consent, when applicable;
• information regarding data sharing with third parties.

Since Pickley does not require registration and does not maintain user accounts, certain rights may not be applicable or technically feasible with respect to aggregated and non-identifiable statistical information used by the application.

9. Data Security:

We adopt technical and organizational security measures, including:

• access control;
• encryption;
• secure storage.

We also select service providers that maintain appropriate data protection standards.

10. Data Retention and Deletion:

Technical and statistical information collected by Pickley is retained only for the period necessary to analyze performance, stability, and improve the application, or as otherwise required by legal obligations.

Pickley does not store photographs, videos, or other personal user content on its own servers, does not require registration, and does not maintain user accounts and/or profiles.

11. Data Controller:

The controller of personal data processed by Pickley is:

Rafael Bitencourt
contato@rafaelbitencourt.dev.br