Last updated: February 2, 2026

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.

This policy tells you what information we collect from you, why we collect it, how we use it, and how we protect that information.



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We may collect Personal Data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for you to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Business, this refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

• CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Kinetic Digital Pty Ltd, 24 Campbell Street, Haymarket NSW 2000. For the purpose of the GDPR, the Company is the Data Controller.

• Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

• Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.

• Country refers to New South Wales, Australia

• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

• GDPR refers to EU General Data Protection Regulation.

• Personal Data is any information that relates to an identified or identifiable individual.
  For the purposes of GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
  For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

• Service refers to Pico Coding.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

• Teacher Account means the teacher (non-student) facing portion of the site with the domain https://teacher.getpico.co.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Learning Data refers to data associated with completing tutorials and other educational content while using our Service.

• Student/User Account means the student facing portion of the site with the domain https://app.getpico.co.

• Website refers to Pico Coding, accessible from https://picocoding.com.

Important Clarifications

• We do not display advertisements of any kind from third party advertisers in our Service.

• Data from Student Accounts and Teacher Accounts is not tracked for advertising purposes or on other third-party sites or services.

• We do not create or use data from Student Accounts or Teacher Accounts for personalized advertisement.

Children’s Privacy is Our Priority

We do not sell Personal Data. We are committed to protecting the privacy of students under the age of 13 (each, a “Child” and collectively, “Children”) who visit and use our Service.

We will not perform targeted advertising of Students and will not share Student Account data with any third-party for the purpose of targeted advertising.

Parents and Teachers are urged to instruct children to never give out their full legal names, address, phone numbers, or any other Personal Data while using our Service.

Student Accounts

We do not directly collect personally identifiable information from anyone under the age of 13. We ask for some information (which is non-personal information, as defined by COPPA).

We collect:

• Username or alias, we need this to create your account. We don't use your username to identify you outside of our Service.

• For Student Accounts linked to Teacher Accounts, we ask for first name and last initial for teachers to adequately administer their classrooms.

• Your password, we need this to log you in to your account and provide the Service.

Students under 13 are encouraged to provide a parent or guardian's email address for account recovery and integrity, but are not required to do so to create or maintain an account.

Teacher Accounts

For Teacher Accounts we collect:

• Email address, first and last name, and educational institute where you work

• Your password, we need this to log you in to your account and provide the Service

• Year level and classroom name

• First name and last initial of the students in your classroom(s)

Your decision to provide us with information is voluntary, and we use the information to allow you to take advantage of all of the Service’s features.

Collecting and Using Your Personal Data

Types of Data Collected

Our Service collects Personal Data relevant to the creation and management of both Teacher Accounts and Student Accounts.

Email addresses

We collect email addresses for Teacher Accounts so:

• You can login to your account with a unique identifier

• We can notify you of important information (account management and recovery)

First name and last name

We collect first and last name for Teacher Accounts so:

• We can personalize communications and display names appropriately within the Service

• Teachers can identify account holders and manage classrooms and students within the Service

First name and last initial

We collect first and last initial for Student Accounts so:

• Teachers can identify and manage students in their classrooms while minimising the collection of personal identifiers for students

• Teachers can monitor and assess the progress of students in their classrooms

• Teachers can offer help to students while completing educational content in our Service

• Students’ privacy is protected by only using minimal information necessary for classroom management

Education Institution 

We collect school name or name of educational institution for Teacher Accounts so:

• We can verify that a Teacher Account is from a legitimate educational institution

• Teacher Accounts can create classrooms and link Student Accounts under that institution

Year level and classroom name

We collect the school year and classroom name to facilitate classroom management and effective delivery of educational content as part of our Service.

Uses of Your Personal Data

The Company use Personal Data for the following purposes:

• To manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.

• To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To manage your requests: To attend and manage your requests to us.

Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Delete Your Personal Data

You have the right to delete or request that we assist in deleting the Personal Data that we have collected about you.

You may update, amend, or delete your information at any time by signing in to your Account, if you have one, and visiting the account settings section that allows you to manage your Personal Data. You may also contact us to request access to, correct, or delete any Personal Data that you have provided to us.

How long we keep your Personal Data

We retain your Personal Data only for as long as necessary to provide our Service, comply with legal obligations, resolve disputes, and enforce our agreements. Once your Personal Data is no longer required for these purposes, it is securely deleted or de-identified.

Learning Data

The Service collects Learning Data to support and enhance the educational experience for students. Learning Data includes information such as saved code, learning progress, badges, and completed activities. This data helps us provide students with a consistent learning experience, track progress over time, and offer meaningful feedback within the platform.

The learning data we collect does not include Personal Data. It does not contain names, email addresses, or other information that could identify an individual student. Learning Data is used solely to support educational outcomes, improve the platform, and allow teachers to monitor classroom learning trends in an aggregated form.

Accidental storage of Personal Data

You may accidentally provide your Personal Data as part of your learning process, for example by including your name or email address as a variable name/value in code submissions as part of our Learning Data.

The Service strongly discourages users from including Personal Data in this way because Learning Data is stored and treated separately, as described in this Privacy Policy. You acknowledge that if you include Personal Data within Learning Data, the Service is not responsible for identifying, obfuscating, or removing that information unless you request that we do so.

Usage Data

We collect Usage Data to understand how our Service is used and to improve its functionality, performance, and educational effectiveness. Usage Data includes information such as features accessed, session duration, and actions taken within the platform. This data does not include Personal Data, as we do not collect geolocation information or IP addresses. Usage Data is analysed in aggregate to help us enhance the Service and provide a better learning experience for students and teachers.

Disclosure of your Personal Data

The Service discloses Personal Data only in very limited circumstances and, except where required by law, only with your express consent.

Law enforcement

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

Where permitted by law, we will seek to notify affected Users or schools before disclosing Personal Data in response to legal requests.

Detailed Information on Data Processing

Personal Data

We may use third-party Service providers, known as subprocessors, to securely store and manage Personal Data. These subprocessors help us ensure reliable storage, backup, and access control for account information.

AWS

AWS (Amazon Web Services) is used to securely store email addresses for Teacher Accounts. Data is hosted in the US East region. AWS provides robust security measures, including encryption, access controls, and monitoring, to protect Personal Data. https://aws.amazon.com/privacy/

MongoDB

MongoDB is used to securely store first names and last names for Teacher and first name and last initials of Student Accounts. Data is hosted in the US East region. MongoDB ensures that Personal Data is protected with strong security protocols and reliable access management. https://www.mongodb.com/legal/privacy/privacy-policy

Usage Data

We may use third-party Service providers, known as subprocessors, to monitor and analyze the use of our Service. These subprocessors help us improve platform performance, understand user interactions, and enhance the overall learning experience.

Mixpanel

Mixpanel is used to analyse user interactions and engagement within the Service. It helps us track feature usage, session flows, and overall trends as relates to how users interact with our Service. We do not collect Personal Data such as geolocation or IP addresses. Our implementation of Mixpanel only processes Usage Data and does not collect Personal Data. https://mixpanel.com/legal/privacy-policy/

Sentry

Sentry is used to monitor errors within the Service. It helps our development team identify and fix bugs quickly. Sentry alerts our development team by sending reports of unexpected bugs and errors within the Service. Our implementation of Sentry does not collect Personal Data such as geolocation information, user identifiers or IP addresses. For more information on Sentry https://sentry.io/privacy/

Google Analytics

Google Analytics helps us understand how the Service is used at an aggregate level, including pages accessed and feature engagement. We configure it to exclude Personal Data, including IP addresses, and only collect anonymised Usage Data. https://policies.google.com/technologies/partner-sites

Learning Data

We may use third-party Service providers, known as subprocessors, to securely store and manage Learning Data. These subprocessors help us provide a consistent learning experience, track progress, and support classroom management.

MongoDB

MongoDB is used to securely store Learning Data, including saved code, learning progress, and completed activities. Data is hosted in the US East region. MongoDB provides robust security measures, including encryption, access controls, and monitoring, to protect Learning Data. https://www.mongodb.com/legal/privacy/privacy-policy

OpenAI

We use OpenAI to provide automated feedback on students’ code submissions within the Pico platform. There is no chat functionality available in our Service. No Personal Data is sent to OpenAI, and the feedback feature with the Service only uses Learning Data such as saved code. Additionally, none of this data is used by OpenAI for AI training purposes. OpenAI acts solely as a service provider to improve the learning experience without compromising student privacy. https://openai.com/policies/row-privacy-policy/

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Stripe

Stripe is used as our payment processor. It handles payment information such as credit or debit card details when users make purchases. Stripe processes this information in accordance with strict security standards and PCI compliance. We do not store full payment card details on our systems; all sensitive payment data is managed directly by Stripe. https://stripe.com/us/privacy

Use of artificial intelligence

The Service uses artificial intelligence systems solely to support learning by evaluating student code submissions, which form part of the Service’s Learning Data, and by providing automated feedback. The Service does not provide open-ended chat or conversational AI functionality. AI is limited to predefined educational workflows related to programming tasks.

How AI Is Used

AI systems are used only to analyse Learning Data, including code submitted by students as part of learning activities. This analysis is designed to identify errors, assess whether tasks have been completed correctly, and generate instructional feedback to help students improve their understanding of programming concepts.

AI is not used to make decisions about student behaviour, grading for formal assessment, or any other non-educational purpose.

Personal Data and AI

No Personal Data is sent to, processed by, or stored within AI systems. The Service is designed to prevent Personal Data from being included in requests sent to AI providers. Student identifiers such as names, email addresses, or account details are excluded from AI processing.

We implement technical and organisational safeguards to ensure that AI interactions are restricted to Learning Data only, such as restricting the ability to directly prompt the AI system and providing pre-determined context.

Safeguards and Limitations

The Service includes controls to prevent misuse of AI systems, including protections designed to avoid so-called “jailbreak” attempts or the transmission of unauthorised data to AI providers. AI access is limited to tightly controlled functions within the Service and cannot be used to submit free-form prompts.

AI-generated feedback is intended to assist learning and may not always be perfect or complete. Teachers and parents remain responsible for supervising student learning and assessing educational outcomes.

Storage and Training

AI systems used by the Service do not retain or store Personal Data. Learning Data submitted for code evaluation is not used for AI training purposes.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given your consent for processing Personal Data for one or more specific purposes.

• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

• Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.

• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

• Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.

• Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.

• Object to processing of Your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for Our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

• Request erasure of Your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.

• Request the transfer of Your Personal Data. We will provide to you, or to a third-party you have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Australia and New Zealand Privacy Rights

Australian Privacy Act 1988 (Cth)

If You are located in Australia, We collect, use, store and disclose Personal Data in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This includes taking reasonable steps to:

• only collect Personal Data that is reasonably necessary for the operation of the Service;

• ensure Personal Data is accurate, up to date and complete;

• protect Personal Data from misuse, interference and loss, and from unauthorised access, modification or disclosure; and

• delete or de-identify Personal Data when it is no longer required, subject to legal or contractual obligations.

Access and Correction

You may request access to the Personal Data that we hold about you, or request that We correct inaccurate, outdated, incomplete or misleading information.

Requests can be made using the contact details in the “Contact Us” section below.

We may need to verify your identity before responding. We will respond to access or correction requests within a reasonable period and in accordance with the Privacy Act.

In some circumstances, we may refuse access or correction as permitted by law. If this occurs, We will provide written reasons where required and explain the mechanisms available to complain about the refusal.

Complaints and Privacy Concerns

If you believe that We have interfered with your privacy or breached the Australian Privacy Principles, You may lodge a complaint with us using the contact details in the “Contact Us” section below.

Please include:

• Your name and contact details;

• details of the issue; and

• any relevant supporting information.

We will:

• acknowledge receipt of your complaint within a reasonable time;

• investigate the matter; and

• respond in writing with the outcome and any proposed resolution as soon as practicable.

If you are not satisfied with our response, You may make a complaint to the Office of the Australian Information Commissioner (OAIC).

New Zealand Privacy Act 2020

If You are located in New Zealand, We collect, use, store and disclose Personal Data in accordance with the Privacy Act 2020 and the Information Privacy Principles (IPPs).

This includes taking reasonable steps to:

• only collect Personal Data that is reasonably necessary to provide and operate the Service;

• limit the Personal Data collected about Students, including by collecting only a Student’s first name and last initial when accounts are created through schools;

• ensure Personal Data is accurate, up to date and complete;

• protect Personal Data from misuse, interference and loss, and from unauthorised access, modification or disclosure; and

• delete or de-identify Personal Data when it is no longer required, subject to legal, regulatory, or contractual obligations.

Access and Correction

You may request access to the Personal Data that we hold about you and request correction of inaccurate, outdated, incomplete, or misleading information.

Requests can be made using the contact details in the “Contact Us” section below.

We may need to verify your identity before responding. We will respond to access or correction requests within the timeframes required by the Privacy Act 2020.

If we refuse a request, we will provide written reasons and advise you of your right to complain to the New Zealand Office of the Privacy Commissioner.

Complaints and Privacy Concerns (New Zealand)

If you believe that we have breached the Privacy Act 2020 or interfered with your privacy, you may lodge a complaint with us using the contact details in the “Contact Us” section below so we can attempt to resolve the issue.

We will:

• acknowledge receipt of your complaint within a reasonable time;

• investigate the matter; and

• respond in writing with the outcome and any proposed resolution as soon as practicable.

If you are not satisfied with our response, You may make a complaint to the Office of the Privacy Commissioner in New Zealand.

CCPA/CPRA Privacy Notice

This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

• Category A: Identifiers.
  Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
  Collected: Yes.

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
  Collected: Yes.

• Category C: Protected classification characteristics under California or federal law.
  Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  Collected: No.

• Category D: Commercial information.
  Examples: Records and history of products or services purchased or considered.
  Collected: Yes.

• Category E: Biometric information.
  Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
  Collected: No.

• Category F: Internet or other similar network activity.
  Examples: Interaction with our Service or advertisement.
  Collected: Yes.

• Category G: Geolocation data.
  Examples: Approximate physical location.
  Collected: No.

• Category H: Sensory data.
  Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
  Collected: No.

• Category I: Professional or employment-related information.
  Examples: Current or past job history or performance evaluations.
  Collected: No.

• Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
  Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
  Collected: No.

• Category K: Inferences drawn from other personal information.
  Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  Collected: No.

• Category L: Sensitive personal information.
  Examples: Account login and password information, geolocation data.
  Collected: Yes.

Under CCPA/CPRA, personal information does not include:

• Publicly available information from government records

• Deidentified or aggregated consumer information

• Information excluded from the CCPA/CPRA's scope, such as:

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from the forms you complete on our Service, preferences you express or provide through our Service, or from your purchases on our Service.

• Indirectly from you. For example, from observing your activity on our Service.

• Automatically from you. For example, through cookies we or our Service Providers set on your Device as you navigate through our Service.

• From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to you.

Use of Personal Information

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:

• To operate our Service and provide you with our Service.

• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Service.

• To fulfill or meet the reason you provided the information. For example, if you share Your contact information to ask a question about our Service, We will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, We will use that information to process your payment and facilitate delivery.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your personal information or as otherwise set forth in the CCPA/CPRA.

• For internal administrative and auditing purposes.

• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

• Other one-time uses.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Sale of Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use your personal information for the business purposes described in Our Privacy Policy for activities such as analytics.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service. We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

• The right to know/access. Under CCPA/CPRA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, We will disclose to you:

  • The categories of personal information we collected about you

  • The categories of sources for the personal information We collected about you

  • Our business or commercial purposes for collecting or selling that personal information

  • The categories of third parties with whom we share that personal information

  • The specific pieces of personal information we collected about you

  • If we sold your personal information or disclosed your personal information for a business purpose, We will disclose to you:

    • The categories of personal information categories sold

    • The categories of personal information categories disclosed

• The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct us to not sell your personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact us.

• The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) your personal information, unless an exception applies.

• The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about you, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact us.

• The right to delete Personal Data. You have the right to request the deletion of your Personal Data under certain circumstances, subject to certain exceptions. Once we receive and confirm your request, We will delete (and direct our Service Providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:

  • Denying goods or services to you

  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

  • Providing a different level or quality of goods or services to you

  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of your rights under the CCPA/CPRA, and if you are a California resident, You can contact us:

• By email: info@getpico.co

Only you, or a person registered with the California Secretary of State that you authorize to act on Your behalf, may make a verifiable request related to your personal information.

Your request to us must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with the required information if we cannot:

• Verify your identity or authority to make the request

• And confirm that the personal information relates to you

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt-out, please contact us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

Website

If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell My Personal Information" buttons listed on the Service to review your privacy preferences and opt out of cookies and other technologies that we may use. Please note that you will need to opt out from each browser that you use to access the Service.

Additionally, you can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA's opt-out platform http://www.youronlinechoices.com/

• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Limit the Use or Disclosure of My Sensitive Personal Information

If you are a California resident, you have the right to limit the use and disclosure of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how we use your personal information, please see the "Use of Your Personal Data" section or contact us.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with Your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact us:

• By email: info@getpico.co