PICLEY

Privacy Policy

Effective date: May 8, 2026 · Last updated: May 9, 2026

This Privacy Policy explains how Picley ("Picley", "we", "our") collects, uses, shares, and protects your information when you use our mobile app and website at getpicley.com (together, the "Service"). Picley is operated as a sole‑developer service based in the United States.

Picley is built around a simple promise: photos guests upload to an event album are used to give those guests their event memories — nothing else. We do not sell your data, we do not show you advertisements, and we do not use your photos to train AI models.

Contents

1. Information we collect 2. How we use information 3. AI processing of photos 4. How information is shared 5. Service providers we use 6. International data transfers 7. How long we keep data 8. Security 9. Your rights and choices 10. California (CCPA/CPRA) rights 11. UK / EU (GDPR) rights 12. Children's privacy 13. Changes to this policy 14. Contact us

1. Information we collect

You give us

We collect automatically

We do not collect

2. How we use information

We use the information described above to:

We do not use your information for advertising, do not "sell" or "share" personal information as those terms are defined under California law, and do not engage in cross‑context behavioural advertising.

3. AI processing of photos

Picley runs every uploaded photo through a server‑side processing pipeline that is essential to the product. This pipeline:

All processing happens on Picley's own servers in the European Union. Your photos, face data, and reel videos are never used to train AI models, are never sent to OpenAI, Anthropic, Google AI, or any other third‑party AI provider, and are never made available to anyone outside the album members.

4. How information is shared

Photos and album content are shared only with people you grant access to:

5. Service providers we use

Picley uses a small set of trusted vendors. Each is contractually limited to processing your data only on Picley's instructions.

ProviderPurposeRegion
SupabaseDatabase and authenticationEU (Frankfurt)
HetznerApplication server hostingEU (Frankfurt)
CloudflareDNS, CDN, DDoS protectionGlobal
SendGrid (Twilio)Transactional email deliveryUSA
Apple Push Notification serviceiOS push notificationsUSA
Firebase Cloud Messaging (Google)Android push notifications and iOS push token routingUSA
Dropbox (optional)Save your album to your own Dropbox, only if you connect itUSA
Google Photos (optional)Save your album to your own Google Photos, only if you connect itUSA

6. International data transfers

Picley primarily stores data in the European Union. Some service providers in section 5 are based in the United States, which means data may be transferred outside the EU/UK. Where that happens, transfers are protected by the European Commission's Standard Contractual Clauses (SCCs) and the providers' own certifications under the EU‑US Data Privacy Framework.

7. How long we keep data

8. Security

We protect your information using industry‑standard measures: TLS 1.2+ in transit, encrypted databases at rest, hashed passwords, principle‑of‑least‑privilege access controls, and audit logging. No system is perfectly secure, however, and we cannot guarantee absolute security. If we discover a breach involving your personal information, we will notify you and the appropriate regulators as required by law.

9. Your rights and choices

Picley provides four levels of deletion, in increasing scope:

Web‑only guests (who joined an album via web link without installing the app) can request deletion of their data by emailing [email protected].

10. California (CCPA / CPRA) rights

If you are a California resident, you have the right to (i) know what personal information we collect, (ii) request deletion, (iii) request correction, and (iv) opt out of the "sale" or "sharing" of your personal information. We do not sell or share your personal information for cross‑context behavioural advertising. To exercise any right, email [email protected]. We will not discriminate against you for exercising these rights. We use no "financial incentives" within the meaning of California law.

11. UK / EU (GDPR) rights

If you are in the UK or EEA, the General Data Protection Regulation gives you rights to access, rectify, erase, restrict, port, and object to processing of your personal data, and to lodge a complaint with your supervisory authority. Our legal bases are:

You can exercise any right by emailing [email protected]. Picley does not have an EU representative because the developer operates as a sole individual; if this changes, this section will be updated.

12. Children's privacy

Picley is not directed to children under 13. We do not knowingly collect personal information from anyone under 13. If you believe a child under 13 has used Picley, please email [email protected] and we will delete the account. In jurisdictions where the digital age of consent is higher (such as the EU, where it can be 16), the same applies.

13. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent change. If we make a material change, we will notify you in the app or by email at least 30 days before it takes effect.

14. Contact us

Privacy questions or requests:
[email protected]

General support:
[email protected]