Effective as of September 05, 2024
This Privacy Policy describes how Pickle, Inc. (“Pickle,” “we”, “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable our website, social media pages, our marketing activities, and other activities described in this Privacy Policy (collectively, the “Service”)). Pickle may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.
Pickle provides an AI video cloning platform that enables users to generate many personalized videos of themselves for their target audience. This Privacy Policy does not apply to information that we process on behalf of our business customers (such as businesses and other organizations) while providing the Pickle services to them. Our use of information that we process on behalf of our business customers may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that enterprise customer.
The Service is designed for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family, or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as business representatives of the relevant enterprise customer and not their individual capacities.
Notice to European Users: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.
Index
Personal Information We Collect
How We Use Your Personal Information
How We Share Your Personal Information
Your Choices
Other Sites and Services
Biometric Data Policy
Security
International Data Transfer
Children
Changes to this Privacy Policy
How to Contact Us
Notice to European Users
1. Personal Information We Collect
Information You Provide to Us:
Personal information you may provide to us through the Service or otherwise includes:
• Contact Data: Such as your first and last name, email address, billing and mailing addresses, company name, company domain name, professional title, and phone number.
• Demographic Data: Such as your city, state, country of residence, postal code, and age.
• Profile Data: Such as the username and password that you may set to establish an online account on the Service and any other information that you add to your account profile.
• Communications Data: Based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Job Application Data: Such as professional credentials and skills, educational and work history, LinkedIn profile page, personal website, authorization to work in the U.S., immigration status, criminal history, and other information that may be included on a resume or curriculum vitae as well as in a cover letter. This may also include diversity information that you voluntarily provide.
• Transactional Data: Such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
• Marketing Data: Such as your preferences for receiving our marketing communications and details about your engagement with them.
• User Content Data: Such as the initial audio and video samples you provide (which may be considered “biometric data” as described further in the Biometric Data Policy below), the AI-generated videos you create through the Service, the business logo, contact information, and other distribution information you provide for any AI-generated videos, as well as any comments, questions, messages, works of authorship, and other files, content, or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Payment Data: Needed to complete transactions, including payment card information or bank account numbers.
• Other Data: Not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Information from Other Sources:
We may combine personal information we receive from you with personal information we obtain from other sources, such as:
• Public Sources: Such as government agencies, public records, social media platforms, and other publicly available sources.
• Data Providers: Such as information services and data licensors that provide demographic and other information.
• Affiliate Partners: Such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
• Marketing Partners: Such as joint marketing partners and event co-sponsors.
• Third-Party Services: Such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture, and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
Automatic Data Collection:
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:
• Device Data: Such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online Activity Data: Such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Location Data: When you authorize the Service to access your device’s location.
• Communication Interaction Data: Such as your interactions with our email, text, or other communications (e.g., whether you open and/or forward emails) – we may do this through the use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies and Similar Technologies:
Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.
Please note that the language provided above is intended to guide you in updating your privacy policy to reflect the use of cookies and similar technologies by your online data partners or vendors. It is important to clarify that we, as your service provider, do not directly contact individuals on your behalf based on this data collection. The recommended text is to ensure transparency with your website visitors, indicating that they may be contacted by you or your service providers based on the information collected through these technologies. We encourage responsible and compliant use of such data in accordance with privacy laws and best practices.
Data About Others:
We may offer features that help users invite their colleagues or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.
2. How We Use Your Personal Information
Service Delivery and Operations:
We may use your personal information to:
• Provide, operate, and improve the Service and our business;
• Personalize the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• Establish and maintain your user profile on the Service;
• Facilitate your invitations to colleagues or contacts who you want to invite to join the Service;
• Enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• Communicate with you about the Service, including by sending service-related announcements, updates, security alerts, and support and administrative messages;
• Understand your needs and interests, and personalize your experience with the Service and our communications; and
• Provide support for the Service, and respond to your requests, questions, and feedback.
Research and Development:
We may use your personal information for research and development purposes, including to analyze and improve the Service and our business (e.g., by training our proprietary artificial intelligence technology).
Marketing and Advertising:
We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
• Direct Marketing: We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-Based Advertising: Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications, and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice.
To Manage Our Recruiting and Process Employment Applications:
We may use personal information, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.
Compliance and Protection:
We may use your personal information to:
• Comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas, investigations, or requests from government authorities;
• Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• Enforce the terms and conditions that govern the Service; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
Service Improvement and Analytics:
We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
With Your Consent:
In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To Create Anonymous, Aggregated or De-Identified Data:
We may create anonymous, aggregated, or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated, or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated, or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
3. How We Share Your Personal Information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliates:
Our affiliated companies, for purposes consistent with this Privacy Policy.
Service Providers:
Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research, and website analytics).
Payment Processors:
Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.
Advertising Partners:
Third-party advertising companies for the interest-based advertising purposes described above.
Third Parties Designated by You:
We may share your personal data with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested.
Business and Marketing Partners:
Third parties with whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Linked Third-Party Services:
If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
Professional Advisors:
Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
Authorities and Others:
Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business Transferees:
We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Pickle, financing of Pickle, public stock offerings, or the sale, transfer, or merger of all or part of our business, assets, or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Pickle as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
4. Your Choices
In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.
Access or Update Your Information:
If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account or by contacting us at contact@getpickle.ai.
Opt-Out of Communications:
You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies:
For information about cookies employed by the Service and how to control them, see our Cookie Notice.
Do Not Track:
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to Provide Information:
We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked Third-Party Platforms:
If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
Close Your Account:
You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.
5. Other Sites and Services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.
6. Biometric Data Policy for U.S. Users
Pickle collects and processes information that may be considered “biometric data” under certain laws from individuals who use our Service. By accessing our Services and voluntarily providing user content data, including such “biometric data,” you are providing your consent to our collection, use, and disclosure of your information that may be considered “biometric data” as described in this Biometric Data Policy.
Biometric Data:
Biometric data is identifying information related to your biometric characteristics that may be used to identify you. Voiceprints (in audio samples you provide) and facial geometry (included in video samples you provide) are examples of common forms of biometric data that may be included in the user content data you provide in order to use the Service. Pickle collects and uses certain information related to your physical characteristics, specifically included in the audio and video samples you upload in order to provide our Services.
Biometric Data Collection:
When you sign up for a Pickle account to use our Services, you may provide certain biometric data. For example, to use the Services, you may provide several audio and video recordings that include physical characteristics such as your voice and facial geometry. You may decline to provide your biometric data. However, if you decline to provide biometric data, certain Services that require the use of such data will become unavailable to you. You may also experience a loss of functionality of some or all of the Services that we provide.
Use of Biometric Data:
Pickle will create anonymized data to train AI models, provide the Services (e.g., make requested custom videos), and for compliance and protection purposes (as outlined above).
Security of Biometric Data:
Pickle takes data security seriously and has implemented data security measures designed to secure biometric data as described in the Security section, below.
Biometric Data Sharing:
Pickle may work with certain third parties to provide the Services to you, but only as necessary to provide you with such Services. Pickle has agreements with third parties that will receive your biometric data where the third party has a legitimate need to deliver the Services to you. These third parties are contractually obligated to protect your biometric data. In certain specific instances, we may disclose biometric data in cases where such disclosure is required by state or federal law, or municipal ordinance, or when required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
Retention:
For any biometric data that we collect from you, we will retain such biometric data only until (a) the initial purposes for which we collected your biometric data have been satisfied (e.g., to provide our Services), or (b) one year following your last interaction with us (e.g., the last time you used our Service), whichever comes first. After such occurrence, we will delete your biometric data in accordance with applicable law. You may also request that we delete your biometric data by notifying us at contact@getpickle.ai or closing your account.
7. Security
We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
8. International Data Transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in Europe should read the important information provided below about the transfer of personal information outside of Europe.
9. Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
10. Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment that the modified Privacy Policy applies to your interactions with the Service and our business.
11. How to Contact Us
• Email: contact@getpickle.ai
12. Notice to European Users
General:
Where this Notice to European users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).
Personal Information:
References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”). Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect”.
Controller:
Pickle is the “controller” in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.
