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Privacy policy

Last updated: 5 September 2025

This English translation is provided for convenience. The German privacy policy remains authoritative.

We respect your privacy. Your photos and videos belong to you. We do not sell your personal data or disclose it to third parties. We respect and comply with the GDPR and all other relevant national regulations. We also follow the OWASP Top Ten. This privacy policy explains how we process your personal data. Please take a few minutes to read it so that you understand how we handle your data and which rights you have. If you have any questions, we will be happy to help.

1. Introduction

This privacy policy explains how Trick22 GmbH (“Trick22”, “we”, “us”, “our”) processes your personal data when:

  • You visit www.picudia.com or another website we provide, including online shops, mini-sites and social-media profiles;
  • You use our software and technology platform, available as the Picudia app and web version, or other services offered through our websites;
  • You apply for a position with us; or
  • We otherwise process your personal data as part of our business activities.

We process your personal data either:

  • As the primary controller when we are directly responsible for your data; or
  • As a processor or service provider when fulfilling an agreement with your company or another institution. In that case, your company or institution is the primary controller.

Our contact details:

Trick22 GmbH
Blauenstraße 11a
79410 Badenweiler
Germany
Email: [email protected]

By using our app, you agree to the provisions of this privacy policy.

2. Applicable law

This privacy policy is based on the requirements of the EU General Data Protection Regulation (GDPR). For users outside the EU, we ensure that data is also processed in accordance with the relevant data-protection standards.

3. Data collection – which personal data do we process?

We collect personal data in different ways:

  1. Data you provide voluntarily, for example when registering or contacting us.
  2. Data collected automatically, including technical information such as your IP address, browser type, operating system or device information.

When you provide personal data, it is identified as either necessary for delivering our services or voluntary. You may contact us at any time if you would like to know which data is required and why.

3.1. When you visit our website

When you visit our website, we automatically collect technical information to ensure its security and operation. This includes:

  • Your IP address;
  • Information about your operating system and browser;
  • Device information;
  • Referring pages.

If you contact us through the website, book a software demonstration, subscribe to a newsletter or download content, we also process your contact details and any other information you provide.

We use cookies and related technologies such as:

  • Essential cookies for website functionality and security;
  • Statistics cookies for improving our services;
  • Marketing cookies for personalising advertising.

Details of the cookies used and the available opt-out choices are provided in our cookie banner.

3.2. When you use our services

When you use Picudia, we process personal data including:

  • Sign-in and profile data for registered users: your email address and other information you provide;
  • Communication data: emails, support requests and similar information;
  • Technical and usage data: details of how you interact with our services;
  • Content: photos and videos you upload or create in the app. These continue to belong to you;
  • Payment references where required for specific features.

Users may delete their own content at any time. Event creators may also remove another user’s content from their events or albums. Deleted content cannot be recovered.

3.4. Advertising in the app (Google AdMob)

In free use (guest access and the Free account) the Picudia app shows advertising. We use Google AdMob, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Users with a Premium subscription see no ads; the advertising SDK is not started for them.

When ads are shown, Google processes data including:

  • IP address (to estimate an approximate location) and technical details about the device;
  • Device identifiers: on Android the resettable advertising ID, on iOS only an app-scoped identifier. On iOS we show non-personalised ads only and do not request tracking permission (App Tracking Transparency);
  • Interactions with ads (impressions, clicks) and diagnostic data of the advertising SDK.

For users in the EEA, the United Kingdom and Switzerland we ask for your consent through the Google User Messaging Platform before the first ad is shown. Without consent only non-personalised ads are served. You can change or withdraw your choice at any time in the app under Settings → Advertising. The legal basis is your consent (Art. 6(1)(a) GDPR) or, for non-personalised ads, our legitimate interest in funding the free service (Art. 6(1)(f) GDPR). Further information is available in Google’s privacy policy at policies.google.com/privacy and at policies.google.com/technologies/ads.

3.3. When you apply for a position with us

When you apply for a position, we process the following personal data:

  • Contact details: name, email address, postal address and telephone number;
  • Professional background and qualifications from your CV, covering letter and other documents;
  • References, where you have agreed that we may obtain them.

We receive this data either directly from you or from publicly accessible sources such as professional networks. It is used solely to assess your application and conduct the recruitment process.

4. For which purposes and on which legal bases do we process personal data?

We collect and process personal data to provide our services, comply with legal obligations and protect our legitimate interests. This includes:

  • Providing and improving our services;
  • Communicating with you, including support requests;
  • Protecting our rights and interests, including fraud prevention;
  • Meeting legal requirements such as accounting obligations.

The legal bases for processing are:

  • Your consent where it is required, for example for newsletters;
  • The necessity of performing a contract;
  • Legal obligations;
  • Legitimate interests, provided these do not override your rights and freedoms.

5. When and how do we share personal data with third parties?

To provide our services, meet legal obligations or protect legitimate interests, we may share your personal data with the following recipients:

  1. IT service providers for hosting, maintenance and support of our IT systems;
  2. Authorities and institutions when we are legally required to do so;
  3. External advisers such as lawyers or auditors where necessary;
  4. Business successors if our company is sold or merged.

International data transfers:

If we transfer personal data to a country outside the EU or EEA, we ensure appropriate safeguards are in place, such as the EU Standard Contractual Clauses.

We never rent or sell your personal data to third parties.

6. Data security

We use technical and organisational measures to protect your personal data from unauthorised access, loss or misuse. These include:

  • Encryption of data at rest and in transit;
  • Access restrictions for authorised employees;
  • Regular security reviews and updates;
  • Following the OWASP Top Ten for secure software development.

7. How long do we retain your personal data?

We retain personal data only for as long as required for the purpose for which it was collected or to meet legal obligations. This means:

  • Data linked to your account is stored while the account is active. It is deleted when you delete the account unless a legal requirement specifies a longer retention period.
  • Users may delete their own content at any time. Deleted content cannot be recovered.
  • Applicant data is generally deleted when recruitment ends unless you consent to longer storage.

8. Which rights do you have in relation to your personal data?

You have the right to:

  1. Request access to the personal data we hold about you and information on how it is processed;
  2. Correct data that is incomplete or inaccurate;
  3. Request deletion of personal data unless statutory retention obligations apply;
  4. Restrict processing of your personal data under certain conditions;
  5. Object to processing based on legitimate interests;
  6. Receive a copy of your personal data in a commonly used format.

To exercise your rights, contact us at [email protected]. We aim to respond to requests as quickly as possible.

Our website may link to third-party websites that we neither operate nor control. We are not responsible for whether or how those third parties comply with data-protection law. Review their privacy policies before providing personal data.

10. Complaints

If you are dissatisfied with how we process your personal data, you have the right to lodge a complaint with the relevant data-protection authority. In Germany, this is the Federal Commissioner for Data Protection and Freedom of Information (BfDI). However, we recommend contacting us first so that we can try to resolve the issue directly.

11. Changes to this privacy policy

We reserve the right to amend this privacy policy at any time. Changes take effect when the updated version is published on our website. We recommend reviewing this policy regularly.

12. Special provisions for the USA

12.1 Children’s data

Our services are not intended for children under 13. If we learn that we have collected personal data from a child under 13, we will delete it without delay. If you believe a child under 13 has provided us with personal data, please contact us at [email protected].