Private Policy

We respect your privacy. Your photos and videos belong to you. We do not sell your personal data or share it with third parties. We adhere to the GDPR and all other relevant national regulations. Furthermore, we align our practices with 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 fully understand how we handle your data and what rights you have. If you have any questions, we are happy to assist.

1. Introduction

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

•You visit our website at www.Picudia.com or other websites we provide (including online shops, mini-sites, and social media presences);
•You use our software/technology platform (available as an app and web version, “Picudia”) or other services offered through our websites;
•You apply for a job with us; or
•We process your personal data in other ways as part of our business activities.


We process your personal data either:
•As the primary data controller, when we are directly responsible for your data; or
•As a data processor/service provider, when fulfilling a contract with your company or another organization. In this case, your company or organization is the primary data controller.

Our contact details:

Trick22 GmbH
Blauenstraße 11a
79410 Badenweiler
Germany
Email: datenschutz@picudia.com

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 their data is also processed in compliance with relevant data protection standards.

3. Data Collection – What Personal Data Do We Process?

We collect personal data in various ways:

  1. Data you provide voluntarily:
    •For example, when you register or contact us.
  2. Data collected automatically:
    •This includes technical information such as IP address, browser type, operating system, or device information.
    If you provide us with personal data, it will either be marked as necessary for providing our services or as optional. Feel free to contact us if you have questions about what data is required and why.


3.1. When You Visit Our Website

When you visit our website, we automatically collect technical information to ensure the security and functionality of the website. This includes:

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

If you contact us via the website, book a software demo, subscribe to our newsletter, or download content, we also process your contact information and other data you provide.


We use cookies and other technologies such as:

Essential Cookies: For the functionality and security of our website.
Analytics Cookies: To improve our services.
Marketing Cookies: To personalize advertising.
Details about the cookies we use and how to disable them can be found in our cookie banner.

 

3.2. When You Use Our Services

When using Picudia, we process the following personal data:

Login/Profile Data (registered users only): Your email address and other data you provide.
Communication Data: Emails, support requests, and similar information.
Technical and Usage Data: Details about your interactions with our services.
Content: Photos and videos you upload or create within the app. These remain your property.
Payment References: If required for certain features.
Users can delete their own content at any time. Event creators can also remove content from their events or albums. Deleted content cannot be restored.

 

3.3. When You Apply for a Job with Us

If you apply for a job with us, we process the following personal data:
Contact Information: Name, email address, address, phone number;
Professional Background and Qualifications: Information from your resume, cover letter, and other documents;
References: If you have consented to reference checks.
This data is either provided by you or collected from publicly available sources (e.g., professional networks). We use it exclusively to evaluate your application and conduct the recruitment process.

 

4. Why and on What Legal Basis Do We Process Your Personal Data?

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

•Providing and improving our services;
•Communicating with you, e.g., regarding support requests;
•Protecting our rights and interests, e.g., preventing fraud;
•Complying with legal obligations, such as accounting requirements.

Legal bases for processing include:
•Your consent, when required (e.g., for newsletters);
•Necessity for contract performance;
•Legal obligations;
•Legitimate interests, provided your rights and freedoms are not affected.

5. When and How Do We Share Your Personal Data with Third Parties?

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

1.IT Service Providers: For hosting, maintenance, and support of our IT systems.
2.Authorities and Institutions: When legally required.
3.External Consultants: Such as lawyers or auditors, when necessary.
4.Corporate Successors: In the event of a company sale or merger.

International Data Transfers:

If we transfer personal data to countries outside the EU or EEA, we ensure appropriate safeguards, such as EU standard contractual clauses.
We do not rent or sell your personal data to third parties.

6. Data Security

We implement technical and organizational measures to protect your personal data from unauthorized access, loss, or misuse. This includes:
•Encrypting data at rest and during transmission;
•Access restrictions for authorized personnel;
•Regular security audits and updates;
•Aligning with OWASP Top Ten guidelines for secure software development.

7. How Long Do We Retain Your Personal Data?

We retain your personal data only as long as necessary for the purposes for which it was collected or to comply with legal obligations. For example:
Account Data: Retained as long as your account is active. Once your account is deleted, the associated data will be removed unless legal requirements mandate a longer retention period.
Content Data: Users can delete their content at any time. Once deleted, it cannot be restored.
Applicant Data: Typically deleted after the recruitment process, unless you have agreed to a longer retention period.

8. What Are Your Rights Regarding Your Personal Data?

You have the right to:

1.Access: Request information about the personal data we store and process about you.
2.Rectification: Correct your data if it is incomplete or inaccurate.
3.Erasure: Request the deletion of your personal data, unless legal obligations require otherwise.
4.Restriction: Restrict the processing of your data under certain conditions.
5.Objection: Object to the processing of your data for legitimate interests.
6.Data Portability: Receive a copy of your personal data in a commonly used format.

To exercise your rights, please contact us at datenschutz@picudia.com. We strive to handle requests promptly.

9. Links to Other Websites

Our website may contain links to third-party websites not operated or controlled by us. We are not responsible for how these third parties comply with data protection laws. Please review their privacy policies before sharing personal data.

10. Complaints

If you are dissatisfied with how we process your personal data, you have the right to lodge a complaint with a 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 to resolve the issue directly.

11. Changes to This Privacy Policy

We reserve the right to update this privacy policy at any time. Changes become effective upon posting the updated version on our website. We encourage you to review this privacy policy regularly.

12. Special Provisions for the U.S.

12.1. Children’s Data

Our services are not directed at children under 13 years of age. If we learn that we have collected personal data from a child under 13, we will delete it immediately. If you believe a child under 13 has provided us with personal data, please contact us at datenschutz@picudia.com.