1. Definitions and Interpretation
1.1 Definitions
In this Privacy Policy, the following terms have the meanings set out below unless the
context indicates otherwise.
Account means the registered Pictruly account created by a user to access and use the
Services.
Applicable Law means any law, regulation, rule, code, ordinance or legally binding
requirement that applies to Pictruly or your use of the Services.
Content means any information, photographs, images, profile information, captions,
comments, messages, reports or other material that you create, upload, submit or share
through the Services.
Personal Information means information that identifies you, relates to you, describes you,
or can reasonably be linked to you, as defined under applicable privacy laws.
Services means the Pictruly mobile application, website, features, functionality and any
other products or services operated by Pictruly Pty Ltd.
Third-Party Service Provider means a company or organisation engaged by Pictruly to
provide services that help operate, secure or improve the Services.
User, you or your means any person who accesses or uses the Services.
We, us, our or Pictruly means Pictruly Pty Ltd.
1.2 Interpretation
Unless the context requires otherwise:
● References to the singular include the plural, and references to the plural include the
singular.
● References to any gender include all genders.
● References to a person include an individual, company, partnership, trust,
government authority or any other legal entity.
● The words "including", "includes" and "such as" are to be interpreted as
"including without limitation".
● Headings and titles are provided for convenience only and do not affect the
interpretation of this Privacy Policy.
● References to laws or regulations include any amendments, replacements or
re-enactments of those laws or regulations.
● Any reference to a section or clause is a reference to a section or clause of this
Privacy Policy unless otherwise stated.
2. Welcome to Pictruly
Pictruly exists to help people share real moments with the people who matter most.
Protecting your privacy is fundamental to that mission.
This Privacy Policy explains how Pictruly Pty Ltd ("Pictruly", "we", "our" or "us") collects,
uses, stores, shares and protects your Personal Information when you use the Pictruly
Services.
Pictruly is incorporated in Victoria, Australia, however our Services are available to users
around the world. Depending on where you live, you may have additional rights under the
privacy or data protection laws that apply in your jurisdiction.
By creating an Account or using the Services, you acknowledge that you have read and
understood this Privacy Policy and agree to the collection, use and disclosure of your
Personal Information as described in this document.
If you do not agree with this Privacy Policy, you should not use the Services.
2.1 Scope of this Privacy Policy
This Privacy Policy applies to all users of the Pictruly Services, including visitors, registered
users, beta testers and any person who accesses or interacts with the Services.
3. Our Privacy Principles
Privacy is more than a legal obligation - it's one of the principles that guides how Pictruly is
designed and operated.
We believe people should understand what information is collected, why it is collected and
how it is used. These principles influence the decisions we make as we continue to build and
improve our Services.
3.1 Purposeful Collection
We believe privacy begins with restraint.
Pictruly only collects Personal Information that is reasonably necessary to provide, improve
and protect our Services. We do not collect information simply because technology allows us
to.
3.2 No Sale of Personal Information
Your Personal Information is not a product.
Pictruly does not sell your Personal Information to advertisers, data brokers or other third
parties.
3.3 You Control What You Share
You decide what Content you choose to create and share through Pictruly.
While some information is required to create and maintain an Account, you remain in control
of the Content you choose to upload, publish or remove, subject to our Terms of Service and
Community Guidelines.
3.4 Privacy by Design
Privacy is considered throughout the design, development and operation of Pictruly.
As our Services evolve, we will continue working to protect Personal Information through
responsible data practices, appropriate security measures and thoughtful product design.
3.5 Transparency
We aim to explain our privacy practices in clear and accessible language.
If we make significant changes to this Privacy Policy, we will communicate those changes in
an appropriate way so you understand how they may affect you.
4. Information We Collect
The information we collect depends on how you use Pictruly, the features you access and
the choices you make while using the Services.
We collect information to operate the platform, maintain security, improve the user
experience and comply with applicable legal obligations.
We do not intentionally collect more information than is reasonably necessary for these
purposes.
4.1 Information You Provide
When you create or use a Pictruly Account, you may provide information including:
● Mobile phone number
● Username
● Display name
● Profile photograph
● Biography or profile description
● Date of birth, where required
● Country or region
● Any other information you choose to include in your profile
You are responsible for ensuring the information you provide is accurate and kept up to date.
4.2 Content You Create
Pictruly is designed to allow you to capture and share genuine moments with your friends.
When you use the Services, we collect the Content you choose to create or upload,
including:
● Photographs
● Captions
● Comments
● Profile images
● Reports submitted through the platform
● Feedback provided to Pictruly
● Any other Content you voluntarily submit through the Services
You retain ownership of the Content you create. Our rights to use that Content are explained
in our Terms of Service.
4.3 Device and Technical Information
To provide a secure and reliable experience, Pictruly automatically collects certain technical
information, including:
● Device type and model
● Operating system version
● App version
● IP address
● Device language and region settings
● Time zone
● Crash reports
● Diagnostic information
● Performance data
This information helps us maintain the stability, security and performance of the Services.
4.4 Usage Information
We collect information about how you interact with Pictruly, including:
● Account creation and sign-in activity
● Profile updates
● Friend requests
● Posts you create
● Features you use
● Reports you submit
● Blocks and privacy settings
● General interaction with the Services
This information helps us understand how Pictruly is used so we can improve functionality,
identify technical issues and maintain a safe platform.
4.5 Information Provided by Other Users
Other users may provide information relating to you when they:
● Send you a friend request
● Mention or reference you
● Report your Account or Content
● Interact with your public profile where applicable
We handle this information in accordance with this Privacy Policy.
4.6 Information We Do Not Intentionally Collect
Pictruly is designed to minimise unnecessary collection of Personal Information.
Unless you voluntarily choose to share it, we do not intentionally collect sensitive Personal
Information such as:
● Health information
● Religious beliefs
● Political opinions
● Sexual orientation
● Biometric information
● Financial information
If you choose to include sensitive information in Content you share through the Services, you
acknowledge that this information may be visible to others in accordance with your privacy
settings and the nature of the Content you publish.
5. How We Use Your Personal Information
Pictruly uses Personal Information only where it is reasonably necessary to operate,
maintain, improve and protect the Services.
Depending on how you use Pictruly, your Personal Information may be used for one or more
of the following purposes.
5.1 Providing the Services
We use your Personal Information to:
● Create and manage your Account.
● Authenticate your identity when you sign in.
● Display your profile and the Content you choose to share.
● Connect you with friends and other users.
● Deliver the core functionality of the Services.
● Provide customer support and respond to enquiries.
5.2 Maintaining Safety and Security
We use Personal Information to help keep Pictruly safe for everyone.
This may include:
● Investigating reports submitted by users.
● Detecting spam, fraudulent activity or abuse.
● Preventing unauthorised access to Accounts.
● Protecting the integrity, reliability and security of the Services.
● Enforcing our Terms of Service and Community Guidelines.
5.3 Improving Pictruly
We continually improve the Services based on how they are used.
Personal Information may be used to:
● Understand how features are being used.
● Diagnose technical issues and application errors.
● Improve reliability and performance.
● Develop new features and functionality.
● Enhance the overall user experience.
Where possible, we use aggregated or de-identified information when analysing usage
trends.
5.4 Communicating With You
We may use your Personal Information to communicate with you about your Account or the
Services.
These communications may include:
● Verification codes.
● Important account notifications.
● Security alerts.
● Updates relating to the operation of the Services.
● Responses to support requests.
We will not send marketing communications where prohibited by applicable law without the
required consent.
5.5 Legal and Regulatory Obligations
We may use Personal Information where reasonably necessary to:
● Comply with applicable laws and legal obligations.
● Respond to lawful requests from government authorities or regulators.
● Protect the rights, property or safety of Pictruly, our users or others.
● Establish, exercise or defend legal claims.
6. Legal Bases for Processing Personal Information
The laws of some countries require organisations to identify the legal basis on which
Personal Information is processed.
Where these laws apply, Pictruly processes Personal Information on one or more of the
following legal bases:
6.1 Performance of a Contract
Processing is necessary to provide the Services you have requested, including creating and
maintaining your Account, delivering platform functionality and enabling you to use Pictruly.
6.2 Legitimate Interests
Processing is necessary for our legitimate interests, provided those interests are not
overridden by your rights or freedoms.
These legitimate interests include:
● Operating and improving the Services.
● Maintaining platform security.
● Preventing fraud and abuse.
● Responding to user reports.
● Protecting the Pictruly community.
6.3 Legal Obligations
Processing may be necessary to comply with applicable laws, regulations, court orders or
other lawful obligations.
6.4 Consent
In certain circumstances, we may rely on your consent before processing specific Personal
Information.
Where processing is based on consent, you may withdraw that consent at any time.
Withdrawal of consent does not affect the lawfulness of processing that occurred before
consent was withdrawn.
7. How We Share Personal Information
Pictruly does not sell your Personal Information.
We only share Personal Information where it is reasonably necessary to operate the
Services, comply with legal obligations or protect the safety and security of our users.
7.1 Trusted Service Providers
We engage trusted third-party service providers to help us operate Pictruly.
These providers may assist with services such as:
● User authentication.
● Secure cloud infrastructure.
● Data storage.
● Application performance monitoring.
● Crash reporting.
● Customer support.
● Email and notification delivery.
● Platform security.
These providers are only authorised to process Personal Information on our behalf for the
purposes of providing services to Pictruly and are required to protect that information
appropriately.
7.2 Legal Requirements
We may disclose Personal Information where we reasonably believe it is necessary to:
● Comply with applicable law.
● Respond to lawful requests from courts, regulators or government authorities.
● Protect the rights, safety or property of Pictruly, our users or the public.
● Investigate suspected unlawful activity, fraud or security incidents.
7.3 Business Transactions
If Pictruly undergoes a merger, acquisition, investment, corporate restructuring or sale of
assets, Personal Information may be transferred as part of that transaction, subject to
applicable privacy laws.
Where required by law, we will take reasonable steps to notify users of any significant
changes affecting the handling of their Personal Information.
8. Third-Party Services
Pictruly relies on carefully selected third-party service providers to help deliver, maintain and
improve the Services.
These providers perform services on our behalf and may process Personal Information only
where reasonably necessary to provide those services.
Depending on how you use Pictruly, we may use third-party providers for services including:
● User authentication.
● Cloud hosting and secure data storage.
● Database infrastructure.
● Application performance monitoring.
● Crash reporting and diagnostics.
● Push notifications.
● Customer support.
● Security and fraud prevention.
Our service providers are contractually or legally required to protect Personal Information
and may only process it in accordance with our instructions and applicable law.
While we carefully select providers that meet appropriate security and privacy standards,
their services are governed by their own privacy policies and terms of use where applicable.
Pictruly may change or introduce service providers from time to time as our Services evolve.
9. International Data Transfers
Pictruly is operated by Pictruly Pty Ltd, a company incorporated in Victoria, Australia.
Because our Services are available worldwide, your Personal Information may be processed
or stored in countries other than the country in which you reside.
Some of our trusted service providers operate global infrastructure, which means Personal
Information may be transferred internationally where reasonably necessary to provide the
Services.
Where Personal Information is transferred across borders, we take reasonable steps to
ensure appropriate safeguards are in place and that any transfers are carried out in
accordance with applicable privacy and data protection laws.
By using Pictruly, you acknowledge that your Personal Information may be transferred,
processed and stored outside your country of residence where necessary to provide the
Services.
10. Cookies, Analytics and Similar Technologies
Depending on the platform you use to access Pictruly, we and our trusted service providers
may use cookies, device identifiers and similar technologies to support the operation of the
Services.
These technologies may be used to:
● Keep you signed in.
● Remember your preferences.
● Improve application performance.
● Monitor reliability and diagnose technical issues.
● Understand how the Services are being used.
● Protect Accounts from unauthorised access or misuse.
Pictruly does not use cookies or similar technologies to sell your Personal Information or to
build advertising profiles based on your activity.
Where required by applicable law, you will be provided with appropriate choices regarding
the use of cookies or similar technologies.
You may also manage certain cookie preferences through your browser or device settings,
although disabling some technologies may affect the functionality of the Services.
11. Data Retention
We retain Personal Information only for as long as it is reasonably necessary to fulfil the
purposes described in this Privacy Policy, comply with legal obligations, resolve disputes,
enforce our agreements and protect the integrity of the Services.
The length of time Personal Information is retained depends on the nature of the information
and the purpose for which it was collected.
For example, we may retain:
● Account information while your Account remains active.
● Content until it is deleted by you or removed in accordance with our Terms of Service
or Community Guidelines.
● Technical logs and security records for a limited period to investigate security
incidents, detect fraud and maintain platform reliability.
● Certain records after Account deletion where required or permitted by law, or where
reasonably necessary to protect Pictruly, our users or the public.
When Personal Information is no longer required, we will take reasonable steps to securely
delete, anonymise or de-identify that information unless retention is required or authorised
by law.
12. Your Choices
Pictruly is designed to give you meaningful control over your experience and the information
you choose to share.
Depending on how you use the Services, you may choose to:
● Update or correct your profile information.
● Change your profile photograph or biography.
● Delete Content you have shared.
● Block other users.
● Manage your hidden words and content preferences.
● Control who you connect with through friend requests.
● Report Content or Accounts that you believe violate our policies.
● Delete your Account.
Some information may continue to be retained after you make these changes where
reasonably necessary to comply with legal obligations, investigate security incidents or
protect the integrity of the Services.
13. Your Privacy Rights
Depending on where you live, you may have legal rights relating to your Personal
Information under applicable privacy or data protection laws.
Subject to those laws, you may have the right to:
● Request access to the Personal Information we hold about you.
● Request correction of inaccurate or incomplete Personal Information.
● Request deletion of your Personal Information in certain circumstances.
● Withdraw consent where processing is based on your consent.
● Request that we restrict or object to certain processing activities.
● Request a copy of your Personal Information in a portable format where required by
law.
● Lodge a complaint with a relevant privacy regulator or supervisory authority.
To help protect the privacy of our users, we may ask you to verify your identity before
responding to certain requests.
Some rights may not apply in every circumstance and may be limited where permitted by
applicable law.
14. Account Deletion
You may request deletion of your Pictruly Account at any time through the Services, where
available, or by contacting us using the details provided in this Privacy Policy.
When an Account is deleted, we will take reasonable steps to delete or de-identify the
associated Personal Information within a reasonable period, unless we are required or
permitted to retain certain information by law.
Some information may continue to be retained for a limited period, including:
● Information stored in secure backup systems.
● Records required to comply with legal obligations.
● Information reasonably necessary to investigate fraud, abuse or security incidents.
● Records required to enforce our Terms of Service or protect the rights, safety and
security of Pictruly, our users or the public.
Deleting your Account is permanent and may result in the loss of access to your profile,
Content and other information associated with your Account.
15. Children and Minimum Age Requirements
Pictruly is intended for users who meet the minimum legal age required to use our Services
in their country or region.
We do not knowingly collect Personal Information from children below the applicable
minimum age without any consent required under applicable law.
If we become aware that an Account has been created in breach of these requirements, we
may suspend or permanently remove the Account and take reasonable steps to delete
associated Personal Information.
If you believe a child has provided Personal Information to Pictruly inappropriately, please
contact us at support@pictruly.app so we can investigate and take appropriate action.
16. Security
Protecting the security of your Personal Information is a responsibility we take seriously.
Pictruly maintains reasonable technical, administrative and organisational safeguards
designed to protect Personal Information against unauthorised access, disclosure, alteration,
misuse or loss.
These safeguards may include:
● Secure authentication processes.
● Encrypted communications where appropriate.
● Access controls and permission management.
● Infrastructure monitoring.
● Security logging and auditing.
● Regular software and security updates.
● Measures designed to detect unauthorised access and suspicious activity.
While we work to protect your Personal Information, no method of transmitting information
over the internet or storing information electronically can be guaranteed to be completely
secure.
For this reason, we encourage all users to take reasonable steps to protect their own
devices and Account information.
If we become aware of a security incident involving Personal Information, we will investigate
the incident, take appropriate action to reduce any potential impact and notify affected users
or relevant authorities where required by applicable law.
17. Changes to this Privacy Policy
As Pictruly continues to evolve, we may update this Privacy Policy to reflect changes to our
Services, legal obligations, technology or privacy practices.
When we make material changes, we will take reasonable steps to notify users through the
Services or by other appropriate means where required by applicable law.
The "Last Updated" date at the beginning of this Privacy Policy indicates when this
document was most recently revised.
Your continued use of the Services after an updated Privacy Policy becomes effective
constitutes acceptance of the revised Privacy Policy.
If you do not agree with any changes, you should discontinue your use of the Services and,
where appropriate, request deletion of your Account.
18. Contact Us
If you have any questions, concerns or requests relating to this Privacy Policy or the way
Pictruly handles Personal Information, please contact us.
Pictruly Pty Ltd
Victoria, Australia
Email: support@pictruly.app
We aim to respond to privacy enquiries within a reasonable timeframe and in accordance
with applicable privacy laws.
Our Commitment
At Pictruly, privacy is more than compliance - it's part of the trust people place in us every
time they open the app.
We recognise that every Account represents a real person, every photograph captures a
genuine moment and every connection reflects a relationship that matters.
As Pictruly grows, we remain committed to handling Personal Information responsibly,
communicating openly about our privacy practices and continually improving the way we
protect our community.
Thank you for placing your trust in Pictruly.
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