Privacy Policy
Last Updated: March 11, 2025
Effective Date: March 18, 2025
To review the previous version(s), please click the hyperlink at the top right corner of this page.
We recognize the importance of privacy and confidentiality of personal information.
This Privacy Policy sets out how NEURALNETICS PTE. LTD. (“NEURALNETIC”, “we”, “us”, “our” or “ours”) collect, use and disclose information in connection with the operation of https://www.piccopilot.com/(“PicCopilot” or the “Sites”), including personal information about users, visitors and representatives (collectively, the “User” or “you”). Any contents, information and materials contained in or appeared on the Sites, as developed from time to time, which are owned, operated and provided by or on behalf of us.
We refer to the Sites and the contents, information and materials collectively as the "Services".
By using our Services, you are agreeing and consenting to the practices set out in this Privacy Policy and in our Terms of Use.
Table of Contents
1. Collection of Personal Information
2. Use of Personal Information
3. Disclosure or Sharing of Personal Information
4. Retention
5. Your Rights and Choices
6. Cookies
7. Minors
8. California Do Not Track Notice
9. California Shine the Light
10. Security Measures
11. International Transfer of Personal Information
12. Other Third-Party Websites and Social Media Buttons
13. Changes to this Privacy Policy
14. How to Contact us
1. Collection of Personal Information
The personal information that we collect broadly falls into the following categories:
a) Information That You Provide to Us:
● account profile and other contact information including: phone number; email address; name or company name, company website and company address.
● your username and password.
● purchase and payment information, including credit card or other similar payment information processed by third-party payment processors (e.g., Stripe and Alipay) and records of services you purchased or obtained.
● any personal information contained in the contents of complaints made in connection with the Sites or goods and/or services purchased via the Sites or other correspondence with us, such as discussion forums or customer support emails.
● audio and visual information, including but not limited to your photographs when using our virtual try-on tool and your videos when using our AI avatars tool.
● additional personal information, such as user preferences, collected in response to questionnaires for market research/analytics or other studies. If you prefer not to provide such information, the use of our services and products will not be affected.
● inferences derived from any personal information we collect about you.
b) Information That We Collect Automatically
● when you use the Sites and/or the Services, we will automatically collect information from your device, which may include IP addresses, date and time of access to the Sites, device type, unique device identification numbers, browser type, broad geographic location (e.g., country or city-level location), browsing patterns and details of how you have interacted with our Sites and the services available on it. In addition, we gather information about the Sites and visitors to the Sites including browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Some of this information may be collected using cookies and similar tracking technologies, as explained further under section 6 “Cookies” below. Where we are required by applicable law, we will seek your prior consent to the collection of information using cookies and similar tracking technologies.
c) Information That We Receive from Third Parties
We collect your personal information from third parties, such as other third party platforms (e.g., Google) you use to register for an account with us. The personal information we receive from these third parties will depend on your privacy settings with such third parties, but may include the following:
-Your account information, such as your user id, nickname or username, email address, and profile picture;
-Your country or place of residence; and
-Your company name or other company information (if applicable).
We will only collect personal information from third parties where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
● other platforms such as our advertising partners. The information we receive is usually analytics data, typically including the number and kinds of people who see and engage with our ads and commercial content on such other platforms, and confirmation from such other platforms which ads or commercial content you viewed that led you to take an action with us. But we don’t receive information from such other platforms that by itself can be used to contact or identify you, such as your name or email address. These platforms have their own privacy policies which govern their use of information.
d) Use of Generative Artificial Intelligence (“AI”)
● We also collect certain personal information directly from you when you use or interact with any of our generative AI products or services, such as your facial and body geometry derived from photographs as well as text, images, videos, voice or other materials inputted into our AI tools (“Inputs”). If you include personal information in your Inputs, we will collect that information as well.
None of your personal information or Inputs will be used to train or improve our AI models, systems or other algorithms, and will only be used to provide our products and services such as our AI tools.
● Some of our generative AI products or services may require access to your photos or videos, including images of your face and body if you agree and upload to function properly, but it is not mandatory to provide us with your photos or videos. Although our products and services are not directed to minors under 18, if you are uploading images of a minor, please ensure you have obtained proper consent from a parent or lawful guardian.
We are committed to protecting your privacy and ensuring that any data collected is used solely for the purpose of providing the generative service, such as providing users with a visual representation of how certain products may appear when worn, and we will not use your photos for any recognition or identification purposes. We will not store your Inputs, but the photos or videos generated will be retained so that you may download any time until your deletion of them.
2. Use of Personal Information
We collect and use your personal information for the following purposes:
a) setting up and administering your accounts, including providing log-in IDs;
b) providing customer service support, such as responding to your queries, feedback and managing claims and/or disputes;
c) providing and supporting general services of the Sites including our AI tools, facilitating communication, processing transactions and payments, and assessing advance withdrawal requests;
d) providing relevant membership benefits, including membership offers, coupons, and exclusive member prices;
e) verifying your identity and purchases in connection with product warranty or other after-sales claims;
f) assessing and monitoring account security and transaction risks, such as detecting and preventing fraud, money laundering and other security incidents;
g) sending marketing emails and serving tailored marketing and advertising that we believe will be of interest to you based on the ways in which you use the Sites, your browsing records, and order history (we may use cookies and other similar technologies to provide you with marketing and advertising based upon your browsing activities and interests);
h) conducting internal research and analytics;
i) ensuring the security of our Sites, improving your user experience on the Sites, and improving our Sites, product offerings and services;
j) complying with applicable laws and regulations or national security requests and legal process, such as to respond to a court order or subpoena or requests from government authorities.
We may also use your personal information for other purposes that are compatible with the purposes we have disclosed to you if and where this is permitted by applicable data protection laws.
3. Disclosure or Sharing of Personal Information
We disclose or share personal information with the following categories of recipients:
a) third party partners and service providers and/or affiliates engaged by or working with us to assist us in providing services to you or who otherwise process personal information for purposes described in this Privacy Policy.
Categories of these partners and service providers include:
i. our business partners (if applicable) where you have consented to receiving such information from them if required by applicable data protection laws;
ii. marketing and advertising partners (if applicable), and/or analytical service providers, such as Google and Microsoft, so that they may tailor the content you see when visiting our Sites for analytics and/or advertising purposes. These partners may combine information they collect on our Sites with data on their platforms and data they collect from other websites or through other sources in order to conduct targeted advertising. The processing activities of these third parties marketing platforms are governed by their own privacy policies, not this Privacy Policy;
iii. payment service providers. such as Alipay and Stripe. that provide payment processing services on our behalf.
iv. cloud computing or other hosting service providers to provide cloud storage services;
v. other service providers that work with us to provide processing services such as software, tools, systems and messaging services for purposes described in this Privacy Policy;
vi. our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations where we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person; or as otherwise required or permitted by applicable laws;
vii. an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
viii. other third parties to help detect and protect against fraud or data security vulnerabilities.
ix, any other person with your consent to the disclosure.
We have established relationships with other parties and websites to offer you the benefit of products and services which we do not offer. We offer you access to these other parties and their websites either through the use of hyperlinks to these sites from our Sites or through offering “co-branded” sites in which both we and other parties share the same uniform resource locator (URL), domain name or pages within a domain name on the Internet. In some cases, you may be required to submit personal information to register or apply for products or services provided by such third parties or co-branded partners. This Privacy Policy does not apply to these third-party sites or co-branded sites. The privacy policies of those other parties may differ from ours, and we have no control over the information that you submit to those other sites. You should read the relevant privacy policy for those third parties’ sites and co-branded sites before responding to any offers, products or services advertised by them.
4. Retention
We will retain your personal information for 24 months from the date when your account remains inactive for more than 180 days or until we have no legitimate business need to do so, or as required or permitted by applicable laws. In the event that there are no other legitimate processing purposes, and upon the expiration of the 180-day period abovementioned, we will either anonymize your personal information in 24 months, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. How long your data is kept for will also depend on how you use our Sites (for example if you are logged in as a member or you are visiting our Sites as a guest) and what the information you provide to us is used for. For example, if you are a registered member, certain data will be retained for a length of time following termination or deletion of your account, in order to comply with applicable laws [(for example, if a court order is received about your account, we would retain your account data for longer than the usual retention period when an account is deleted)] or in case of disputes. In other instances, the period of retention may be determined according to your activity on the Sites or to comply with a specific arbitration period/resolve a dispute.
5. Your Rights and Choices
As a user of the Sites, you have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided under section 14. "How to Contact Us" below:
a) The right to access, correct, update or request deletion of your personal information.
b) The right to object to processing of your personal information when it is based on our legitimate interests, and separately the right to object to direct marketing.
c) The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
d) The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under section 14 "How to Contact Us" below.
e) If we have collected and process your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
f) The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.
6. Cookies
This section explains how we use cookies and similar technologies (we refer to them collectively as “cookies”) to recognize you when you visit our Sites. It explains what these technologies are and why we use them, as well as your rights to control them.
a) What are cookies?
● A cookie is a string of information that is sent to your browser and stored on your computer’s or mobile device’s hard drive. If you do not de-activate or erase the cookie, each time you use the same browser or device to access the Sites, our web servers will be notified of your visit to the Sites and, in turn, we may have knowledge of your visit and the pattern of your usage.
● Cookies set by the sites or app owner (in this case, NEURALNETICS) are called “first party Cookies”. Cookies set by third parties other than the sites or app owner are called “third party Cookies”. Third party Cookies enable third party features or functionality to be provided on or through the websites (e.g., like advertising, interactive content and analytics). The parties that set these third-party cookies can recognize your device both when it visits the websites in question and also when it visits certain other websites.
● Cookies are also categorized as “session Cookies” (which are erased once you close the browser or shut down the device) and “persistent Cookies” (which remain even after closing the browser or shutting down the device/application and which are activated each time you visit the Sites). Session cookies use encrypted data to authenticate you. Persistent Cookies do not store account numbers or passwords. We use both session cookies and persistent cookies.
b) Why do we use Cookies?
● We use first- and third-party Cookies for several reasons.
● Some Cookies are required for technical and/or security reasons in order for our Sites to operate, and we refer to these as “essential” or “strictly necessary” Cookies. First party Cookies are mainly served to enable basic functionality on our Sites; including web analytics Cookies that help us understand how users use our web pages and how we can improve their use. For example, we use essential or strictly necessary Cookies to enable us to remember goods added to your shopping basket and to recognize you when you sign into your account.
● We may also use social media Cookies (if applicable). You may register for Sites membership and “share” Sites content through social media such as Facebook and Twitter. Sometimes we embed videos from websites like YouTube. These websites have their own privacy policies which govern their use of information, which you can find on the respective websites.
● We also use Cookies to enable us to track and target the interests of the Sites visitors to enhance the experience on our Sites by researching visiting patterns and conducting interest-based advertising; assisting our partners in tracking user visits to the Sites; to track progress and participation in promotions and the success of our email marketing campaigns. We use first- and third-party Cookies for these purposes. We or our partners may also use Cookies, trackers, or otherwise collect personal information about your online activities over time and across different website when you visit our Sites.
7. Minors
The Sites are intended for adults and users must be over 18 to use our Sites. We do not knowingly collect or sell any personal information of minors under the age of 18. We do not intend to sell any of our products or services to minors, as defined by applicable law. If we learn that a minor has provided us with personal information without parental or guardian consent, we will take all necessary steps to remove the personal information from our systems.
8. California Do Not Track Notice
California law requires us to let you know how we respond to web browser "Do Not Track" (DNT) signals. Because there currently isn't an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
9. California Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents that have an established business relationship with a business to annually request, free of charge, information about certain categories of Personal Information a business has disclosed to third parties for those parties’ direct marketing purposes in the preceding calendar year. We do not share our customer's personal information with third parties for their own direct marketing purposes, without users’ approval. For information and to make a request, please contact us at PicCopilot@aliexpress.com.
10. Security Measures
● We implement appropriate technical and organizational measures to prevent unauthorized access to the Sites, to maintain data accuracy and to ensure the correct use of the information we hold. Upon becoming aware of a data breach, we will notify you and the regulatory authorities in accordance with the timescales and scope required by applicable data protection law.
● For registered users of the Sites, some of your information can be viewed and edited through your account, which is protected by a password. It is your responsibility to keep your password secure and confidential. We recommend that you do not divulge your password to anyone. We have instructed our personnel to never ask you for your password. If you share a computer with others, you should not save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session.
● No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we use appropriate technical and organizational measures to protect the information we hold for you, we cannot guarantee the security of any information you transmit over the internet.
11. International Transfer of Personal Information
In connection with providing the services through our Sites, we will store your personal data processed through the Sites in the Singapore. There might also be international transfers of your information as we may update in this Privacy Policy from time to time. We will take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement appropriate measures to ensure your personal information will remain protected in accordance with this Privacy Policy, such as standard contractual clauses or other mechanism provided for in the applicable law. A copy of the relevant clauses can be obtained by contacting us using the contact details provided under section 14 How to Contact Us below.
12. Other Third-Party Websites and Social Media Buttons
Our Sites may contain links to other websites or social media buttons. We are not responsible for the privacy practices or the content of those websites or social media platforms. This Privacy Policy applies only to our business and the personal information we collect.
13. Changes to this Privacy Policy
● We may update this Privacy Policy from time to time in response to changing legal, technical or business developments.
● When we update our Privacy Policy, we post those changes on the Sites and update the date of the Privacy Policy. If the changes are material, you will be notified via a notice on our Sites.
14. How to Contact us
You can reach out to us by email: PicCopilot@aliexpress.com.
