Privacy Policy
Effective as of October 9, 2023
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.
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.
Security Measures
9.
International Transfer of Personal Information
10.
Changes to this Privacy Policy
11.
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:
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contact information including: name; address; phone number; email address, company name, company website.
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purchase and payment information including: credit card or similar payment information that you intend to purchase with; billing and delivery address; the goods purchased and how many; your purchase and return history.
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information about and to support complaints made in connection with the Sites or goods and/or services purchased via the Sites.
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ID（such as a passport）for identification verification in certain circumstances, when you apply for after-sales services.
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additional information, such as in response to questionnaires for market research/analytics. This may include marital status, nationality, gender, date and/or year of birth, annual income, monthly spending and user preferences. If you prefer not to provide such information, the use of our services and products will not be affected.
b)
Information That We Collect Automatically
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a copy of any correspondence with us, including any verification information we ask for, if you contact us for any reason (such as our customer service department chat service, telephone or email).
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details of transactions and communications over the Sites, including the types and specifications of the goods sold and purchased, pricing and delivery information, any dispute records, and any information disclosed in any discussion forum.
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when you use the Sites and/or the Services, we will automatically collect information from your device. Specifically, this collected information 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 goods and 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 technology, as explained further under section 6 “Cookie” 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. We also may derive or collect inferences about you based on your buying and browsing activity information and other information we have collected about you.
We may collect information about the people or accounts with whom you share content or interact and contact information if you choose to upload or import it from a device (such as an address book).
c)
Information That We Receive from Third Parties
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other platforms if you choose to register for the Sites account via the platform’s account (such as AliExpress, Shopify). Exactly what information we receive will depend on your privacy settings with the applicable platform, but would typically include basic public profile information such as:
i.
Account information: your user id, nickname or username, profile picture
ii.
Order information
iii.
Country
iv.
Company name (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.
2.
Use of Personal Information
We collect and use your personal information for the following purposes:
a)
verifying account registrations of the Sites, including conducting fraud, security, “Know Your Customer” and anti-money laundering checks in order to approve your Sites account;
b)
setting up / administering accounts, including providing log-in IDs and setting up payment / transaction accounts;
c)
providing customer service support, such as responding to your queries, feedback and managing claims and/or disputes;
d)
providing/supporting general services of the Sites, facilitating communication, processing transactions and payments, assessing advance withdrawal requests, providing and supporting logistics and delivery services;
e)
supporting clearance declarations / applications where made via the Sites;
f)
providing relevant membership benefits, including birthday rewards, membership offers and coupons, anniversary awards, exclusive member prices;
g)
verifying your identity and purchases in connection with product warranty or other after-sales claims;
h)
assessing and monitoring account security and transaction risks, such as detecting and preventing fraud, money laundering and other security incidents;
i)
sending 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;
j)
conducting research and analytics to ensure the security of our Sites, to improve the content and layout of the Sites, and to improve our Sites, product offerings and services;
k)
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;
l)
help you find people you may know who are also using the Sites.
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. You can request further information about the compatibility of other purposes upon request.
3.
Disclosure or Sharing of Personal Information
We disclose/share personal information with the following categories of recipients:
a)
other Sites Users where necessary to support purchases and communications made between you.
b)
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 or notified to you when we collect your personal information. Categories of these partners and service providers include:
i.
AliExpress, Alibaba group entities and affiliated companies and/or their designated 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;
ii.
our business partners where you have consented to receiving such information from them if required by applicable data protection laws;
iii.
marketing and advertising partners, such as Shopify, Google, Twitter, Facebook, Instagram, Reddit and TikTok, 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;
iv.
payment service providers that provide payment processing services. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;
v.
logistics partners for providing delivery services for you, including return and exchange of products, and warehousing services;
vi.
cloud computing or other hosting service providers to provide cloud storage services;
vii.
warranty service providers to provide product warranty services;
viii.
customer service support providers to provide after-sale services or other customer service support;
ix.
risk control service providers to assess the security of user’s accounts and transaction risks;
x.
to 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;
xi.
to 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.
xii.
to 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, to provide services or products to you, 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 websites (for example if you are logged in as a member or you are visiting our websites 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 11. "How to Contact Us" below:
a)
The right toaccess, correct, update or request deletionof your personal information.
b)
The right toobject to processingof your personal information when it is based on our legitimate interests, and separately the right toobject to direct marketing.
c)
The right to ask us, in some situations, torestrict processing of your personal information or request portabilityof your personal information.
d)
The right toopt-out of marketingcommunications 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 section11 "How to Contact Us" below.
e)
If we have collected and process your personal information with your consent, then you have the right towithdraw your consentat 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 tocomplain to a data protection authorityabout 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?
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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.
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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.
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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?
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We use first- and third-party Cookies for several reasons.
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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.
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We also use social media Cookies. 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.
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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; and 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.
Types of Cookies | Who serves these Cookies | How to refuse |
Essential Cookies：These Cookies are strictly necessary for enabling access and use of our Platform. They provide necessary functionality to ensure the proper performance, security and functionality of our Platform. These Cookies cannot be disabled. | global_sid | Essential Cookies cannot be disabled |
Analytics Cookies: These Cookies collect information in aggregate form to help us determine and understand how users interact with and use our Platform. We use this information to help us to improve and optimize our Platform and its security. | Google Analytics (please see below for further information) Alimama Analytics cna sca atpsida | To refuse these Cookies, please follow the instructions below under the heading "How can I control Cookies?" |
c)
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to our Sites. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Sites or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Sites to another, to deliver or communicate with cookies, to understand whether you have come to our Sites from an online advertisement displayed on a third-party website, to improve sites performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
d)
How can I control Cookies?
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You can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access the Sites or the “privacy setting” of your device. As the means by which you can refuse Cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. If you adjust the privacy setting in the browser, your mobile device will continue collecting data unless you adjust the privacy setting of the device, and vice versa.
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Certain features of the Sites depend on Cookies. Please be aware that if you choose to block Cookies, you may not be able to sign in or use those features, and preferences that are dependent on Cookies may be lost.
e)
Google Analytics (More information): Our Sites use Google Analytics, an internet analytics service provided by Google, Inc. (“Google”). Google’s Cookies allow us analyze use of the Sites by telling us which pages our users are viewing, which ones are most popular, what time of day our Sites are visited, if users have previously visited our Sites, from which websites users are redirected to our Sites were and the like. The data generated by the cookie about your use of the Sites will be transmitted to Google and stored by Google on servers in the United States.
The Sites uses an anonymization tool of IP addresses so that the IP addresses are truncated within the territory of the Member States of the European Union and the other members of the agreement on the European Economic Area. In some cases, non-truncated IP address may be transmitted to Google’s servers in the US and then truncated there.
Google uses the data on behalf of us to evaluate your use of our Sites, to compile reports on website activity for the website operators and for other website activity and internet usage services. Google may disclose this information to third parties under the terms of the law or for further processing by third parties on behalf of Google. For more information about Google Analytics Cookies, visit: the Google Help pages and Privacy Policy: Google Privacy Policy: https://policies.google.com/privacy; and the Google Analytics Help Centre: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.
Through your browser settings, you can block Cookies; however, this can lead to problems with the use of some functionalities of the websites. Through the add-on “Google Analytics Opt-out” you can through your current web browser opt-out to the use of Google Analytics from then on: http://tools.google.com/dlpage/gaoptout?hl=en.
7.
Minors
The Sites are intended for adults and users must be over 18 to use our Sites. We do not intend to sell any of our products or services to minors, as defined by applicable law. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact PicCopilot@aliexpress.com to remove the information.
8.
Security Measures
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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.
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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.
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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.
9.
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 will also be international transfers of your information among the above-mentioned countries. We 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 11 How to Contact Us below.
10.
Changes to this Privacy Policy
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We may update this Privacy Policy from time to time in response to changing legal, technical or business developments.
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When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make and as required by applicable law, such as by posting an amended Privacy Policy on the Sites.
11.
How to Contact us
