Privacy Policy

Effective Date: February 7, 2026

1. Introduction

This Privacy Policy describes how Gain Foundry, LLC, doing business as PicFloc ("PicFloc," "we," "us," or "our"), collects, uses, and discloses information about you when you access our website, client portal, and services (collectively, "Services").

We respect your privacy and are committed to protecting it. By using our Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy.

2. Information We Collect

We collect information to provide and improve our Services. The types of information we collect are:

a. Information You Provide to Us

• Account Information: When you access the client portal, we collect your email address. We use a passwordless login system that sends a one-time verification code to your email.
• Client Content: We collect the files you upload through the client portal, including photos, videos, and documents. This is necessary to provide our content marketing services.
• Communications: We collect information when you contact us for customer support or other inquiries.

b. Information We Collect Automatically

• Usage & Device Information: We collect information about how you use our Services, including your IP address, browser type, operating system, pages viewed, and the dates and times of your visits. This helps us understand user behavior and improve the Services.
• Cookies: We use essential cookies to keep you logged in and maintain your session. These cookies are necessary for the Services to function and cannot be disabled.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To Provide and Maintain the Services: To authenticate your identity, provide access to the client portal, store and manage your uploaded files, and deliver our content marketing services.
• To Improve Our Services: To analyze usage trends, understand how clients interact with our features, and improve the overall experience.
• To Communicate with You: To send you verification codes, security alerts, and respond to your support requests.
• For Safety and Security: To detect and prevent fraud, abuse, and other harmful or illegal activities.
• To Comply with Legal Obligations: To comply with applicable laws, lawful requests, and legal processes.

4. How We Disclose Your Information

We do not sell your personal information. We may disclose your information in the following circumstances:

• Vendors and Service Providers: We share information with third-party companies that perform services on our behalf, such as cloud hosting and storage (Microsoft Azure) and email delivery (Azure Communication Services).
• Legal Requirements: We may disclose information if required to do so by law or in response to a valid legal process, such as a court order or government request.
• Business Transfers: In connection with a merger, sale of company assets, or financing, your information may be transferred to the new entity. We will notify you if such a transfer occurs.
• With Your Consent: We may share your information for other purposes with your explicit consent.

5. Data Retention

We retain your personal information for as long as necessary to provide the Services and fulfill the purposes outlined in this policy. You may request deletion of your account and associated content at any time by contacting us. After your account is deleted, your data is kept in backups for a limited time for disaster recovery purposes and is then permanently erased.

6. Your Choices and Rights

• Account Information: You can access your account information by logging into the client portal.
• Deleting Your Account: You can request to delete your account and associated data by contacting us at contact@picfloc.com.
• Communications: You can opt-out of promotional emails by following the unsubscribe instructions in those emails. You will still receive essential emails related to your account, such as login verification codes.

7. Security of Your Information

We implement reasonable technical and organizational measures to protect your information from unauthorized access, use, or disclosure. These measures include encrypted connections (HTTPS), secure authentication, and access controls on stored files. However, no internet transmission is ever completely secure, and we cannot guarantee the absolute security of your data.

8. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without parental consent, we will take steps to delete it.

9. Information for Users in the European Economic Area (EEA) and United Kingdom

If you are located in the European Economic Area (EEA) or United Kingdom, this section applies to you in addition to the rest of this Privacy Policy.

a. Legal Basis for Processing

We process your personal data under the following legal bases:

• Contract: Processing necessary to provide the Services you request (e.g., authenticating your identity, storing your files).
• Legitimate Interests: Processing for our legitimate business purposes, such as improving the Services, preventing fraud, and security.
• Consent: Where required by law, we rely on your consent, which you can withdraw at any time.

b. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right of Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can ask us to correct inaccurate or incomplete personal data.
• Right to Erasure ("Right to be Forgotten"): You can request that we delete your personal data in certain circumstances.
• Right to Restrict Processing: You can ask us to limit how we use your personal data.
• Right to Data Portability: You can request a copy of your data in a structured, machine-readable format.
• Right to Object: You can object to our processing of your personal data for direct marketing or based on legitimate interests.
• Right to Withdraw Consent: Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at contact@picfloc.com. We will respond to your request within 30 days.

c. International Data Transfers

Your personal data may be transferred to and processed in countries outside the EEA, including the United States, where our servers and third-party service providers are located. We rely on appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission, to ensure your data is protected in accordance with this Privacy Policy.

d. Data Protection Authority

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with your local data protection authority.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by revising the date at the top of this policy and, in some cases, by providing additional notice (such as a notification within the Services).

11. Contact Us

If you have any questions about this Privacy Policy, please contact us at contact@picfloc.com.