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PictoNexo Augmentative and alternative communication
PictoNexo · Legal

Privacy Notice

Review how PictoNexo handles and protects information related to the service.

Version
v3
Effective date
2026-09-09
Published date
2026-09-09
Language
English

PictoNexo Comprehensive Privacy Notice

Last updated: September 7, 2026

Version: 1.0

At PictoNexo, we respect the privacy and protection of our users' personal data.

This Comprehensive Privacy Notice describes what personal data we may process, the purposes for which we use it, how we protect it, and the rights available to individuals whose personal data is processed.

PictoNexo is an augmentative and alternative communication (AAC) application designed to facilitate communication through pictograms, words, phrases, sounds, audio, and other visual or auditory tools.

1. Data Controller

VICTOR HUGO PEREZ MARQUEZ, responsible for the operation of PictoNexo, with an address in:

the State of Chihuahua, Mexico.

is responsible for the processing, use, storage, and protection of personal data that may be collected through PictoNexo, in accordance with applicable Mexican personal data protection laws.

For matters related to privacy and personal data protection, you may contact us at:

Email: [PRIVACY EMAIL]

2. Scope of this Privacy Notice

This Privacy Notice applies to personal data processed directly by PictoNexo through the application, website, support mechanisms, official communications, or other services operated directly by us.

Certain data, settings, or content may remain stored exclusively on the user's device and, in such cases, are not received or stored by PictoNexo on its own servers or on servers operated by service providers acting on our behalf.

3. Personal Data We May Collect

The personal data processed will depend on the features used by the user.

PictoNexo may process the following categories of information:

3.1. Data Provided Directly by the User

  • Name or a name provided to identify the user, when required by a feature.
  • Email address, when the user contacts us or uses features that require it.
  • Information voluntarily provided in support requests or communications with PictoNexo.

3.2. Data Related to the Use and Configuration of the Application

Depending on the available features, the following data may be processed:

  • Selected language.
  • Configuration preferences.
  • Accessibility settings.
  • Application version.
  • Technical information necessary for the operation of the application.
  • Date and time of certain relevant actions.

3.3. Information Related to Legal Documents

When it is necessary to record acceptance of legal documents, PictoNexo may retain information such as:

  • Legal document accepted.
  • Document version.
  • Document language.
  • Date and time of acceptance.
  • Application version from which acceptance was provided.
  • Technical information reasonably necessary to provide evidence of such acceptance.

3.4. Personalized Content

PictoNexo may allow the user, parent, legal guardian, caregiver, or authorized person to add personalized content, including:

  • Photographs or images.
  • Personalized pictograms.
  • Voice recordings.
  • Words.
  • Names.
  • Labels.
  • Personalized phrases.
  • Favorites.
  • Pictogram organization preferences.

When such content is stored exclusively on the device, PictoNexo will not have access to it and will not receive it on its servers.

If optional synchronization services, cloud backups, or other features involving the transmission of such content outside the device are enabled in the future, the user will be informed in advance about such processing and, where applicable, the necessary consent will be requested.

4. Sensitive Personal Data

PictoNexo does not require users to provide medical diagnoses, clinical records, genetic information, or other sensitive data as a general requirement for using the application's basic communication features.

However, due to the nature of an augmentative and alternative communication application, certain content voluntarily added by a user, parent, guardian, or caregiver could indirectly reveal information considered sensitive, including information related to health, disability, or a person's particular needs.

When such information remains stored exclusively on the device and is not transmitted to PictoNexo, PictoNexo will not remotely process such data.

If a future feature requires PictoNexo to receive or store sensitive personal data, the user will be clearly informed and the corresponding express consent will be obtained when legally required.

5. Data Relating to Minors

PictoNexo may be used by minors due to the nature of its communication-support features.

When it is necessary to provide a minor's personal data to PictoNexo, such data must be provided or authorized by their parent, guardian, or legal representative when required by applicable law.

We recommend that application configuration and the addition of photographs, recordings, names, or other content related to minors be carried out under the supervision of a responsible adult.

PictoNexo seeks to limit the collection of minors' personal information to what is strictly necessary to provide the corresponding features.

6. Biometric Authentication

PictoNexo may allow the use of biometric authentication mechanisms available on the device, such as facial recognition, fingerprint recognition, or other mechanisms provided by the operating system.

When these features are used, biometric authentication is processed by the security mechanisms of the device or operating system.

PictoNexo does not need to receive or store the biometric templates used by the operating system to perform such authentication.

7. Primary Purposes of Processing

Personal data processed directly by PictoNexo may be used for the following purposes necessary to provide the service:

  • Provide and operate PictoNexo features.
  • Save and apply settings selected by the user.
  • Facilitate the application's communication features.
  • Manage features intended for parents, guardians, or caregivers.
  • Handle technical support requests.
  • Respond to user inquiries or communications.
  • Maintain the security and stability of the application.
  • Diagnose and correct technical errors.
  • Comply with legal obligations.
  • Manage and retain evidence of acceptance of legal documents when applicable.
  • Prevent fraudulent, abusive, or Terms-and-Conditions-violating uses.

8. Secondary Purposes

If PictoNexo uses personal data for additional purposes that are not necessary to provide the service, such purposes will be disclosed to the user and, where applicable, mechanisms will be provided to allow the user to object.

PictoNexo will not use sensitive personal data for personalized advertising.

9. Data Minimization Principle

PictoNexo seeks to limit the processing of personal data to information that is necessary, appropriate, and relevant to the purposes described in this Privacy Notice.

The application is designed so that certain features may operate using information stored directly on the device whenever technically possible.

10. Data Stored Locally on the Device

Certain information generated through PictoNexo may be stored exclusively on the user's device, including, depending on the version and configuration:

  • Personalized pictograms.
  • Photographs.
  • Voice recordings.
  • Quick phrases.
  • Favorites.
  • Personalized organization of pictograms.
  • Display preferences.
  • Accessibility settings.

When this information is stored only locally, PictoNexo will not be able to access it remotely.

Uninstalling the application, losing or restoring the device, deleting files, or experiencing system failures may result in the loss of such data if no backup mechanism exists.

11. Device Permissions

To provide certain features, PictoNexo may request permissions from the operating system.

Depending on the features used, such permissions may include access to:

  • Microphone, to make voice recordings.
  • Camera, to create pictograms or personalized content.
  • Photo gallery or photo library, to select images.
  • Local storage necessary to retain application content.
  • Authentication features provided by the device.

Requesting a permission does not necessarily mean that PictoNexo sends the associated information to external servers.

The user may manage these permissions through the privacy and security settings of their device.

12. Automatic Technologies and Technical Data

PictoNexo may process technical information strictly necessary to provide, protect, or improve the operation of the application.

Depending on the technologies implemented in each version, such information may include:

  • Device type.
  • Operating system and version.
  • PictoNexo version.
  • Device or application language.
  • Information related to failures or technical errors.

When third-party tools that collect data from the application are incorporated, their use and the categories of information involved will be reflected in this Privacy Notice as appropriate.

13. Cookies and Website

The official PictoNexo website may use technical technologies necessary for its proper functioning.

If cookies, identifiers, or other technologies are used for additional purposes, the user will be informed through the appropriate mechanisms and the necessary options will be provided in accordance with applicable law.

14. Transfers of Personal Data

PictoNexo does not sell personal data.

Personal data may be disclosed to service providers acting on behalf of PictoNexo when their participation is necessary to provide infrastructure, support, security, hosting, or other services necessary for operation.

Such providers must process data only in accordance with applicable instructions and contractual and legal obligations.

Transfers may also be made when necessary or permitted by applicable law, including when required:

  • By law.
  • By order of a competent authority.
  • For the recognition, exercise, or defense of a legal right.
  • To fulfill a legal relationship between PictoNexo and the data subject.

When a transfer requires the consent of the data subject, such consent will be requested in accordance with applicable law.

15. Third-Party Platforms and Services

The download, installation, purchase, or operation of PictoNexo may involve platforms operated by third parties, such as app stores, operating systems, or technology providers.

Data collected directly by such third parties under their own terms will be subject to their respective privacy notices and privacy policies.

PictoNexo does not control independent data-processing practices carried out directly by such third parties.

16. Data Retention

PictoNexo will retain personal data only for the time necessary to fulfill the purposes for which it was obtained and for any additional periods required to comply with legal or contractual obligations or to defend legal rights.

Once data is no longer necessary, it will be deleted, anonymized, or subjected to the corresponding blocking and subsequent deletion process in accordance with applicable law.

17. Personal Data Security

PictoNexo adopts reasonable administrative, technical, and organizational measures to protect personal data against:

  • Loss.
  • Damage.
  • Alteration.
  • Destruction.
  • Unauthorized access.
  • Unauthorized use or disclosure.

However, no technological system can guarantee absolute security.

18. Security Breaches

In the event of a security breach that significantly affects the rights of personal data subjects, PictoNexo will carry out the notices and actions required under applicable law.

19. ARCO Rights

The personal data subject or, where applicable, their legal representative may exercise the following rights:

  • Access: obtain information about the personal data we hold and the conditions under which it is processed.
  • Rectification: request correction of inaccurate, incomplete, or outdated personal data.
  • Cancellation: request deletion of personal data where legally appropriate.
  • Objection: request that certain processing of personal data cease where legally appropriate.

20. Procedure for Exercising ARCO Rights

To exercise ARCO rights, the data subject or their legal representative may submit a request through the following method:

Email: [PRIVACY EMAIL]

The request must include, where applicable:

  • Name of the data subject.
  • Information necessary to locate the relevant data.
  • A clear description of the right the individual wishes to exercise.
  • Documentation that allows us to verify the identity of the data subject or, where applicable, their legal representative.
  • Any additional information necessary to process the request.

For rectification requests, the data to be corrected must be identified and, where applicable, supporting documentation for the requested change must be provided.

PictoNexo will respond to requests within the time limits established by applicable law.

21. Withdrawal of Consent

When the processing of personal data is based on the data subject's consent, such consent may be withdrawn at any time, without retroactive effect, subject to the limitations established by applicable law.

The request may be submitted through:

Email: [PRIVACY EMAIL]

Withdrawal of consent may result in certain features that necessarily depend on such data becoming unavailable.

22. Limitation of the Use or Disclosure of Personal Data

The data subject may request the limitation of the use or disclosure of their personal data where legally appropriate.

The request may be submitted through:

Email: [PRIVACY EMAIL]

23. Deletion of Locally Stored Content

When certain data is stored exclusively on the device and PictoNexo does not have remote access to it, such data may be deleted through the features available within the application, by deleting the corresponding content, or, where necessary, by deleting application data through the options provided by the operating system.

A request submitted to PictoNexo cannot delete information that PictoNexo technically cannot access because it exists only on the user's device.

24. Changes to this Privacy Notice

This Privacy Notice may be modified as a result of:

  • Changes in applicable law.
  • New PictoNexo features.
  • Changes in the categories of data processed.
  • Changes in service providers or technologies used.
  • Changes in the purposes of processing.
  • Changes in our privacy and security processes.

Each version of the Privacy Notice may be identified by a version number and an update date.

Changes will be communicated through one or more available methods, which may include:

  • The PictoNexo application.
  • The official PictoNexo website.
  • An in-app notification.
  • Email, when PictoNexo has such contact information and it is appropriate to use it.

When a change involves new processing that legally requires consent, such consent will be requested before the processing takes place.

25. Previous Versions

PictoNexo may retain and publish previous versions of this Privacy Notice for historical, transparency, regulatory compliance, and evidence purposes regarding the terms applicable at a particular time.

26. Competent Authority

Personal data subjects retain the rights and legal remedies recognized under applicable Mexican personal data protection laws and may contact the competent authority when they believe their right to personal data protection has been violated.

27. Applicable Law

The processing of personal data carried out by PictoNexo shall be governed by the applicable laws of the United Mexican States concerning the protection of personal data held by private parties and any other applicable provisions.

28. Contact

For any questions regarding this Privacy Notice or the processing of personal data carried out by PictoNexo, you may contact us at:

Email: [PRIVACY EMAIL]

29. Consent

When applicable law requires consent for a specific data-processing activity, PictoNexo will provide the appropriate mechanisms to obtain such consent.

In the case of sensitive personal data, the consent requirements established by applicable law will apply.

30. Effective Date

This Privacy Notice becomes effective on September 7, 2026.

PictoNexo
Comprehensive Privacy Notice
Version 1.0
Last updated: September 7, 2026