PicusGOpicusgo.com · Politika privatnosti

PicusGO Privacy Policy

English version. The Croatian version is the original; translations are provided for convenience and do not reduce your rights.

Version 2.0, 1 October 2026.
Replaces the Privacy Policy of 15 April 2026.
Date of entry into force: the day of publication in the app and on picusgo.com.


In brief


1. Who is responsible for your data

The controller of your personal data is:

Agilos IT d.o.o.
Oreškovićeva ulica 6H, 10000 Zagreb, Croatia
Company ID (OIB): 32160662087
Data protection email: privatnost@picusgo.com

Contact person for data protection: Ivan Žuna, Director, privatnost@picusgo.com, Oreškovićeva ulica 6H, 10000 Zagreb, Croatia.

This Policy covers the PicusGO mobile app for iOS and Android, the web pages the app opens (the public tree map, the reports portal, the annual recap) and the email we send you. It does not cover third-party sites the app may link you to.


2. What data we collect

We collect all data directly from you, from your device while you use the app, or from a sign-in provider (Apple, Google) if you sign in that way. We do not buy data about you from third parties.

Category What data When we get it
Account email address, password (we store it only as a bcrypt hash, never in readable form), nickname, app language, registration date, date of first and last sign-in at registration and at every sign-in
Sign-in with Apple or Google your unique user identifier at that provider, email address (with Apple this may be an anonymized relay address), your name if the provider sends it, confirmation that the email address is verified if you choose that sign-in method
Guest session a temporary guest identifier, the nickname you chose, the tree you chose, your progress through the introductory steps if you try the app without an account
Profile if you choose to give them: first name, last name, city, country, company, avatar, the "first guardian" label on a tree; visibility settings (which of these others can see); answers from the introductory questionnaire (why you use the app, which missions interest you) when you fill in your profile or the introductory questionnaire
Location GPS coordinates of the tree you scan, of the report you send and of the place where you record a story; accuracy, altitude, heading and speed of the device at the moment of scanning (these help place the tree more precisely); a GPS "ping" roughly every 2 minutes only while the app is open on screen, which we use to check whether you are in a sponsored zone or at the site of a daily mission while you use the app with location turned on
Photos and videos three photos of a tree (the whole tree, a leaf, the bark), photos and videos of reports (hazardous tree, waste, ragweed, planting site), video tree stories with your message, images and videos in feed posts, your avatar when you take them or pick them from your gallery
User content posts, comments, likes, messages in public chat rooms, the text of reports and stories, reports of other people's content, the list of users you have blocked when you write or send them
Social connections who you follow and who follows you, who has viewed your profile, your tree or your streak (you can turn this off), your friend invite code and who registered through it while you use the social features
Game and EIT points your EIT points balance, a record of every award and every spend with the reason, ranger level, badges, quests, streaks, participation in leagues and leaderboards, EkoŠkolica (the daily eco quiz) results while you play
Payments The app currently has no purchases or payments and does not collect payment data. not applicable
Reward delivery (merch) first and last name, street, city, postal code, country, phone number, clothing size only if you request a physical reward; this is the only part of the app where we ask for an address
Push notifications your device's Expo push token, platform, device model name, app version, language, when the token was last seen; your notification settings (categories, quiet hours, frequency) when you allow notifications
App usage (analytics) which screens and buttons you use and for how long, which cards you open, how you move through the introductory steps, which variant of the EkoŠkolica A/B test you are in; platform and app version while you use the app
Technical device data device type (iOS/Android), app version, total device memory (so we can adjust how much content we load) while you use the app
Web pages on the public tree map, the reports portal and the annual recap page: the data Google Analytics records (IP address, browser, pages visited); on the app download page: IP address, browser, referral source and approximate location derived from the IP address; if you leave your email address through a friend's invite link before registering: email address, invite code, IP address and browser when you open those pages
Communication messages you send us by email, password reset requests (IP address and time, to protect against abuse), complaints when you contact us

About photo metadata (EXIF). Photos taken with the camera inside the app do not contain embedded GPS data, because the app reprocesses them before sending. If you pick a photo from your gallery, it may contain data about where and when it was taken.

What we do not collect. We do not ask for your date of birth, gender, address (except for reward delivery) or health data. The kilometres walked for rewards are calculated from the distance between your scans, not from a pedometer. We do not access your address book, your contacts or other apps. We do not process biometric data (see section 6).


3. Why we process data and on what legal basis

For each purpose we rely on one legal basis from Art. 6 of the General Data Protection Regulation (GDPR).

Purpose Data Legal basis
Running accounts, sign-in, password reset, guest session account, Apple/Google sign-in, guest session contract (Art. 6(1)(b))
Scanning and mapping trees, reports, stories, showing the map location of the tree and of the report, photos and videos, sensor data at the moment of scanning contract
Identifying the tree species and assessing whether a photo or a story is valid photos, videos, tree location, your level and number of trees contract (with the safeguards in section 6)
EIT points, quests, badges, leagues, leaderboards, EkoŠkolica game data, nickname, avatar, city (for local leaderboards) contract: leaderboards are part of the service; your nickname is shown (or your name if you chose that), the city only on local leaderboards; you can hide yourself in Settings
Social feed, comments, chat rooms, following, profile views user content, social connections contract
Notifications about your own activity (tree approved, points awarded, reply to your comment, your standing in the league) push token, notification settings contract
Motivational and promotional notifications (reminders to play, announcements, Stablo dana / "Tree of the Day") push token consent, which you give and withdraw in Settings > Notifications
Checking whether you are in a sponsored zone or at the site of a daily mission (GPS ping while the app is open) device location consent, which you give and withdraw in Settings > Privacy
Measuring app usage in order to improve it (which screens get used, where users drop out) usage analytics consent, which you give and withdraw in Settings > Privacy
Sending physical rewards delivery data contract
Security, preventing abuse and fraud (fake scans, artificial point farming, multiple accounts, attacks on the system) technical data, IP address at password reset, activity patterns legitimate interest: protecting the reward system, other users and our own infrastructure
Content moderation and acting on reports user content, reports, moderation logs legitimate interest: a safe community and meeting our obligations under the Digital Services Act
Forwarding reports of hazardous trees, waste and ragweed to the responsible city or municipality report content, location, photos, your nickname legitimate interest: the point of the app is that problems in nature actually get solved; you can hide your nickname with the "private entry" option
Answering your messages, complaints and requests communication legitimate interest (support) or legal obligation (consumer complaints, data subject rights)
Basic diagnostics of how the app runs (version, platform, loading errors) technical data legitimate interest: app stability
Publishing your photos or stories that show an identifiable person in our promotional material outside the app photos, videos consent, separate and not pre-ticked, which you can withdraw at any time
Web pages: measuring visits and campaigns Google Analytics, IP address and browser on the download page consent (cookies and similar technologies)

You can withdraw consent at any time, as easily as you gave it. Withdrawal does not affect the lawfulness of processing before the withdrawal. Where we rely on legitimate interest, you have the right to object (section 11); after an objection we continue processing only if we can demonstrate compelling legitimate grounds that override your interests.

Do you have to give us this data? To open an account you need an email address and a nickname; without them we cannot open an account. To scan a tree you need location and a photo; without them scanning does not work. Everything else (your name, city, avatar, analytics, notifications other than service ones) is your choice, and you can use the app without it.


4. Location

Location is at the heart of PicusGO: without it, a tree cannot be put on the map. That is why it matters that you know exactly what we do with it.

What we use
- The location of the tree at the moment you scan it, with the best accuracy your device can provide at that moment (in practice usually a few metres). It becomes part of the public map.
- The location of a report (hazardous tree, waste, ragweed, planting site). It becomes part of the public reports portal and is forwarded to the responsible city or municipality.
- The location of the place where you record a story, so that we can link the story to a nearby tree.
- A GPS ping roughly every 2 minutes while the app is open, which we use to check whether you are in a sponsored zone or at the site of a daily mission. These pings are not public.

What we do not do
- We do not track you in the background. The app has no background location permission on iOS or Android, and does not use one. As soon as you close the app or send it to the background, tracking stops.
- We do not sell location data and we do not use it for advertising.
- We do not try to infer from your locations where you live or where you work.

How you control location
- You grant location permission in your device's system settings and can withdraw it there at any time. Without it you cannot scan trees, but you can still view the map, the feed and the leaderboards.
- You can turn off the GPS pings for zones and missions separately in Settings > Privacy.
- You choose how you are shown next to trees and reports in Settings, at three levels (section 5): first level, default: your nickname; second level, your choice: your first and last name (and company), then also visible on the public web without signing in; third level, private entry: "Private user". For accounts of people under 16, only the nickname is shown until a parent or guardian approves otherwise. No level, not even private entry, hides the location or the photo. If you do not want a location to be public, do not scan a tree in your own garden or anywhere else that would reveal your address.

Approximate location from an IP address. On the app download page (the website, not the app) we derive the visitor's country and city from their IP address in order to measure campaigns. The external service ip-api.com is used for this.


5. What is public and what is not

PicusGO is a community app and much of its content is public by design. Here is how it breaks down:

Data Who can see it
The location and photos of every scanned tree, the species, the age estimate and the CO₂ estimate everyone, including visitors to the public web map who have no account
Reports (hazardous tree, waste, ragweed, planting) with photos, exact coordinates, status and the artificial intelligence assessment everyone, in the app and on the public reports portal on the web, without signing in; the reporter is shown according to the level you choose (row below)
How you are shown next to trees, reports, stories, leaderboards and your profile you choose in Settings, at three levels. First level, default: your nickname. Second level, your choice: your first and last name (and company); they are then also visible to everyone on the public web (the tree map, the reports portal), without signing in. Third level, private entry: "Private user". For accounts of people under 16, only the nickname is shown until a parent or guardian approves otherwise. No level hides the location or the photo.
Your avatar everyone
The "first guardian" label you write on a tree everyone
City and country on your profile only if you mark them as visible in Settings
Posts, comments, tree stories, likes signed-in users of the app. Stories are published in the feed automatically.
Messages in chat rooms all signed-in users in that language room. The rooms are public; there are no private messages.
Your position on the leaderboards and in the league, weekly points, number of trees signed-in users (global leaderboards, leagues) and everyone (local leaderboards by city and county)
Who you follow and who follows you signed-in users
Who has viewed your profile only you; you can stop your own views of other people's profiles from being recorded (Settings)
Email address, password, delivery address, push token, analytics, GPS pings nobody except us and the providers who process data on our behalf

The reports portal does not publish the addresses of the city departments a report has been forwarded to.

Photos and videos are stored on a server in the EU and are reachable through a link that is practically impossible to guess. Anyone who gets the link (for example when you share a card) can open that file without signing in.

Think before you post. Everything you scan, report or post is seen by the community, and trees and reports are seen by the whole internet. Do not post photos in which other people are recognizable without their agreement, and do not record stories in which people who have not agreed to it can be heard or seen. If someone posts a photo of you without your agreement, contact us (section 11) or report the content in the app.


5a. If you appear in someone else's recording

Users can take a photo or video that has you in it (your face, your voice, your house, your vehicle) even if you do not have a PicusGO account. We receive that data from the user who uploaded the recording, we process it on the basis of our legitimate interest in providing the service to the community (Art. 6(1)(f)) and, if the user posts it publicly, we show it to others. We do not recognize faces and we do not link a recording to your identity. If you want a recording that has you in it removed or blurred, write to privatnost@picusgo.com (you do not need an account) with a link or a description of where it is; we will reply within 15 days, and in clear cases we remove it straight away. You have all the rights set out in section 11.


6. Artificial intelligence and automated decision-making

In PicusGO, artificial intelligence (AI) does three things. Agilos IT d.o.o. is the provider of the PicusGO AI system within the meaning of Regulation (EU) 2024/1689 (the AI Act) and is answerable to you for how AI is built into it, even though the models themselves are developed by third parties.

6.1 Identifying the tree species

When you scan a tree, the three photos, together with the tree's GPS location, the sensor data (accuracy, altitude, heading) and a short summary of your context (ranger level, number of trees scanned, whether you are a digital ranger), are sent to our analysis service on a server in Germany, which uses OpenAI (a model from the GPT family) and Pl@ntNet (a French botanical platform) for the identification. Your name, email address and account identifier are not sent. We store the identified species, the age and CO₂ estimates and the result of the analysis.

6.2 Assessing photos, stories and reports

Video stories and reports (hazardous tree, waste, ragweed, planting site) are assessed by Google Gemini through the Vertex AI service, via our intermediary service on a server in Germany. We send the model only a link to the media file, the assessment instructions and the file type. We do not send your name, email address or account identifier. We store the assessment, the level, the number of points awarded, a short explanation, the model name and the time of the assessment.

The model also flags whether a recording contains people's faces or licence plates. That flag exists only so that such a recording is not published automatically as "breaking news". We do not identify who those people are, we do not compare faces and we do not create biometric templates. We do not process biometric data.

Model providers are contractually prohibited from using your photos or videos to train their models. Under those providers' contractual terms, your content is not used to train their models (Google Cloud: customer data is not used for training without our permission; OpenAI: data sent through the API is not used for training).

6.3 Generating card images

The image on every collectible card is generated by artificial intelligence (Google Gemini) from the photo of your tree, the species, the age, your message and the location text. Generated images are marked as AI content in the app and carry an invisible digital watermark (SynthID) which must not be removed.

Texts such as the fun facts about the Tree of the Day or the species descriptions are sometimes generated by artificial intelligence (OpenAI). Such texts are marked as AI content.

6.4 What AI decides and what rights you have (Art. 22 GDPR)

The AI assessment automatically decides:
- whether a scan is valid and which species the tree is,
- how many EIT points you get for a story or a report (none, the basic amount or a higher amount),
- whether a report is forwarded to the city or municipality.

The criteria are: whether the photo really shows a tree, whether the recording is original (and not a photo of a screen or someone else's picture), whether the story or report is on topic, whether the content is appropriate, and whether it shows people or licence plates. We publish the criteria in the app alongside every assessment. The assessment is shown as an "artificial intelligence assessment".

AI never closes an account, never takes away points already awarded and never deletes your content without a human decision.

If you disagree with an assessment, you have the right to:
- ask for the assessment to be reviewed by a member of our staff who is authorized to change the outcome,
- express your point of view,
- contest the decision.

Send your request to privatnost@picusgo.com or use the "Request review" button in the app, with a link to the tree, story or report. We answer within 15 days.


7. Who we share data with

We do not sell your data. We share it only with providers who help us run the app (processors, who act on our instructions and with whom we have contracts under Art. 28 GDPR) and with providers who decide on the processing themselves (independent controllers).

Recipient Role What it processes Where Basis for transfer outside the EU
A2 Hosting (hosting.com) processor the main database, the API, sending email, older photos server in the Netherlands; U.S. company EU-U.S. Data Privacy Framework (DPF), Implementing Decision (EU) 2023/1795; the entity A2 Hosting, Inc. / A2 Hosting, LLC is on the DPF list
Hetzner Online GmbH processor storage of photos and videos, our AI analysis service, the nightly database backup, test environments Germany (EU) not required
Google Cloud (Vertex AI, Gemini) processor assessment of stories and reports, generating card images in the European Union or the United States, depending on how the service is configured DPF, Google LLC is on the DPF list
Google (sign-in) independent controller verifying your Google account at sign-in global DPF
Apple (sign-in) independent controller verifying your Apple account at sign-in global DPF
OpenAI Ireland Ltd processor tree species identification, text generation Ireland / USA Standard Contractual Clauses (Decision (EU) 2021/914, Module 2)
Pl@ntNet (Agropolis Fondation / CIRAD, INRAE, INRIA, IRD) processor botanical identification from photos of the tree France (EU) not required
Expo (650 Industries, Inc.) processor delivery of push notifications (including the notification title and text), delivery of app updates USA DPF, 650 Industries, Inc. is on the DPF list (certification expires 23 October 2026)
Apple (APNs) and Google (FCM) independent controllers delivering push notifications to your device global DPF
Mapbox, Inc. processor displaying the map (the coordinates of the area shown) USA DPF, Mapbox, Inc. is on the DPF list
OpenStreetMap Foundation (Nominatim) processor turning a tree's coordinates into a city and county name EU not required
Open-Meteo not personal data weather forecast for grid coordinates (not yours) EU not required
ip-api.com processor approximate location from the IP address of a visitor to the app download page outside the EU
Google Analytics processor visit statistics for the web map, the reports portal and the annual recap USA DPF, Google LLC
Cities and municipalities we forward reports to independent controllers report content, location, photos, your nickname (except with "private entry") Croatia not required
The delivery service we choose for sending rewards processor name, address, phone number Croatia not required
Competent authorities independent controllers data we are legally obliged to hand over (courts, police, AZOP, HAKOM) Croatia / EU not required

Transfers outside the European Economic Area. Some providers process data in the United States. For providers listed under the EU-U.S. Data Privacy Framework, the transfer relies on Commission Implementing Decision (EU) 2023/1795. For OpenAI, which is not on that list, the transfer relies on the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914, Module 2) together with additional measures. You can request a copy of the safeguards at privatnost@picusgo.com.

Internal copies. The database is copied every night to a Hetzner server in Germany as a backup; the copies are kept for 10 days. For development and testing we use a copy of the database in which email addresses, passwords, Apple and Google sign-in identifiers and push tokens have been replaced or removed.

We contractually require every provider that processes data on our behalf to protect your data at least to the same standard described in this Policy and to use it only on our instructions.


8. How long we keep data

Data Retention period
Account and profile data while the account exists, then 30 days after a deletion request (a grace period in case you change your mind), after which it is permanently deleted
Trees, reports, cards and CO₂ statistics permanently, because they are part of the public ecological map; after your account is deleted they remain without your name, under the label "User#number" (Art. 17(3)(d) and Art. 89 GDPR, processing for purposes in the public interest and for statistical purposes)
Posts, comments, stories until you delete them or until the account is deleted
Photos and videos as long as the content they belong to exists; files with no owner are deleted after 48 hours (an unfinished upload), 7 days (unlinked sessions) or 30 days (rejected)
Chat room messages 30 days
Chat presence data 7 days
Reports of chat messages and chat moderation logs 180 days
Reports of posts and comments in the feed for as long as the case is open, then 12 months from the decision
EIT transactions while the account exists; after deletion, anonymized so that the points system stays consistent
Reward delivery address until delivery and the end of the complaint period, at most 2 years from delivery
Push tokens while they are active; inactive ones are deleted daily; notification settings for as long as the account exists
App usage analytics (individual events) 24 months, after which only aggregated daily figures without identifiers remain
GPS pings (zones and missions) 12 months
Profile views ("who viewed me") 90 days
IP address and browser at password reset 30 days
Website visit data (download page, friend invite links, email opens by cities) 12 months
Email address collected before registration (friend invite link) 12 months or until registration
Messages, complaints and requests to exercise your rights 12 months after they are resolved; the register of consumer complaints 1 year (Croatian Consumer Protection Act, Zakon o zaštiti potrošača)
Cron job logs and technical logs 60 days
Database backups 10 days

When the period expires, we delete the data or anonymize it so that you can no longer be identified.


9. Deleting your account

You can delete your account in the app: Settings > Delete account. You can also write to us at privatnost@picusgo.com or follow the instructions at https://picusgo.com/brisanje-racuna.

What happens:
1. The account is deactivated immediately and disappears from the app.
2. For 30 days you can change your mind: sign in with the same email address and password and the account comes back.
3. After 30 days the data is permanently deleted: email address, password, name, profile, push tokens, settings, analytics, GPS pings, delivery address, EIT balance, social connections and your content in the feed and in chat.
4. What stays: the trees, reports and cards you scanned stay on the public map, without your name (shown as "User#number"), because they are part of a shared ecological record. Your posts that other users have shared also stay, in the form in which they shared them.

If you do not want a particular tree to stay on the map even anonymously, write to us and we will assess the request under Art. 17 and Art. 21 GDPR.


10. Children and young people

The app may be used by people aged 13 and over. If you are under 13, you cannot open an account. If you are between 13 and 16 and live in the EU, you can use the core features without separate consent, because they are based on the contract, and features that need your consent (notifications that are not service notifications, analytics, promotional use of your content) are switched on only with the approval of a parent or guardian, in line with the age limit of the country where you live (Croatia and Germany 16, France 15, Spain 14). For accounts of people under 16, only the nickname is shown until a parent or guardian approves otherwise.

If we learn that an account was opened by someone under 13, we will delete the account and remove the data. If we learn that someone between 13 and 16 is using features that need consent without the approval of a parent or guardian, we switch those features off and delete the data collected on the basis of that consent.

For parents and guardians. If you believe that your child is using PicusGO without your approval, or you want your child's data deleted, write to privatnost@picusgo.com. Deleting data collected from a child is a right under Art. 17(1)(f) GDPR and we will act on it without delay.

Content posted by younger users is subject to the same publicity rules as everyone else's (section 5). We ask parents to go through what is public in the app together with their child.


11. Your rights

Under the GDPR you have the right:

Send your request to privatnost@picusgo.com from the email address of your account, or by post to our registered office. If we cannot establish that it is you, we will ask for further confirmation (for example a reply from the account's email address). We answer within 30 days; in complex cases we may extend that by up to 60 days, and we will tell you if we do. Exercising your rights is free of charge.

Complaint to a supervisory authority. If you believe that we are processing your data unlawfully, you have the right to lodge a complaint:

Croatian Personal Data Protection Agency (AZOP)
Selska cesta 136, 10000 Zagreb, Croatia
azop@azop.hr, www.azop.hr

If you live in another EU country, you can also lodge a complaint with the supervisory authority of your own country.


12. Notifications and communication


13. Cookies and similar technologies

In the app we do not use cookies. There are no advertising, marketing or tracking tools in the app, no crash reporting tools and no third-party analytics tools; we measure usage with our own system (section 3). We do not ask for tracking permission on iOS (App Tracking Transparency), because we do not track you across other apps or websites. The data the app stores on your device (your account identifier, guest session data, push token, the last known location for the map, the queue of photos waiting to be sent, a temporary copy of photos for up to 48 hours, a local copy of chat messages) serves only to run the app and is deleted when you sign out or uninstall. The map uses the Mapbox SDK; Mapbox records which area of the map is loaded.

On the web pages (the public tree map, the reports portal, the annual recap, the download page) we use Google Analytics to measure visits. Those cookies are set only after you consent in the cookie notice; without consent the page works without measurement. The annual recap page is reachable only through a signed personal link and is marked so that search engines do not index it. The picusgo.com landing page uses neither cookies nor analytics.

A device permission is not consent. The permission you give the operating system (for location, camera, microphone or notifications) technically opens access, but it is not the same as consent under data protection law; we ask separately in the app for consent to processing that is not necessary, and you can withdraw it in Settings.


14. How we protect your data

We take technical and organizational measures appropriate to the risk:

No system is completely secure. We recommend a strong, unique password and signing in with Apple or Google. If you suspect that your account is being misused, contact us immediately.


15. Changes to this Policy

We may change this Policy when we change app features or service providers, or when the law requires it. We will tell you about any material change at least 30 days before it takes effect, by a notice in the app and by email, with a clear description of what is changing. Minor changes (corrections, extra clarifications) are published with a new date at the top of the document. Every version is archived and available on request.

Change history


16. Contact

For any question about privacy, to exercise your rights or to report a problem:

Agilos IT d.o.o., Oreškovićeva ulica 6H, 10000 Zagreb, Croatia
Email: privatnost@picusgo.com
For general support: podrska@picusgo.com

Contact point for the competent authorities under Regulation (EU) 2022/2065 (the Digital Services Act): privatnost@picusgo.com, languages of communication Croatian and English. The Digital Services Coordinator in the Republic of Croatia is HAKOM.

This Policy was originally written in Croatian. Translations are provided to make it easier to understand; in case of any difference, the Croatian version prevails, on the understanding that a translation cannot take away the rights you have under the law of the country where you live.

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