Privacy Policy

This is the Privacy Policy of apps of Papcorns Dijital Hizmetler Anonim Sirketi and its various & next versions (hereinafter collectively referred to as "us", "we", or "our") and is incorporated into and is subject to our Terms of Use which can be found at here. In this Privacy Policy, we refer to our products and services as the "Service". Please read on to learn more about our data handling practices. Your use of the Service signifies that you agree with the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use the Service.

What Information Do We Collect?

When you install and use the Service, personally identifiable information about you may be collected. If you create an account, you are asked to provide your email address. Providing any other personal information is optional.

We may also collect and gather non-personally identifiable information, such as country of residence and preferences. In addition, we may collect and store information about your usage of and interaction with the Service and our websites, including which features you use, usage by geographies, device and connection information, IP address, device capability, bandwidth, statistics on page views, network type and traffic to and from our websites. To protect the Service and our users against fraud, abuse and automated use, we also collect device integrity signals, aggregated touch and motion-sensor statistics (never touch coordinates or what you tap or type), whether accessibility features are turned on, and, on Android, whether certain known automation apps are enabled. This information is used only for security and fraud prevention, never for advertising, and is deleted after 90 days.

Our applications allow you to submit photos, videos and text prompts in order to generate or edit content using AI features. Content you submit, and the results generated from it, are stored on our servers so that they remain available to you in the app. We do not make this content available to other users of the Service, and we do not publish it.

We may also collect and gather user content (e.g., photos, videos, prompts and other materials) that you create on the Service. If you do not agree with all the terms of this Privacy Policy, please do not use the Service. Purchases and subscriptions are processed by Apple or Google through the App Store or Google Play. We do not receive, process or store your payment card details. We may store information about your subscription status and transaction history, which may include the date, time and amount of the transaction.

We also collect error-reporting information if the Service crashes or hangs up so that we can investigate the error and improve the stability of the Service for future releases. In general these reports do not contain personally identifiable information, or only incidentally. As part of these error reports, we receive information about the type and version of your device, the device identifier, the time the error occurred, the feature being used and the state of the application when the error occurred. We do not use this information for any purpose other than investigating and fixing the error.

Sharing of Your Information

We will not rent or sell your information to third parties without your consent, except as noted in this Privacy Policy. This section does not apply to face data. Face data is shared only as described in the "Face Data" section below. Parties with whom we may share your information:

- We may share your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that is part of, or that become part of that group ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Service, including by providing analytics.

- We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.

- We may also share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of users our app receives. This information does not contain any personal or personally identifiable information, and is used to develop content and services that we hope you will find of interest.

- We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

How Do We Use The Information We Collect?

We use or may disclose your personal information only as follows:

- To verify your identity;

- To allow your use of certain features of the Service that may be offered from time to time (such as Premium Services (see our Terms of Use));

- To deliver to you any administrative notices, alerts and communications relevant to your use of the Service;

- For internal operations, including troubleshooting problems, data analysis, testing, research, improvements to the Service, detecting and protecting against error, fraud or other illegal activity;

- When we have a good faith belief that the law, any legal process, law enforcement, national security or issue of public importance requires disclosure;

- To protect and defend our rights or property (including to enforce our Terms of Use and other agreements); or

- In connection with a corporate transaction involving us, such as the purchase or sale of a business unit, an acquisition, merger, sale of assets, or other similar event.

Your User Profile

The information you enter into your user profile (your "Profile") is used only to provide the Service to you. You control your Profile and you can access and modify it from the application at any time. Your Profile is not shared with, visible to, or discoverable by other users of the Service.

Data Access and Removal

You can always control what information you choose to share with us on the Service. To do so, you can change your settings in the Service or in your mobile device. Alternatively, you can remove the Service from your mobile device entirely. You can remove your data anytime you want. If you ask us to delete your account, we will use commercially reasonable efforts to remove your data from our servers.

Service Providers

In certain instances, we may have contracts with third parties to provide products and/or services in connection with the Service. In those cases, we may share your personal information with our third-party service providers, but only in connection with providing the services to you. For example, we may share your phone number or email with third party SMS and email providers to deliver the authentication SMS or email to you when you register. We contractually require that these third parties use your information solely to deliver SMS or email to you and to use appropriate security measures to protect your information. In addition, certain servers are owned and hosted by third party service providers. Except as stated in the "Face Data" section below, this Privacy Policy does not apply to the practices of third party service providers.

Outbound Links

If you accessed a website, product or service provided by a third party, including through the Service, such third party may also collect information about you. Please see the privacy policies of each such third party for more information about how they use the information they collect. This Privacy Policy does not apply to any exchange of information between you and any third party.

Security

Protecting user privacy and personal information is a top priority for us. We make substantial efforts to ensure the privacy of all personally identifiable information you provide to us. Access to all personally identifiable information is restricted to those employees, contractors, agents and third-party service providers who need to know that information in order to provide, operate, develop, maintain, support or improve the Service. We use password protection, access logs, and system monitoring to safeguard the confidentiality and security of all member information. In addition, due to the inherent nature of the Internet and related technology, we do not guarantee the protection of information under our control against loss, misuse or alteration.

Face Data

Some of our apps include features that detect or analyze faces in images or videos you choose to provide, for example to apply an AI-generated edit, filter, style, retouch or effect to a portrait. This section describes how we handle face data and applies in addition to the rest of this Privacy Policy. If any other section of this Privacy Policy conflicts with this section, this section controls with respect to face data.

1. What face data we collect and how we collect it

We process face data only from content that you actively and deliberately submit: a photo or video that you select from your device library, or that you capture with your camera after granting the relevant permission. We do not scan your photo library in the background, we do not collect face data passively, and we do not obtain face data from any other app, data broker or third-party source.

Depending on the feature you use, face data may consist of: (a) the image or video you submit that contains a face; (b) facial landmarks, geometry or measurements derived from that image (such as the relative position of eyes, nose and mouth) that are computed solely in order to place or apply the effect you requested; and (c) the edited or generated output produced from it.

We do not create or store a persistent faceprint, face template or other biometric identifier. We never use face data to identify, authenticate, verify or recognize you, and we do not use face data to match or link the same person across different images, sessions, devices or accounts.

2. All uses of face data

We use face data only to:

- perform the specific edit, effect, filter, style or generation you requested;

- deliver the resulting output back to you and keep it available in your in-app history so that you can view, re-use or download it later;

- run the safety and content-moderation checks needed to prevent unlawful or abusive use of the service;

- diagnose and fix technical errors in the processing pipeline.

We do not use face data for advertising, marketing, profiling, or identity recognition. We do not sell face data, and we do not disclose face data to data brokers or advertising networks. We do not use your face data to train, fine-tune or otherwise improve our own or any third party's AI or machine-learning models.

3. Face data sharing and disclosure

In order to generate the result you requested, the content you submit is transmitted to the third-party AI processing providers that operate the models we use. These providers are:

- Google LLC (Gemini API)

These providers act solely as our service providers. They process face data only on our documented instructions and only to return the requested output to us. They are not permitted to use face data for their own purposes, to train their models on it, to sell it, or to disclose it to anyone else.

We confirm that any third party with whom we share face data is contractually required to provide the same or equal protection of face data as stated in this Privacy Policy, including equivalent obligations regarding permitted use, confidentiality, security safeguards, retention limits and deletion.

We do not share face data with any other third party, except where we are required to do so by law or valid legal process.

4. Face data retention

We retain face data only for as long as it is needed for the purposes described in section 2. Specifically:

- Content you submit and the outputs generated from it are stored so that they remain available to you in the app, and are kept until you delete them, ask us to delete them, or delete your account.

- Our AI processing providers retain the content only transiently, for the time needed to process your request and return the result to us.

- Any copy you save to your device remains on your own device and is under your control.

We do not retain face data for any period longer than is necessary for these purposes, and we delete it once it is no longer needed or once you ask us to.

5. Face data deletion and withdrawing your consent

You can withdraw your consent to our collection and use of face data at any time, and you can have your face data deleted, in the following ways:

- Withdraw consent: stop using the face-related features, and/or revoke the camera and photo library permissions for the app in your device settings. Once consent is withdrawn, we will not process any new face data.

- Delete by request: email us at [email protected], or use the contact or support option inside the app. If you have an account, write from the email address associated with it; otherwise describe your request so that we can locate the data held about you. We will delete the relevant face data, instruct our processing providers to do the same, and confirm the deletion without undue delay and in any event within 30 days. There is no charge for this and you do not need to give a reason.

- Deleting the app removes the copies stored locally on your device.

Withdrawing consent or requesting deletion does not affect the lawfulness of processing carried out before the withdrawal or request. Deletion is permanent and cannot be undone.

6. Contact

For any question or request concerning face data, contact us at [email protected]

Age

The Service is not directed to children under the age of thirteen (13) and we do not knowingly collect personally identifiable information from children under the age of thirteen as part of the Service. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of the Service, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Service.

Changes To Our Privacy Policy

We reserve the right at our discretion to make changes to this Privacy Policy. You may review updates to our Privacy Policy at any time via links on our website. You agree to accept electronic communications and/or postings of a revised Privacy Policy on our website, and you agree that such electronic communications or postings constitute notice to you of the Privacy Policy. We reserve the right to modify this policy from time to time, so please review it frequently. If we make material changes to this policy, we will notify you by publishing a revised Privacy Policy or by means of a notice on our website, or as required by law. You agree to review the Privacy Policy periodically so that you are aware of any modifications. You agree that your continued use of the Service after we publish a revised Privacy Policy or provide a notice on our website constitutes your acceptance of the revised Privacy Policy. If you do not agree with the terms of the Privacy Policy, you should not use the Service.

Your rights

If you wish to use any of the rights described below, you may contact us at any time by emailing us at [email protected]. We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

1. Right to request access

You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:

- a. the purposes of the processing; the categories of personal data concerned

- b. the recipients or categories of recipient to whom the personal data have been or will be disclosed

- c. the envisaged period for which the personal data will be stored

Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.

2. The right to object

You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there is compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use the Service will cease automatically.

3. Right to rectification and erasure

You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR. Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR:

- a. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,

- b. if you have withdrawn your consent and there are no other legal grounds for the processing,

- c. if you have objected to the processing and there are no overriding legitimate grounds for the processing,

- d. the personal data have to be erased for compliance with a legal obligation in Union or Member State law,

- e. the personal data have been unlawfully processed or the personal data have been collected in relation to the offer of information society services.

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.

4. Right to withdraw consent

You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest the right to withdraw consent. If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR. If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. Please note that if you withdraw your consent, your user license to use the Services will cease automatically. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

5. The right to data portability

You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.