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Privacy Policy

Privacy Policy

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Last updated: September 7, 2026

MOR TOSBAA MOBIL COZUMLER ANONIM SIRKETI ("Mor Tosbaa", the "Company", "we", "us" or "our") develops and publishes mobile applications and provides related services. This Privacy Policy explains how we collect, use, disclose, transfer and retain Personal Data when you access or use our applications or related services.

We use Personal Data to provide, secure and improve the Service. We process and disclose Personal Data only as described in this Privacy Policy and as permitted by applicable law.

1. Interpretation and Definitions

1.1 Interpretation

Capitalised words have the meanings set out below. These definitions apply whether the words appear in the singular or plural.

1.2 Definitions

  • Account means a unique account created for you to access the Service or parts of the Service.

  • Affiliate means an entity that controls, is controlled by, or is under common control with the Company.

  • Application means any mobile application provided by the Company that links to or incorporates this Privacy Policy.

  • Company means MOR TOSBAA MOBIL COZUMLER ANONIM SIRKETI, a company incorporated under the laws of Türkiye, with its registered office at Hürriyet Mahallesi, Dr. Cemil Bengü Caddesi, No. 4, İç Kapı No. 13, Kağıthane, İstanbul, Türkiye.

  • Device means any computer, mobile phone, tablet or other device that can access the Service.

  • Personal Data means any information relating to an identified or identifiable individual.

  • Service means the Applications and any related services provided by the Company.

  • Service Provider means a third party that processes data for or provides services to the Company in connection with the Service.

  • Usage Data means data collected automatically from the use or operation of the Service.

  • You means the individual accessing or using the Service.

2. Personal Data We Collect

Depending on the Application and the features you use, we may process the following categories of Personal Data:

  • Contact and account data, such as your name, email address, account identifier, account settings and support details.
  • AI Inputs that you voluntarily provide, including text prompts, messages, instructions, titles, descriptions, photos, images, videos, video frames and audio recordings.
  • AI Outputs generated in response to your request, including generated or transformed images, videos, audio, text and related content.
  • Transaction data associated with subscriptions and in-app purchases, such as product, purchase status and transaction identifiers. Payment details are processed by the relevant app store or payment provider, as applicable.
  • Usage and technical data, such as IP address, Device type, operating system and version, unique or advertising identifiers where permitted, app configuration, feature interactions, access times, crash information and diagnostic data.
  • Information you provide when you contact us, including the content and metadata of support communications.

Some Applications may request access to your camera, photo library or microphone. Access is requested through your Device settings and is used only for the feature you choose. You may change these permissions through your Device settings.

3. AI-Powered Features

3.1 AI Inputs and Outputs

Certain Applications include AI-powered features that allow you to submit AI Inputs to generate, edit, transform, search for or otherwise create content. We process the AI Inputs and related technical information only as necessary to provide the feature you request, return the AI Output, maintain security and prevent misuse.

Where an Application provides a conversational AI or chatbot feature, we may retain your messages, prompts, the responses generated for you and related thread information on our systems so that the conversation history can be displayed and the AI provider can receive the context needed to continue the conversation. This information is used only to provide and maintain the conversational feature and for the limited security and legal purposes described in this Privacy Policy.

We do not use AI Inputs or AI Outputs for advertising, marketing, personal identification, user profiling or cross-app tracking. We do not use them to train our own AI models.

3.2 Photos, Videos and Face Data

Photos, images, videos and video frames that you voluntarily upload or capture may contain faces or facial features ("Image and Face Data"). We do not automatically collect Image and Face Data. We do not create, extract, store or analyse biometric templates, facial geometry, facial maps or identifiers for personal identification or authentication.

Image and Face Data is processed only to provide the AI-generated content, visual search, image or video transformation, or other AI feature that you request. We do not use Image and Face Data for identification, authentication, advertising, marketing, profiling, analytics or tracking.

3.3 Audio and Text Data

Where an Application offers relevant features, text prompts, messages, instructions and audio recordings that you voluntarily submit may be processed to generate or transform text, images, video, audio or other content requested by you. We do not use this content for advertising, marketing, profiling, identification or tracking.

3.4 Permission Before Third-Party AI Processing

Before AI Inputs are transmitted to a third-party AI provider, the Application displays an in-app disclosure explaining the categories of data involved, the purpose of the processing and the relevant third-party AI providers by name. Transmission occurs only after you affirmatively agree to the disclosure. If you decline or close the notice, the data will not be transmitted and the relevant AI feature will not be available.

4. How We Use Personal Data

We may use Personal Data for the following purposes and legal bases, as applicable:

  • To provide and maintain the Service, perform the contract with you and make requested features available.
  • To process AI Inputs and generate the AI Outputs you request, based on performance of the Service and your affirmative permission for third-party AI processing.
  • To manage Accounts, subscriptions and purchases and to provide customer support.
  • To monitor performance, diagnose errors and improve the security and operation of the Service, based on our legitimate interests in operating a reliable and secure service.
  • To send service-related notices, updates and security communications.
  • To send marketing communications where permitted by law and subject to any consent or opt-out right required by law. AI Inputs, Image and Face Data and AI Outputs are excluded from this purpose.
  • To comply with legal obligations, respond to lawful requests, establish or defend legal claims and prevent fraud or misuse.

We will not use AI Inputs, Image and Face Data or AI Outputs for purposes incompatible with those described in Section 3.

5. How We Share Personal Data

We may disclose Personal Data in the following limited circumstances:

  • Service Providers: to providers that support hosting, security, diagnostics, analytics, customer support, subscription management, payment processing or other Service operations, only to the extent necessary for the relevant service.
  • Third-party AI providers: as described in Section 6, only to provide the AI feature you request and only after the in-app disclosure and affirmative permission described in Section 3.4.
  • Affiliates: where necessary to operate and administer the Service, subject to appropriate safeguards.
  • Business transfers: in connection with an actual or proposed merger, acquisition, financing, reorganisation or sale of assets, subject to appropriate confidentiality and data-protection measures.
  • Legal and safety purposes: where required by law or reasonably necessary to protect rights, safety and security, prevent wrongdoing or establish, exercise or defend legal claims.
  • With your consent: for another purpose that we clearly explain to you before disclosure.

We do not sell Image and Face Data, AI Inputs or AI Outputs. We do not share them with business partners for advertising, marketing or promotional purposes.

6. Third-Party AI Services and APIs

Depending on the Application and the AI feature used, AI Inputs and related technical information may be transmitted to one or more of the following providers:

These providers receive and process data only as necessary to generate or return the content or response you request. We require our providers to apply appropriate contractual, confidentiality, security and data-protection safeguards and to provide the same or equivalent protection described in this Privacy Policy. We do not disclose AI Inputs to providers for their own advertising, marketing or independent model-training purposes. A provider's technical retention and processing practices may vary according to the provider, feature, account or API configuration and applicable terms, as further explained in Section 8.

Provider availability and the provider used for a particular request may vary by Application, feature, region and technical configuration. Some providers may act as an integration platform and transmit AI Inputs to the model provider required to fulfil your request. The applicable in-app disclosure identifies the relevant third-party AI providers by name before transmission.

7. Third-Party SDKs and Advertising Platforms

Depending on the Application and the features used, we may use third-party SDKs and platforms to manage subscriptions, analyse app performance and usage, measure marketing attribution, and deliver or optimise advertising. These services may process information such as Device and app identifiers, IP address, approximate location, subscription or purchase information, advertising interactions, usage data and diagnostic information, as applicable:

The providers used may vary by Application, platform, region and configuration. We disclose data only as necessary for the relevant service and subject to applicable law. Where required, advertising identifiers, personalised advertising, cross-app tracking or similar processing are enabled only after the required consent or Device permission has been obtained. Please review the providers' privacy policies for further information about their processing practices.

8. Retention and Deletion

We retain Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing the Service, maintaining security, complying with legal obligations, resolving disputes and enforcing agreements.

We do not permanently store Image and Face Data or maintain biometric templates or persistent face databases. Images, videos, video frames and audio submitted for generation or transformation are not retained on our systems beyond the period reasonably necessary to transmit and complete the request and return the result, unless you expressly choose to save an output or a longer period is required for security, abuse prevention, legal compliance or dispute resolution.

For conversational AI or chatbot features, we may retain messages, prompts, generated responses and related thread information for as long as reasonably necessary to maintain and display your conversation history and allow you to continue the relevant thread. Conversation history is deleted or anonymised when it is no longer needed for this purpose, when you delete it using an available in-app control, or following a valid deletion request, subject to limited retention required or permitted by law, security, abuse prevention or dispute resolution.

Third-party AI provider retention may vary according to the provider, feature, account configuration and applicable terms. Where zero-data-retention or equivalent controls are enabled, the provider applies those controls in accordance with its terms. Providers may delete or de-identify data in accordance with their applicable terms, retention practices and legal or security obligations.

Usage and diagnostic data may be retained for a longer period where necessary to maintain security, prevent fraud, improve functionality or comply with law. When Personal Data is no longer required, we delete or anonymise it.

9. International Transfers

The Company is established in Turkiye. Our Service Providers, including third-party AI providers, may process Personal Data in countries other than the country in which you live. Those countries may have different data-protection laws.

Where required by applicable law, we use recognised safeguards for international transfers, such as adequacy decisions, approved contractual clauses or other lawful transfer mechanisms, and take reasonable steps to protect Personal Data in accordance with this Privacy Policy.

10. Your Rights and Choices

Depending on applicable law and subject to legal limitations, you may have the right to:

  • request access to and a copy of your Personal Data;
  • request correction of inaccurate or incomplete Personal Data;
  • request deletion of your Personal Data;
  • request restriction of, or object to, certain processing;
  • request portability of Personal Data you provided to us;
  • withdraw consent where processing is based on consent, without affecting earlier lawful processing; and
  • lodge a complaint with your local data-protection authority.

You may manage camera, photo-library and microphone permissions through your Device settings. You may decline or close the AI-processing disclosure; in that case, your AI Inputs will not be transmitted, but the relevant AI feature cannot be provided.

To exercise a privacy right, contact us using the details in Section 16. We may need to verify your identity and will respond within the period required by applicable law.

11. Account and Data Deletion

Where an Application provides an Account, it may allow you to update or delete certain Account information within the Application. You may also contact us to request access to, correction of or deletion of Personal Data. We may retain limited information where required by law or where another lawful basis permits retention.

12. Security

We use commercially reasonable administrative, technical and organisational measures designed to protect Personal Data. However, no method of internet transmission or electronic storage is completely secure, and we cannot guarantee absolute security.

13. Children's Privacy

The Service is not directed to children under 13, and we do not knowingly collect Personal Data from children under 13. An individual Application may impose a higher minimum age, as stated in its applicable terms, app-store listing or in-app notice.

If we learn that a child has provided Personal Data contrary to the applicable age requirement, we will take reasonable steps to delete it. A parent or guardian may contact us using the details below.

14. Third-Party Links

The Service may contain links to websites or services that we do not operate. We encourage you to review the privacy policy of each third-party service. We are not responsible for the content or privacy practices of third-party websites or services.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version and revise the "Last updated" date. Where required, we will also provide notice through the Service or by another appropriate method before a material change takes effect.

16. Contact Us

If you have questions or requests regarding this Privacy Policy, contact us: