Privacy Policy – AI Video, Face Swap: Editor

Effective Date: 01.04.2026

This Privacy Policy has been prepared by (“MB Oyun Yazılım ve Pazarlama A.Ş. ”) acting as the data controller, in accordance with Article 10 (Disclosure Obligation of the Data Controller) and Article 11 (Rights of the Data Subject) of the Turkish Personal Data Protection Law No. 6698 (“PDPL”).

Company Information

Company Name: MB Oyun Yazılım ve Pazarlama A.Ş.

Address: Reşitpaşa Mah. Katar Cad. Arı 2 Binası

No: A Blok / 4 / 1 İç Kapı 501

34467 Sarıyer / İstanbul, Turkey

E-mail: nongaming@madbytegames.com

This Privacy Policy explains how your personal data is collected, processed, used, transferred, stored, and protected while using the mobile application (“AI Video, Face Swap: Editor”).

By using the App, you acknowledge that you have read and understood this Privacy Policy.

1. Principles of Personal Data Processing

Your personal data is processed:

• In accordance with the law and good faith principles
• Accurately and kept up to date
• For specific, explicit, and legitimate purposes
• In a manner limited and proportionate to the purpose
• For the period required by relevant legislation or processing purpose

2. Collection of Personal Data

Your personal data may be collected:

• Directly from you through the App
• Through customer support communications
• Automatically via technical systems during app usage

Data is stored securely in the Company’s systems and authorized third-party service providers.

3. Processed Personal Data and Purposes

The Company may process the following data:

• User Information: username, email address, phone number
• Technical Data: device model, operating system, app version, performance data
• Log Data: IP address (for security, fraud prevention, and legal obligations)

Purposes of processing include:

• Creating and managing user accounts
• Providing customer support services
• Improving app performance and user experience
• Preventing fraud and ensuring security
• Complying with legal obligations

4. Information Regarding Mobile Applications

Downloading, using, or making in-app purchases in the App does not result in the direct transfer of personal data to the Company beyond what is technically required.

All in-app purchases are processed via Apple App Store or Google Play Store.

Even if you consent to personalized advertising, advertising-related interactions are processed anonymously.

Third-party services used may include:

• Amplitude
• AppLovin MAX
• AppsFlyer
• Facebook
• Firebase
• Unity

Each provider processes data under its own privacy policy.

5. Notifications

Push notifications are sent only with your explicit consent.

You can manage notification permissions via your device settings at any time.

6. Legal Grounds for Processing

Personal data is processed based on:

• Explicit legal obligations (PDPL Art. 5/2-a)
• Necessity for contract performance (Art. 5/2-c)
• Fulfillment of legal responsibilities (Art. 5/2-ç)
• Establishment, use, or protection of legal rights (Art. 5/2-e)

Processing under these grounds does not require explicit consent.

7. Processing Based on Explicit Consent

Certain optional data (such as profile details) may be processed only if you voluntarily provide consent.

Marketing communications (e-mails, notifications) are sent only if explicit consent is given and can be withdrawn at any time.

Withdrawal of consent does not affect prior lawful processing.

8. Transfer of Personal Data

Personal data may be transferred without consent when required:

• To authorized service providers
• To banks, legal advisors, auditors
• To judicial and administrative authorities

Transfers are limited, proportionate, and compliant with PDPL Article 8.

9. Access to Data from Abroad

Personal data is stored on servers located in Turkey.

Limited access from abroad may occur for technical support purposes and is based on explicit consent under PDPL Article 9.

10. Data Security, Retention, and Destruction

The Company implements appropriate technical and administrative security measures.

• User account data: retained for 10 years after last activity
• Purchase-related data: retained for 10 years
• Marketing data: retained for 2 years after last activity

After retention periods, data is deleted, destroyed, or anonymized.

11. Your Rights as a Data Subject

Under PDPL Article 11, you have the right to:

• Learn whether your data is processed
• Request information regarding processing
• Learn the purpose of processing
• Request correction or deletion
• Object to automated decision-making
• Request compensation for unlawful processing

Requests can be sent to:

📧 nongaming@madbytegames.com

12. Complaint Right

If your request is not resolved, you may apply to:

Personal Data Protection Board (KVKK)

Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4

06520 Balgat / Ankara – Turkey

📞 +90 312 216 5000

🌐 http://www.kvkk.gov.tr/