Privacy Policy

Last modified: April 2024

1. Objective

Smart AI Mate (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of information we may process when you install and/or use “Smart AI Mate” software application for mobile devices (the“App”, “our App”).

This Privacy Policy describes which data we collect, how we intend to use, store, protect and share the data we collect, how you can withdraw your consent for the processing of these data and how you can correct and revise the data.

2. Collection of Personal Data and Method

The personal data of users collected and used by us in particular, are as follows: your order information if you make a purchase through in-app purchase, and identifier foradvertisers designated in your mobile device used in accessing our services (The Identifierfor Advertisers-IDFA), identifier for vendors/developers designated your mobile device (TheIdentifier for Vendors-IDVF) and Internet Protocol Address-IP Address

We may collect your above mentioned data directly from you through electronic or physical mediums, your mobile device, third party applications or third party sources which you can access our application through these mediums such as Apple App Store, Google Play AppStore (similar platforms together with “App Stores”), for the purposes of compliance with legal obligations, enhancing our services, administering your use of our services, as well asenabling you to enjoy and easily navigate our services.We may collect your log data generated while you are using our services/applications(through our products or third party products). This log data may include information such asyour device’s Internet Protocol (“IP”) address, device name, operating system version, theconfiguration of the app when utilizing our service/application, the time/date of your use ofthe service/application, and other statistics

3. Purposes of Processing Personal Data and Legal Reasons

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

(a) To make our service available. We use functional information and information that is processed automatically to provide you with all requested services.

(b) To improve, test and monitor the effectiveness of our App. We use information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.

(c) To provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.

(d) To communicate with you. We use the contact information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

(e) To prevent fraud and spam, to enforce the law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

4. Sharing of Your Information

We will share your information with third parties only in the ways that are described in this Privacy policy. We adhere to the U.S. Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment.

Please note that while integrating external services we choose third parties that can assure they apply all necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.

We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.

We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.

5. Transferring Personal Data to Third Parties

The procedures and principles to be applied for transferring of personal data are regulated inarticles 8 and 9 of the PDP Law, and the personal and special categories of data of the supplier may be transferred to third parties within the country or abroad since we may useservers and cloud systems located abroad.Your personal data may be transferred abroad for the following reasons:

● Conducting storage and archive activities

● Conducting business activities

● Conducting after-sales support services for goods/services

● Managing customer relationship management processes

We may also transfer your personal data to services providers of our Company, third parties such as Facebook SDK, Adjust and Firebase Analytics which are embedded into our service for the following purposes:

● Sharing identity, communication and transaction security information with authorized public institutions and organizations for the purpose of execution of activities in compliance with legislation, monitor and execution of legal affairs, informing authorized persons, institutions and organizations.

● Sharing customer transaction information to manage after-sales support services,conduct business activities and manage customer relationship management processes

6. Your Rights as the Data Subject

Pursuant to Article 11 of the PDP Law, you may request the following regarding your personal data by applying to us:

● Learn whether or not your personal data have been processed;

● Demand for information as to if your personal data have been processed;

● Learn the purpose of the processing of personal data and whether data are used in accordance with their purpose;

● Know the third parties in the country or abroad to whom your personal data have been transferred;

● In case the personal data is processed incompletely or inaccurately; requesting notification of the transactions made under this scope to third parties to whom personal data have been transferred;

● Request deletion, destruction or anonymization of personal data if the reasons for theprocessing have disappeared and request notification of the transactions made underthis scope to third parties to whom personal data have been transferred;

● Object to occurrence of any result that is to your detriment by means of the analysis of personal data exclusively through automated systems;

● Request compensation for the damages in case you incur damages due to unlawful processing of your personal data.

Where General Data Protection Regulation (GDPR) is applicable, data subjects have the following rights:

● Right of access - Learning whether personal data is being processed and, if so,accessing your personal data and the information regarding the processing of your personal data,

● Right to correction -To request the correction of information that you believe is inaccurate or the completion of information that you believe is incomplete by us,

● Right to delete – To request deletion of personal data under the conditions stipulated in GDPR,

● The right to restrict processing - To request the restriction of the processing ofpersonal data under the conditions stipulated in the GDPR,

● Right to object to processing - To object to the processing of personal data under theconditions stipulated in the GDPR,

● Right to data portability - To request the data collected by us to be transferred directly to another organization or under certain conditions,

● Objection to the occurrence of a result against the person himself/herself, by analyzing the processed data exclusively through automatic systems, including profiling.

7. Security

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us through the contact form displayed below.