Privacy Policy

Last Updated: February 2024

Introduction

At Marsby Teknoloji A.Ş. ("we," "us," "our"), safeguarding your privacy is paramount. This Privacy Policy elucidates our stance and actions concerning the protection of personal data within the ChatNow application ("the App"). "Personal data" or "personal information" refers to any data about an identifiable individual, obtainable directly or indirectly through identifiers such as names, identification numbers, location data, or factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.

This Policy applies universally to users of the App ("Users").

As the primary data controller under GDPR guidelines, we pledge to uphold your privacy rights.

By using the App, you signify your comprehension and concurrence to the terms outlined herein.

For California Residents

Under the California Consumer Privacy Act (CCPA), residents have the right to understand how their personal information is processed. This includes disclosure requests regarding categories, sources, purposes of data processing, and third-party sharing. For detailed navigation through our privacy practices, please refer to the following sections.

Consent to Share Consumption Data with Apple:

By using our app and making in-app purchases, you consent to our sharing of data regarding your usage and consumption of purchased content with Apple, as part of our efforts to resolve refund requests. This information may include details about how you have accessed and interacted with the purchased content. The purpose of sharing this data is to help Apple make an informed decision regarding refund requests. We ensure that such data sharing is done in compliance with Apple's policies and only as necessary to process your requests.

Personal Information We Collect

We categorize the data we collect as follows:

Functional Information: Essential for App operation and contractual fulfillment. Includes user-generated content, contact details, and interaction data. Our use of third-party services like OpenAI, L.L.C., Anthropic, PBC, and Google LLC is to enhance content creation based on user inputs. Device and usage data are automatically collected for functional and analytical purposes.
Automatically Processed Information: Upon consent, we deploy third-party services for analytics and personalized content, which might involve data profiling. This encompasses device identifiers, usage patterns, location information, and more, tailored to improve user experience and app functionality.
Payment Information: Managed by external e-commerce platforms (e.g., Apple) to process in-app purchases securely. We ensure that your payment data is handled with utmost security and confidentiality.

Usage and Sharing of Information

Our primary goal in collecting personal data is to provide and enhance our services. This includes:

Service Provision: Utilizing functional and automatically collected data to ensure the App's operational integrity.
Improvement and Analytics: Analyzing user interaction to refine and evolve the App's features and user experience.
Marketing and Communication: Employing user data for personalized advertising and direct communication to inform users about updates, offers, and more.
Security and Legal Compliance: Enforcing our terms, protecting against fraudulent activities, and adhering to legal requirements.

To fulfill our contract with you, maintain security, and improve our offerings, we may share your information with the following categories of third parties:

1. Service Providers

We may disclose your personal information to third-party vendors who assist us in the operational delivery of our Services. These providers utilize your information solely to facilitate our business operations. This includes partners who provide AI and LLM infrastructure, IT support and hosting services (e.g., Cloud providers), payment processing, customer service, and data analytics.

2. Business Partners

We may share personal information with business partners to fulfill specific requests for products or services you have initiated. Additionally, we may collaborate with partners with whom we jointly offer specific products, features, or services to ensure seamless delivery and integration.

3. Advertising and Measurement Partners

We may share your information with third-party advertising partners to deliver relevant content. These partners may utilize tracking technologies (such as cookies or SDKs) within our Services to collect data regarding your device and activities.
Interest-Based Advertising: This data allows our partners to deliver personalized advertisements based on your activity across different digital properties.
Analytics and Attribution: We use tools to log app events, track installations, and analyze the performance of marketing campaigns.

4. APIs and SDKs

To ensure the full functionality of ChatNow, we utilize third-party Application Programming Interfaces (APIs) and Software Development Kits (SDKs). These tools allow third-party code to operate within our app to provide specific features (such as AI generation or authentication).

5. Disclosures for Legal and Security Reasons

We reserve the right to access, preserve, and disclose your information to external parties if we believe, in good faith, that such action is required to comply with legal processes, protect the rights or safety of Marsby Teknoloji A.Ş. or our Users, or assist in the investigation of fraud.

6. Business Transfers

In the event of a merger, acquisition, sale of assets, or bankruptcy involving Marsby Teknoloji A.Ş., we reserve the right to transfer your information to the successor entity, provided they agree to adhere to the terms of this Privacy Policy.

We share your information with third parties only when it is necessary for service delivery, with a stringent selection of partners who ensure adequate data protection.

Third-Party Services List

Services performed	Entity name	Entity location	Link to Privacy Policy
AI-generated content provider	OpenAI, L.L.C.	(U.S.A.)	OpenAI Privacy Policy For license terms, visit OpenAI Terms
AI-generated content provider	Anthropic, PBC	(U.S.A.)	Anthropic Privacy Policy Anthropic Terms
AI-generated content provider	Google LLC (Vertex AI / Gemini)	(U.S.A.)	Google Privacy Policy Google Cloud Privacy
Internet search results provider	Microsoft Corporation	(U.S.A.)	Microsoft Privacy Statement
Analytics service provider	Mixpanel Inc.	(U.S.A.)	Mixpanel Privacy Policy
Analytics service provider	AppsFlyer Inc.	(U.S.A.)	AppsFlyer Privacy Policy
User authentication, analytics and marketing	Firebase (Google LLC)	(U.S.A.)	Google Privacy Policy Firebase Privacy
In-App subscription implementation and analytics	Revenuecat	(U.S.A.)	RevenueCat Privacy Policy

Data Retention and User Rights

We retain personal data as long as necessary to provide the App's functionalities and comply with legal obligations. Users have rights to access, correct, or delete their data, and we provide mechanisms to exercise these rights effectively.

International Data Transfers

Your personal data may be transferred across borders, ensuring that we apply robust safeguards and encryption to maintain data protection as per international standards.

Security Measures

We are committed to protecting your personal data with advanced security measures, recognizing that no system can guarantee absolute security. We promptly address potential risks and vulnerabilities to ensure the highest level of data protection.

Children's Privacy

The App is designed for a general audience and not intended for children under 18. We do not knowingly collect personal data from children without appropriate parental consent.

Updates to This Privacy Policy

We may periodically update this Privacy Policy to reflect changes in our practices. Substantial changes will be communicated through the App or other means, ensuring you are always informed.

Contacting Us

For inquiries or concerns regarding this Privacy Policy or your personal data, please contact us at info@themarsby.com.

Your privacy is our priority, and we are dedicated to handling your personal data with care and respect, adhering to the highest standards of data protection and transparency.