Privacy Policy and Personal Data Text

Jarvis AI

Update Date: 15 February 2023

1. Objective

Nexus App Studios (“Company”), aims to process the personal data of users in accordance with general principles of privacy and the provisions of the applicable data protection legislation to the relevant person, particularly Law on Personal Data Protection No. 6698, (“PDP Law”) and other applicable legislation.

Your personal data, which you provided/will provide to our Company and/or obtained by our Company by any external means, may be processed by our Company as “Data Controller”;

• In the context of the objective of processing your personal data and in connection with this purpose, in a limited and measured manner,
• By maintaining the accuracy and up-to-date version of the personal data as reported or notified to our Company,
• May be recorded, stored, preserved, reorganized and be transferred to the institutions authorized to request such personal data by law and shall be transferred, classified and shared with third parties within the country or abroad under the conditions stipulated by legislation and upon your explicit consent if necessary, and they may be processed by other means listed under the legislation and be subject to other procedures set forth in the legislation.

This Privacy Policy is adopted for the continuance and improvement of the activities carried out by Nexus App Studios in line with the principles set forth in the PDP Law.

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.

Capitalized terms in this Policy shall have the meanings specified in the Terms and Conditions unless defined separately in this Policy.

2. Collection of Personal Data and Method

Nexus App Studios may process your personal data for the purposes specified in this Privacy Policy. The personal data of users collected and used by Nexus App Studios in particular, are as follows: your order information if you make a purchase through in-app purchase, and identifier for advertisers designated in your mobile device used in accessing our services (The Identifier for Advertisers-IDFA), identifier for vendors/developers designated your mobile device (The Identifier for Vendors-IDVF) and Internet Protocol Address-IP Address.

Data Categories and Data Types

• Process Security: Internet traffic data (network movements, IP address, visit data, time and date information), device name, In-app purchase history, Token ID (when you allow notifications through your device), identifier for advertisers designated in your mobile device used in accessing our services (if you give a permission, the Identifier for Advertisers-IDFA), identifier for vendors/developers designated your mobile device (The Identifier for Vendors-IDVF)
• Customer Transaction: Order information
• Marketing Data: IDFA, IDVF

We may collect your abovementioned 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 App Store (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 as enabling 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 as your device’s Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our service/application, the time/date of your use of the service/application, and other statistics.

General Principles Regarding Personal Data Processing

In accordance with this Privacy Policy, personal data are processed by Nexus App Studios as a data controller in line with the basic principles named here: (i) being in accordance with law and good faith, (ii) being accurate and, where necessary, up-to-date, (iii) being processed for specific, explicit and legitimate purposes, (iv) being limited for the purpose for which they are processed and data minimization; and (v) being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

3. Purposes of Processing Personal Data and Legal Reasons

Your personal data will be processed via automatic or non-automatic means for the purposes stated below, in accordance with the applicable legislation and articles 5 and 6 of the PDP Law where it is expressly permitted by the laws, the establishment of a contract or direct relation to the execution or performance of the contract and for the legitimate interests of Nexus App Studios provided that your fundamental rights and freedoms are protected.

a) Purposes of Processing Personal Data

In accordance with this text, your personal data is processed for the following purposes in accordance with the above general conditions:

• Execution of activities in compliance with legislation
• Execution of company/product/service commitment operations
• Execution of communication activities
• Execution/auditing of business activities
• Conducting after-sales support services for goods/services
• Execution of goods/services sales processes
• Conducting storage and archive activities
• Execution of agreement processes
• Execution of information security processes
• Conducting audit/ethical activities
• Execution/audit of business activities
• Conducting activities to ensure business continuity
• Providing information to authorized persons, institutions and organizations

Customer Transaction

• Execution/auditing of business activities
• Conducting after-sales support services for goods/services
• Execution of goods/services sales processes
• Conducting activities for customer satisfaction
• Execution of agreement processes

Marketing Data

• Conducting marketing analysis studies
• Execution of advertising/campaign/promotion processes

Besides, the purposes of processing personal data may be updated in line with our obligations arising from our company policies and legislation; in particular,

• Creating user accounts for the service recipients/application users,
• Customizing our Services, understanding our users and their preferences to enhance user experience and enjoyment using our Services and improve our users’ experience,
• Informing about new products, services and applications and delivering you information regarding advertisements and promotions,
• Carrying out a digital subscription and in-app purchase processes of service recipients,
• Carrying out the auto-renewable subscriptions for giving users access to content, services, or premium features in our service,
• Carrying out the processes of information security,
• Conducting activities in accordance with legislation,
• Fulfilling the demands of competent authorities,
• Conducting the processes of finance and accounting transactions,
• Conducting communication activities,
• Conducting the processes of contracts,
• Carrying out strategic planning activities,
• Following up requests and complaints.

b) Legal Reasons

Customer Transaction

• It is necessary to process your personal data, provided that we establish a contractual relationship with you, or that it is directly related to our performance obligation arising from this contract
• We have to process data in order to establish a right for you, to exercise and protect this right

Process Security

• The law explicitly stipulates the process by which we process your personal data
• Conditions that are necessary in order to fulfill our legal obligation
• It is necessary to process your personal data, provided that we establish a contractual relationship with you, or that it is directly related to our performance obligation arising from this contract

Marketing Data

• Your explicit consent (acquired via Apple App Store and Google Play Store)

4. Storage and Disposal of Personal Data

Your personal data will be processed for the period required by the purposes specified in this Privacy Policy and for the duration specified in the applicable legislation and in any case, for a maximum period of 10 years, unless you withdraw your consent.

Upon completion of the duration, your personal data shall be erased, destructed or anonymized in accordance with the PDP Law and other applicable legislation.

5. Security of Personal Data

Your personal data shall be processed within the scope of technical and administrative measures, according to the data security regulations in the PDP Law and other applicable legislation, and protected by the Company against unauthorized access, misuse, disclosure, alteration or destruction.

6. Transfer of Personal Data

Our company may transfer your personal data to third parties in accordance with articles 8 and 9 of the PDP Law and relevant regulations. The categories of third parties to whom we may transfer personal data are indicated below:

• Legally authorized public institutions and private persons
• Real or legal persons who process personal data on behalf of the company
• Shareholders and affiliates
• Consultants and service providers
• Other persons/organizations that are authorized in accordance with the legislation and relevant regulations
• IT support service providers, including cloud computing service providers
• Database and server providers

7. Rights of Data Subjects

Under Article 11 of the PDP Law, data subjects have the right to:

• Learn whether their personal data has been processed,
• Request information if their personal data has been processed,
• Learn the purpose of processing of their personal data and whether this data is used in line with the purpose,
• Know the third parties in the country or abroad to whom their personal data have been transferred,
• Request correction of the personal data if it is incomplete or incorrectly processed,
• Request the deletion or destruction of the personal data within the framework of the conditions set forth under Article 7 of the PDP Law,
• Request notification of the processes conducted as per subparagraphs (e) and (f) of Article 11 of the PDP Law to third parties to whom the personal data has been transferred,
• Object to the occurrence of a result that is to the detriment of the data subject as a result of the analysis of the processed data exclusively through automated systems,
• Request compensation for the damages in case the person incurs damages due to the unlawful processing of personal data.

8. Communication

For more information regarding your rights, the processing of your data, and to exercise your rights, you can contact us via email at privacy@nexusappstudios.com or by mail to:

Nexus App Studios, 1234 Nexus Street, Innovation City, Techland.