Privacy Policy

1. Purpose

Superapp Labs Teknoloji A.Ş. ("Superapp Labs" or "Company") processes users' personal data in accordance with applicable data protection laws, including the Law on the Protection of Personal Data No. 6698 ("Law No. 6698").

Personal data that you provide to the Company, or which is obtained through other means, may be processed by Superapp Labs as a Data Controller for specific and lawful purposes, in a limited and proportional manner, while ensuring data accuracy and currentness.

The data may be recorded, stored, preserved, reorganized, and transferred to authorized public bodies, or shared with third parties domestically and internationally under legal conditions or your explicit consent when required.

This Privacy Policy outlines how Superapp Labs ensures compliance with Law No. 6698 and describes the collection, use, protection, sharing, and management of your personal data.

2. Collection of Personal Data and Method

Superapp Labs collects and processes personal data for purposes outlined in this policy. This includes information such as:

• Name and surname
• Email address and phone number
• Purchase and order history (including in-app purchases)
• Uploaded photos or images
• Advertising ID (IDFA), Vendor ID (IDVF), and IP address
• Login credentials (username, email, password)

Data Categories and Types

• Identity Information: Name and surname
• Contact Information: Phone number, email address
• Process Security: IP address, traffic data, device information, in-app purchase history, IDFA, IDVF, Token ID
• Visual and Audio Records: Photos uploaded by the user
• Customer Transaction: Order history
• Marketing Data: IDFA, IDVF

Personal data may be collected via electronic or physical means, through devices, third-party platforms, or tools integrated in our services.

General principles include:

• Lawfulness and good faith
• Accuracy and up-to-dateness
• Specific, clear, and legitimate purposes
• Proportionality and data minimization
• Retention only as required

Consent Prior to Uploading Photos or Videos

Before you upload a photo or video for the first time, you will be presented with a disclosure screen explaining how your media is processed and identifying the AI service providers involved. By proceeding, you provide your explicit consent for the media to be transmitted to our AI processing services.

Your Responsibility for Uploaded Content

You are solely responsible for ensuring that any media you upload — including photos, videos, and audio — does not contain copyrighted material (such as music, soundtracks, or sound recordings) for which you do not hold the necessary rights or licenses, and does not depict any individual other than yourself without that individual's explicit prior consent. Content uploaded in violation of these requirements may be removed, and accounts that repeatedly violate these rules may be suspended or terminated. For full details, see Section 5 of our Terms of Use.

3. Processing of Facial Data

3.1 What Facial Data We Collect

Facial geometry, feature points, symmetry information, and full-face images for AI processing.

3.2 Purpose

Solely for image enhancement, AI editing, accuracy improvement, and service performance — not for identity verification.

3.3 Retention

Facial data is deleted immediately after real-time inference and never stored.

3.4 Security

Processed securely on Google Cloud with restricted access and encryption.

3.5 Sharing

No sale, rent, or sharing of facial data. SDKs cannot access facial data.

3.6 Third Parties

No third parties store identifiable facial data.

3.7 Third-Party AI Service Providers

Certain features within the app are powered by third-party artificial intelligence services. When you use these features, the following applies:

What data is sent: Depending on the feature used, the following personal data may be transmitted to third-party AI services: photographs or images you upload, text prompts or inputs you provide, and associated content data necessary to fulfill your request. We do not transmit account credentials, payment information, or device identifiers to AI service providers.

Who the data is sent to: Your data may be shared with the following third-party AI service providers:

• Fal.AI — AI-based image and video generation and processing
• Google Cloud — Cloud infrastructure and AI processing services

These providers act as data processors and are contractually prohibited from using your data for any purpose other than fulfilling your request.

User consent: We display a clear, explicit consent prompt before your data is first transmitted to any third-party AI service. You must actively confirm this consent before the feature is activated. You may withdraw your consent at any time within the app settings.

4. Purposes and Legal Basis of Processing

4.1 Purposes

• Legal compliance
• User support
• Service improvement
• Contract fulfillment
• Security
• Marketing (with consent)
• Archiving
• AI-based image processing

4.2 Legal Grounds

• Contract
• Legal obligation
• Legitimate interests
• Explicit consent

5. Third-Party Services

5.1 External Links

External links may exist; Superapp Labs is not responsible for external policies or content.

5.2 Third-Party Analytics, Attribution, and Infrastructure

We use the following third-party services for analytics, performance monitoring, marketing attribution, subscription management, and infrastructure:

• Firebase (Google) — Authentication, database, cloud functions, push messaging, analytics, and crash reporting
• Mixpanel — Product analytics and user event tracking
• Sentry — Error tracking and performance monitoring
• Adjust — Marketing attribution and campaign measurement
• Adapty — Subscription management and paywall analytics
• TikTok (TikTok for Business) — Advertising measurement and campaign optimization

These services may collect usage data and device identifiers (such as IDFA, IDFV, and IP address) in accordance with their respective privacy policies. We do not sell your personal information to any third party.

To measure the effectiveness of our advertising campaigns on TikTok, we share in-app purchase and subscription events (including the product purchased, its price, and currency), an internal user identifier, your App Tracking Transparency status, and device information with TikTok. On iOS, your advertising identifier (IDFA) is shared with TikTok only if you have allowed tracking through Apple's App Tracking Transparency prompt, and you can change this choice at any time in your device settings.

6. Cookies

Used to improve user experience. They do not access personal files.

7. Push Notifications

Users may manage or disable via device settings.

8. Data Retention

Stored only as long as needed or legally required.

Facial data: always deleted instantly post-inference.

9. Security Measures

Includes:

• Antivirus & firewall
• VPN
• RBAC (role-based access control)
• Encryption
• Logging & 2FA
• SIEM & pentests
• Backups
• NDAs

Breach notifications will be made when required.

10. Data Transfers

Data may be transferred for:

• Archiving
• CRM
• Legal compliance
• Third-party SDK services

Facial data is never transferred.

11. Your Rights

Under KVKK & GDPR:

• Learn whether data is processed
• Request information
• Request correction/deletion
• Data portability
• Object to automated processing
• File complaints

Requests: support@superapplabs.co

Responses within 30 days.

12. Children's Privacy

Our services are not directed to individuals under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal data from a child under 13 without verified parental consent, we will promptly delete it. If you believe a child has provided us with personal data, please contact us at support@superapplabs.co.

13. Updates

Policy may be updated. Continued use implies acceptance.

14. Contact Information

If you have any questions about this Privacy Policy, you may contact us at:

Company Name: Superapp Labs Teknoloji A.Ş.

Address: EGS BUSINESS PARK BLOK D:251, NO: 12, YESILKOY MAH., ATATURK CADDESI, BAKIRKOY, Istanbul

Email: support@superapplabs.co

Phone: +90 212 909 17 35