Privacy Policy

Mobilizer Yazılım ve Teknoloji A.Ş is a private Incorporation, having its principal place of business at Ihsan Dogramaci Blv. ODTU Teknokent Gumus Blok No:29/A O-8 Çankaya/Ankara (“AppNava,” “We”, “Us,” or “Our”) provides analytics, data analysis, prediction, and optimization of SaaS (software-as-a-service), which enables the tracking, analysis, and prediction of users’ activities on mobile applications (respectively the “Apps” and the “SaaS”). The SaaS is available to App developers and/or publishers (“Developer” or “Customer”) through the implementation of the AppNava API from AppNava’s website at: https://appnava.com/ (the “Site”). AppNava is fully committed to protecting the privacy of visitors to our Site (the “Visitors”) and/or of our “Customers,” along with the privacy of their Apps’ users (“End Users”), in compliance with applicable privacy and personal data laws and regulations. Customers, Visitors, and End Users are hereby referred to hereunder as “You” or “Your”. We take extra care in protecting the personal information that Customers and Visitors share with us in connection with their use of the SaaS and the Site, including information concerning our Customers' Apps’ End Users (the "Services"). This Privacy Policy (the “Privacy Policy”) is intended to describe our practices regarding the information we may collect from you or to which we may have access when you use or interact with the Services and the manner in which we may use such information, and the choices and rights available to you. With respect to End User Data (as defined below), AppNava will act as a Data Processor on behalf of the Customer, and the Customer shall act as a Data Controller. AppNava promise that We are committed to communicating transparently, providing security, and protecting the privacy of data on Our systems. We keep Your personal information personal and private. We will not sell or rent Your personal information to anyone. We will not share or otherwise disclose Your personal information except as necessary to provide the Services or Our AppNava product to You, or as otherwise described in this Policy, without first providing You with notice and the opportunity to consent.

This Privacy Policy supplements and should be read in conjunction with our Terms of Use, available at https://appnava.com/, which provides additional information on the Services. We reserve the right to change the Privacy Policy. If we decide to make a material change to the Privacy Policy, we will post a notice at least thirty days prior to making any material changes. Your continued use of this Site, including use after the posting of any changes to these terms, will be deemed acceptance by you of the Privacy Policy. You will find information on the following topics within this Privacy Policy:

Collection Information Policy

Anonymous Information

You can Anonymous I about our company, products, and services without telling us who you are and without revealing any personal information. To improve the usefulness of our site, AppNava measures and analyzes non-identifying, usage, and volume statistical information from Site visitors in order to administer our Site and to constantly improve the quality of our service and site performance. Information gathered may include, but is not limited to, the following: the activity of the Site visitor's browser when the visitor is viewing the Site; the site path of visitors; and the time visitors come to the Site. AppNava reserves the right to publish anonymous, aggregate summary information regarding its Site visitors for promotional purposes and as a representative audience for advertisers. Please note that this is not personal information, only general summaries of our visitors' usage of the Site. You can control how websites use cookies by configuring Your browser's privacy settings (please refer to Your browser's help function to learn more about cookie controls). Note that if You disable cookies entirely, our Websites may not function properly.

Personal Information

Personal information refers to individually identifiable information, namely, information that identifies an individual or may, with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or maybe of private or sensitive nature information relating to an identified or identifiable natural person. Identification of an individual also includes the association of such an individual with a persistent identifier such as a name, an identification number, a persistent cookie identifier, etc. Personal information does not include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person. Personal information Customers and/or Visitors provide us actively and voluntarily when they use or interact with our Services. You are asked to provide contact information such as Customers and/or Visitors name, company number, signing person name and position, email and physical addresses, and telephone number, all when such Customers and/or Visitors fill out our online form or register for an account with us or when they update their accounts details. At registration, Customers also provide us with a list of Apps in which they would like to implement AppNava API. Additionally, we collect and use the following categories and types of information in the following respective circumstances: The contents of Customers' and/or Visitors' interaction with our customer support which may include text recording and transcripts of such communications. Financial information (such as credit card or bank account numbers), which is processed by our third-party services providers as further detailed below and to which we have no access. Information we are required or authorized by applicable national laws to require Customers and/or Visitors to provide us in order to authenticate or identify them or to verify the information we have collected or otherwise provide them with our Services. Computer, device, browser, or Application identifier. For example, IP address, user agent, IDFA (identifier for advertisers), Android ID (in Android devices); Google Advertiser ID, unique user ID, and other similar unique identifiers. Information related to a mobile device or computer, such as browser type, device type and model, operating system (iOS/Android, etc.), system language, OS version, Wi-Fi status, time stamp and zone, device motion parameters, and carrier. Other information collected from End-Users when they use the App, such as the dates and times in which End-Users launch the applicable App, its usage duration and frequency, End Users’ in-App purchases (IAP), End-User events, pre-defined by the applicable Customer. End-Users’ interaction with the App, including clicks and views, and in certain cases about End-Users’ impressions of and reactions to advertisements and other information that is being communicated to the End-Users by the Customer through the App. End Users’ interaction with the applicable App, such as Device ID or unique identifier, device type, ID for advertising, operating system, IP address, time zone, and location information from End-Users' mobile devices or as can be derived from their IP addresses. Importantly, End User Data does not generally contain any information that directly identifies an individual, such as names, addresses, credit cards, or other similarly regulated financial information, or any other type of sensitive personal information. We acknowledge that under certain jurisdictions, the End Users data we receive when a Customer uses our Service may be deemed personal data as it is associated with a technical identifier and, where applicable, will be treated as such. If you are a customer, you may only provide us personal information related to End Users or allow us access in accordance with this privacy policy, only with such End Users express authorization and consent and refrain from providing us with any other personal information associated with end users.

Purpose of Information Use and Disclosure

AppNava uses the information that we collect on the Site to contact you to further discuss your interest in our company and our services and to send information regarding our company, such as marketing promotions and events. This information may also be used to improve the services we provide you. The information is collected and stored in a manner that is appropriate for the nature of the data that we collect and the need to fulfill your request. This information is not provided to third parties for their own use unless specifically authorized by you. In certain situations, AppNava may be required to disclose personal data in response to lawful requests by public authorities. We may need to disclose personal information when required by law or in order to comply with a current judicial proceeding, a court order, or a legal process served on the Site. When We believe in good faith that disclosure is necessary to protect Our rights, protect Your safety or the safety of others, investigate fraud, or respond to a government request. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.

As mentioned above, we have no direct relationship with the individual End-Users; therefore, it is the Customers’ responsibility to ensure that all personal information of End Users received or accessed by AppNava pursuant to Customers’ access to the SaaS is being provided to AppNava on the above legal basis for processing which in any event shall include the basis of consent pursuant to which Customer shall obtain express consents and permissions from its End-Users of its App, for the collection and processing of their personal information as set forth hereunder. We may use personal information that we collect about End Users solely for the purposes

Personal information regarding the Customers, End-Users and Visitors will be maintained, processed and stored by us and our authorized affiliates and service providers in Turkey, European Union and as necessary, in other territories in secure cloud storage, provided by our third party service provider. You hereby accept the transfer and storage of information as described above.

Data Security, Data Integrity, and Access

We have implemented appropriate technical, organizational, and security measures designed to reduce the risk of accidental destruction or loss or unauthorized disclosure or access to such information appropriate to the nature of the information concerned. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure Your information, and We make use of privacy-enhancing technologies such as encryption. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations, as the security of information depends in part on the security of the computer, device, or network you use to communicate with us and the security you use to protect your user IDs and passwords.

In terms of Personal Data Breach, AppNava will comply with the Personal Data Breach-related obligations applicable to it under the GDPR and other Applicable Laws. AppNava will assist Customer in complying with those applicable to Customer by informing Customer of a Personal Data Breach without undue delay. AppNava will provide such notification in accordance with Applicable Law to the Customer at the Designated Address. Such notification shall not be construed as an acknowledgment of fault or responsibility, and the obligations herein shall not apply to incidents that are caused by Customer or Customer’s Users. AppNava will notify the personal data breach to the competent supervisory authority in accordance with Article 55 of the GDPR. AppNava shall make reasonable efforts to identify the cause of such Personal Data Breach and take such steps as We deem necessary and reasonable to remediate the cause of such Personal Data Breach to the extent the remediation is within Our reasonable control.

Please make sure to take appropriate measures to protect this information. If You have any questions about the security of Your personal information, You can contact Us at [email protected]

Data Subject, Retention, Rights & Choices

For any subject access request ("SAR") from Visitors, We will need to verify a requestor is inquiring about their own information before We can assist. Where a SAR may implicate the personal data of another individual, We must balance the request against the risk of violating another person's privacy rights. We will comply with SARs to the extent required by applicable law. In the EEA, the UK, and Switzerland, You also have the right to lodge a complaint with a supervisory authority. AppNava will reasonably and timely assist Customers with the fulfillment of Customer’s obligation to honor and respond to requests by individuals to exercise their Personal Data-related rights under the GDPR or other Applicable Law (a “Data Subject Request”), such as rights to access, correct, or delete their Personal Data, insofar as technically possible.

Visitors, Customers. You have the right to access, correct, update, export, or delete Your personal data. You may email Us at [email protected] with any such SARs, and We will respond within 30 days. If You have an account with AppNava, You also can access, correct, export, or update Your account information by editing Your profile or organization record within Your account. If AppNava receives a Data Subject Request or a complaint from Visitors, Customers, AppNava will take commercially reasonable steps to forward the communication to the designated address.

End Users. AppNava has no direct relationship with End Users. Accordingly, We rely upon our Customers to comply with the underlying legal requirements for subject access requests. If an End User requests that We access, correct, update, or delete their information or no longer wishes to be contacted by one of our Customers that use AppNava, We will direct that End User contact the Customer with which they interacted directly. Our Customers are solely responsible for ensuring compliance with all applicable laws and regulations with respect to their users and customers.

In some circumstances, we may store your Personal Information for longer periods of time, for example, (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.

Cookies

Cookies are small text files sent by Us to Your computer or mobile device, which enables certain features and functionality. They are unique to Your account or Your browser. Session-based cookies last only while Your browser is open and are automatically deleted when You close Your browser. Persistent cookies last until You or Your browser delete them or until they expire.

Our Site utilizes cookies, anonymous identifiers, and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you. A cookie may be used, for example, to collect information about activity on the Site. In addition, We use third-party cookies, like Google Analytics. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

Third-Party Policy

The Site may enable you to interact with or contain links to your Third Party Account and other third-party websites and Services that are not owned or controlled by us (each a “Third Party Service”). It is your responsibility to review any third-party integrations you authorize. AppNava is not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Third parties may advertise on our Site. In doing so, those parties, their agents, or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website. They may also use other technology to personalize the content of and measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this Privacy Policy does not cover the information practices of these third parties. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

Information from Third Party Services. We may combine the information We collect, as described in Collection Information Policy above, with personal information We obtain from third parties. For example, We may combine information entered on an AppNava sales submission form with information We receive from a third-party sales intelligence platform vendor to enhance our ability to market our products and services to Customers or potential Customers.

Services Helping Us Manage Your Data:

We engage vendors to perform specific business functions on our behalf, and they may receive information about you from us or collect it directly. These vendors are obligated by contract to use information that we share only for the purpose of providing these business functions, which include:

Supporting Service functionality, such as vendors that support customer service and customer relationship management, application development, postal mailings, and communications (email, fax). Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance. Analytics and marketing services, including entities that analyze traffic on our online properties and assist with identifying and communicating with potential customers. Marketing vendors, such as entities that support the distribution of marketing emails. To provide our services, we rely on other companies that can partially manage your data. We carefully select our providers to ensure the privacy and security of your data. Our biggest providers are:

Hosting: Amazon Web Services

Email marketing: Hubspot

Analytics: Google Analytics

For internal collaboration: Slack

You can find the Terms and Services and Privacy Policies on their pages. By checking the permissions here, you can stop being tracked or unsubscribe from e-mails. In case of any problems, contact us by e-mail.

Notice to UK and EU Residents

Please note that the "personal information" and "personal data" referenced in this Policy means "personal data" as that term is defined under the European Union ("EU") General Data Protection Regulations ("GDPR") and its United Kingdom ("UK") GDPR counterpart. AppNava is a data controller for the personal data collected from all Website Visitors listed above, except for the personal data of Customers, End Users. AppNava processes the personal data of Customers and End Users on behalf of its Customers.

If You are an individual from the European Economic Area (the "EEA"), the UK, or Switzerland, please note that Our legal basis for collecting and using Your personal data will depend on the personal data collected and the specific context in which We collect it. We normally will collect personal data from You only where: (a) We have Your consent to do so, (b) where We need Your personal data to perform a contract with You (e.g., to deliver the Services or information You have requested), or (c) where the processing is in Our legitimate interests. Please note that in most cases, if You do not provide the requested information, AppNava will not be able to provide the requested product or service to You.

In some cases, We may also have a legal obligation to collect personal data from You or may otherwise need the personal data to protect Your vital interests or those of another person. Where We rely on Your consent to process Your personal data, You have the right to withdraw or decline consent at any time. Where We rely on our legitimate interests to process Your personal data, You have the right to object. If You have any questions about or need further information concerning the legal basis on which We collect and use Your personal information, please contact Us at [email protected]

Opt-Out and Update Policy

By providing us with your email address or any other contact information, Customers and Visitors hereby agree that AppNava may use your contact details for the purpose of informing you of our events, products, and services offered by us and to send you newsletters or marketing materials. AppNava offers its Site visitors a means for controlling the use of session information. If, at any time after registering for information, you change your mind about receiving receipt of information from us or about the use of information volunteered by you, if you no longer wish to receive emails from us, you may withdraw your consent by sending a written notice to AppNava by email to the following address: [email protected] or by opting out by clicking “unsubscribe.” Please note that we may notify you (through any of the means available to us) of changes or updates to our Services, payment issues, service maintenance, etc., and you will not be able to opt out of receiving such service messages.

International Information Transfers

AppNava is a Turkey-based, global company. We primarily store Your information in the EEA. To facilitate Our global operations, We may transfer and access such information from around the world. Our Service is rolled out on platforms belonging to reputable leading service providers and vendors that uphold the highest security standards, specifically, EU-based Amazon Web Service (AWS) and EU and US-based Google Cloud Platform (GCP). Our websites are hosted in the European Union with AWS - Europe (Ireland) EU-west-1. We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business. For example, some of the software our website uses may have been developed in Turkey. We use the following safeguards with respect to data transferred outside the European Union. Turkey who is a member of the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework. They also adhere to an enhanced version of the Privacy Shield called BBB EU PRIVACY SHIELD that allows for advanced conflict resolution. The processor is within the same corporate group as our business or organization and abides by the same binding corporate rules regarding data processing. The data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union. We comply with a code of conduct approved by a supervisory authority in the European Union relating to the protection of your information. And both our organization and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to the protection of your information. Whenever AppNava shares personal information originating in the EEA, the UK, or Switzerland with another entity in the AppNava that is outside the EEA, the UK, or Switzerland, We will do so on the basis of the EU standard contractual clauses. If You are accessing or using our Services or otherwise providing information to Us, You are agreeing to the transfer of Your personal information to Turkey and other jurisdictions in which We operate.

Contact Us

If you have questions, concerns, or suggestions regarding our Privacy Policy, we can be reached by email at the following address: [email protected]

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