PRIVACY POLICY

Effective Date: June 10, 2025
Provider: EGE KIRI NURSERY INC.
Registered Address: Tahılpazarı Mahallesi, 471 Sokak No: 5, 07010 Muratpaşa, ANTALYA – Turkey
Represented by: Mesut Gürsoy
Registration Number: 110650
Tel.: +90 531 266 96 93
E-Mail: info@egekiri.com

This Privacy Policy explains how EGE KIRI FİDANCILIK A.Ş. collects, uses, discloses and processes your personal data when you use its mobile application, websites and related services (collectively referred to as “Consumer Services”).

This Privacy Policy applies to individual users of EGE KIRI FİDANCILIK A.Ş.'s Consumer Services for personal, family, or household use. A separate privacy statement applies to commercial and corporate services.

1. Information We Collect

EGE KIRI FİDANCILIK A.Ş. collects the following types of personal data:

Account Information: Name, username, email address, age (minimum 18), profile photo, bio, location.
Usage Data: App usage details, check-ins, ratings, story views, likes, diamonds used/sent, and other interactions.
Location Information: With your consent, precise location data is collected for check-in and matching purposes.
Device Information: Device identifiers, operating system, IP address, app version.
Payment and Diamond Transactions: Non-refundable and non-transferable information related to purchases and virtual currency (Diamonds).
Voluntary Information: Feedback, support requests, and optional profile verification content (e.g., selfie).

1A. Personal Data We Collect and Process

Personal data collected comes from three main sources, depending on how you interact with EGE KIRI FİDANCILIK A.Ş.'s Consumer Services:

Data Provided by You:

• When you create an account or fill out your profile,

• When you consent to share your location or contact information,

• When you upload content or interact with app features,

• When you request support or provide feedback.

Automatically Collected Data: EGE KIRI FİDANCILIK A.Ş. automatically collects the following data through cookies, device sensors and similar technologies:

• Your interaction history,

• Your device and session data,

• Engagement metrics (see our Cookies and Similar Technologies Policy for details).

Data from Third Parties:

• Affiliated Group Companies: Companies under the same group as EGE KIRI FİDANCILIK A.Ş.

• Partners and Developers: Parties collaborating on location-based services that use EGE KIRI APIs or SDKs.

• Data Broker and Advertising Networks: Demographic, behavioral and location data providers.

• Social Media Platforms: If you connect your profile with a platform such as Facebook, data may be received from that platform depending on your settings.

• Service Providers: External platforms we use for data processing, analysis and improvement.

• Public Sources: Social networks, news content, public records.

• Transaction Partners: Data that may be obtained in cases such as acquisition, merger, restructuring.

Categories of Personal Data and Processing Bases

Data Category	Data Samples	Data Source	Purpose of Use	Legal Basis
Contact Data	Name, email, phone number, date of birth, address, authorized contact list	Data Provided by You; Third Parties	Registration, Personalization, Communication, Marketing, Events, Research, Security, Compliance	Contract, Legitimate Interest, Consent
Account Data	Account ID, user ID, password hash, social media login information	Data You Provide	Authentication, Personalization, Operations, Security, Marketing	Contract, Consent
Demographic Data	Gender, age, country, language, income, education, marital status	Data Provided by You; Third Parties	Personalization, Research, Service Development, Compliance	Contract, Legitimate Interest, Consent
Location Data	Precise GPS location, city, county, country (with consent)	Data You Provide; Automatically Collected Data; Third Parties	Check-in, Personalization, Analytics, Marketing, Rewards	Contract, Legitimate Interest, Consent
User Generated Content	Photos, videos, comments, ratings, check-ins, content	Data You Provide	Participation, Personalization, Research, Reward, Compliance	Legitimate Interest, Consent
Online Activity Data	Pages visited, session duration, element interactions, app usage	Automatically Collected Data; Third Parties	Advertising, Optimization, Analysis, Security	Contract, Legitimate Interest, Legal Obligation
Device Data and Identifiers	Device ID, IP address, OS version, app version, advertising ID	Automatically Collected Data; Third Parties	Analytics, Fraud Prevention, Personalization, Security	Legitimate Interest, Consent
Payment / Billing Data	Purchase receipts, card transaction ID, payment method metadata	Data You Provide	Payment, Tax Reporting, Objections	Contract, Legal Obligation

Legal Basis for Processing Personal Data

EGE KIRI FİDANCILIK A.Ş. does not consider unidentifiable, anonymized, or aggregated data as personal data. Anonymized data is not re-identified unless permitted by law.

The following legal bases are used when collecting and processing your personal data:

Performance of Contract: Necessary to provide you with the services we offer under our Terms of Service and to personalize your experience.

Legitimate Interest: Processed for legitimate interests such as securing, improving, optimizing or supporting the delivery of services.

Explicit Consent: Where you have given your express and affirmative consent to a specific processing (for example, location sharing or social media links). You can withdraw your consent at any time from the app settings or your account.

Legal Obligation: When we are required to process data pursuant to law, regulation or official request (e.g. tax reporting, fraud prevention, data retention obligations).

Data Received from Third Parties:

• Group companies,

• Business partners and developers,

• Data brokers and advertising networks,

• Social media platforms,

• Service providers,

• Public resources,

• Transaction partners.

(Tabulated details are preserved as in the original English document.)

Legal Basis for Processing Personal Data

We do not treat de-identified, anonymized, or aggregated data as personal data. We do not attempt to re-identify it unless permitted by law.

Our legal basis for data processing:

• Performance of the Contract

• Legitimate Interest

• Explicit Consent

• Legal Obligation

2. Use of Personal Data

EGE KIRI FİDANCILIK A.Ş. processes your personal data for the following purposes:

a. Account Management and User Support
Used to provide, manage and improve the Services. For example:

• Managing your account and profile information,
  
  

• Providing customer support and processing requests,
  
  

• Making in-app purchases (e.g. Diamonds),
  
  

• Solving technical problems and improving functionality,
  
  

• Verifying your identity.
  
  
  

b. Personalization and User Discovery
To customize the Services for you:

• Your profile data, in-app behavior and location information are analyzed,
  
  

• Nearby venues or users are recommended,
  
  

• When you grant access to your contact list, friend discovery is enabled,
  
  

• Content, stories and recommendations are personalized.
  
  
  

c. Business Operations:
To ensure efficient execution of internal processes:

• Evaluation and optimization of service performance,
  
  

• Analysis of user behavior,
  
  

• Strategic planning, reporting and auditing processes.
  
  
  

d. Contact
You may be contacted for various reasons:

• Updates regarding your account,
  
  

• Changes to the Terms of Service or Privacy Policy,
  
  

• Responses to customer service requests,
  
  

• Notifications about structural changes of the company.
  
  
  

e. Marketing and Advertising
To offer content and campaigns that may be of interest to you:

• In-app personalized promotions,
  
  

• Location-aware ads and sponsored content,
  
  

• Ads targeted to your interests,
  
  

• Sharing anonymous or aggregated reports with advertising partners.
  
  
  

f. Rewards, Sweepstakes and Participation Programs
For loyalty and interaction:

• Diamond awards and incentives,
  
  

• Participation in surveys, contests and draws,
  
  

• Recognition for contributions like check-ins or stories.
  
  
  

g. Events and Check-in Systems
for local community engagement and information:

• Special events for partner venues,
  
  

• Local event notifications based on your interests.
  
  
  

h. Innovation, Artificial Intelligence and Research
For the development of new technologies and system improvements:

• Creating new features using data analysis and artificial intelligence,
  
  

• Increasing system performance with insights obtained from anonymous data,
  
  

• Providing advanced functionality through machine learning models.
  
  
  

i. Location-Based Services
Based on your consent:

• Creating check-in and visit records,
  
  

• Sending alerts when you are near places that may be of interest to you,
  
  

• To provide targeted content and advertising according to interest groups,
  
  

• To provide aggregated and anonymized analytics to partner businesses.
  
  
  

j. Security and Fraud Prevention
To ensure the security of the Platform:

• Detection of suspicious behavior,
  
  

• Prevent account takeover, spam or fake check-ins,
  
  

• Investigating and responding to Terms of Service violations.
  
  
  

k. Protection of Rights and Compliance
To protect the rights of users, the company and the public:

• Implementation of our policies and agreements,
  
  

• Responding to legal requests from official authorities,
  
  

• Preventing fraud, harassment or illegal activities.
  
  
  

l. Corporate Developments and Data Sharing
In the event of a merger, acquisition or restructuring:

• Data may be transferred as part of an asset transfer,
  
  

• In this case, the privacy policy principles continue to apply.
  
  
  

m. Legal Compliance
To comply with legal obligations:\n

• Current national and international legislation,\n
  
  

• Court orders, law enforcement requests,\n
  
  

• Industry standards and data retention obligations.

3. Cookies and Similar Technologies

EGE KIRI FİDANCILIK A.Ş. collects data using cookies and similar technologies (e.g. web beacons, tracking pixels in emails, and identifiers provided by mobile application platforms) for the following purposes:

• To understand how users interact with our Consumer Services,

• To improve user experience and provide personalized content and features,

• Measuring and optimizing the performance of marketing and advertising campaigns,

• To enable third-party ad networks to show ads based on your interests across different websites and apps.

These tools may collect information such as your IP address, device ID, browser type, operating system and interaction data (e.g. number of screen views, clicks).

You can control your cookie preferences through your device settings, in-app settings, or our Privacy Preference Center.

4. Your Privacy Rights

You can learn how to exercise your choices regarding your personal data here. These rights, subject to applicable legislation, include:

Data Access, Copy, or Transfer: You may request access to, a copy of, or the transfer of personal data we hold about you. These requests may also include detailed information about how the data is collected, used, shared, or sold. In some cases, we may only provide information about the categories of data we collect.

Data Correction and Deletion: If you believe that your personal data is incorrect, you can request that we correct it or request that it be completely deleted.

Opting Out of Data Sale, Sharing for Behavioral Advertising, or Targeted Advertising: You may request that we stop the sale of your personal data, cross-context sharing for behavioral advertising, or processing for targeted advertising.

Limiting the Processing of Sensitive Personal Data: You may ask us to stop processing your sensitive personal data that is used to extract characteristics about you.

Withdrawing Explicit Consent: You can withdraw your explicit consent to the processing of your personal data at any time. You can do this through your device settings or through your account preferences within the app.

Opting Out of Marketing Communications: To unsubscribe from marketing emails or notifications sent by us, you can unsubscribe by following the instructions in the messages.

If you reside in Türkiye, you also have additional privacy rights under Personal Data Protection Law No. 6698 (KVKK). You can exercise these rights by contacting us using the methods listed in the "Contact Information" section of this Policy.

In some cases, you may be limited in exercising your privacy preferences. For example, if your request would disclose personal data about another person or if you want us to erase data we need to hold (for example, due to a legal obligation), you may not be able to exercise these rights.

You will not be discriminated against for exercising your privacy rights.

If your concerns remain unresolved, and if permitted by your country's law, you have the right to appeal to the data protection supervisory authority in the country where you live or work.

If you have questions regarding EGE KIRI FİDANCILIK A.Ş.’s obligations under the EU/UK/Swiss – US Data Privacy Framework, please review the “International Data Transfers” section.

5. International Data Transfers

In order for EGE KIRI FİDANCILIK A.Ş. to provide its Consumer Services globally, it may be necessary to transfer your personal data to countries other than your country of residence, including for users residing in Türkiye. Data protection standards may differ in these countries. In such cases, adequate security measures will be taken in accordance with this Privacy Policy and applicable laws and regulations.

By using the services of EGE KIRI FİDANCILIK A.Ş., you consent to the transfer, storage and processing of your data to other countries, primarily the United States, the United Kingdom and Turkey.

EGE KIRI FİDANCILIK A.Ş. complies with data transfer mechanisms adopted by the European Union and complies with obligations under the EU-US, UK-US, and Swiss-US Data Privacy Frameworks established by the US Department of Commerce. These frameworks regulate the collection, use, and storage of personal data transferred from the European Union, the UK, and Switzerland to the US.

EGE KIRI FİDANCILIK A.Ş. declares that it complies with the following Data Privacy Framework Principles:

• Notice

• Right to Choose

• Accountability for Onward Transfers

• Security

• Data Integrity and Purpose Limitation

• Access

• Recourse, Enforcement, and Liability

If you reside in the European Union, the United Kingdom, or Switzerland and have a privacy-related complaint, you are encouraged to first contact us using the methods in the “Contact Information” section of this Policy. If you do not receive a satisfactory response, you may contact our selected alternative dispute resolution provider, JAMS: https://www.jamsadr.com/DPF-Dispute-Resolution .

In some cases, unresolved complaints may be referred to the Data Privacy Panel for binding arbitration. For more information: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf .

The authority to audit EGE KIRI FİDANCILIK A.Ş.’s compliance with the Data Privacy Framework belongs to the Turkish Ministry of Trade.

6. Sharing of Personal Data

EGE KIRI FİDANCILIK A.Ş. may share your personal data specified in the "Data Categories" section of this Privacy Policy with third parties in the following ways:

With Your Explicit Consent or Direction: Your personal data may be shared with third parties when you explicitly request it (for example, by making your profile photo or check-in information visible). You can control this visibility in the app settings.

With Affiliates: Your data may be shared with affiliates and group companies of EGE KIRI FİDANCILIK A.Ş. in line with the purposes specified in the Privacy Policy.

With Service Providers and Contractors: It may be shared with business partners who provide services such as hosting, IT support, analytics, customer service, and marketing. Some of these service providers may be located outside of Turkey (e.g., the US, the UK).

With Business Partners, Developers, and Enterprise Customers: Anonymized and aggregated data, such as visitor patterns, may be shared with business partners, urban planners, or research institutions. Such sharing may constitute "selling," "sharing," or "targeted advertising" under some laws.

With Advertising Partners: We may share data with ad networks, social media companies, or third-party advertisers to deliver personalized ads based on your interests. This may be considered a "data sale" or "data sharing" in some cases.

Legal Compliance and Protection of Rights: Your data may be transferred to legal authorities when required by law, in accordance with the requests of official authorities or to protect our users, our company or public safety.

In Corporate Transactions: In the event of a merger, acquisition, asset sale, or corporate restructuring, data may be transferred as part of the business's assets. In such cases, your data will be protected in accordance with the privacy principles outlined in this policy.

Such data sharing is always carried out in accordance with our Privacy Policy and applicable laws. Reasonable measures are taken to ensure that the parties with whom your personal data is shared also provide an adequate level of data protection.

If you have any concerns regarding data sharing, please contact us via the means listed in the “Contact Information” section of this Policy.

7. Data Security and Storage Period

Your data is protected by appropriate technical and organisational measures and stored only for as long as necessary.

8. About Precise Location Data

Data collection and use for the following sensitive areas is not made:

• Places of worship

• Prisons

• LGBTQ+ spaces

• Children's special areas

• Shelters and treatment centers

• Political protest areas

9. Commitment to Responsibility

EGE KIRI NURSERY INC. is committed to the following principles:

• Digital Advertising Alliance (DAA)

• Network Advertising Initiative (NAI)

• EU/UK/Swiss-US Data Privacy Framework

10. Children's Privacy

Our services are not directed to individuals under the age of 18. If such data is detected, it will be deleted.

11. Contact Information

For any questions:

E-Mail: info@egekiri.com
Address: Tahılpazarı Mah. 471 Sk. No: 5, 07010 Muratpaşa / ANTALYA – TURKEY
Tel.: +90 531 266 96 93

Privacy Policy Changes

This policy may be updated from time to time. Significant changes will be notified to you via the app, website or email.

You are encouraged to review this policy periodically to stay up to date on our privacy practices.