Privacy Policy

1. Personal Data Controller

PLAYA TEKNOLOJİ LİMİTED ŞİRKETİ, a company registered under the laws of Turkey, with its registered office at İdealtepe Mah. Dik Sk. No: 13 İç Kapı No: 2 Maltepe, 34841, Istanbul, Turkey, will be the controller of your personal data.

2. Categories of Personal Data We Collect

We collect data you give us voluntarily (for example, your email address). We also collect data automatically (for example, cookies and technical information about your device) or from third parties (for example, advertisers).

2.1. Data we receive directly from you

Identifiers

You may provide us with your name and email address when you create an account with the Service, make a purchase, or contact us by any other means.

Account Data

This includes your login information (email and password) and user ID.

Quiz Data

When you complete our quiz on the Service, we collect your responses to questions about your demographics, psychological traits, behaviors and preferences, or other personal information ("Quiz Data") which is used to tailor the Services to your requirements. This includes, but is not limited to:

• Your general demographic information (age and gender);
• Your psychological traits (such as satisfaction with life, activity levels, decision-making patterns, stress handling, and risk tolerance);
• Your perspectives on challenges (such as how you handle changes, what causes frustration, and preferences for managing difficult situations);
• Other similar lifestyle information you provide when using the Service.

User Inputs and AI System Outputs

When you interact with our AI-powered Service, we collect information about your interactions with the Service ("User Inputs") and the resulting responses generated by the Service ("AI System Outputs"). User Inputs include:

• All prompts (including in the form of text, video or audio), instructions, questions, or other inputs you provide to the Service;
• Information about decisions you have made or are considering;
• Records of your conversations with the AI system, including frequency and duration of interactions;
• Preferences you express during these interactions;
• Feedback you provide about the AI system's responses;
• Any additional information you voluntarily disclose during these interactions that may reveal your opinions, interests, or personal circumstances.

Purchase Data

When you make payments through the Service, you need to provide your billing data, such as your credit card number, to our payment service providers. We do not collect, store, or have access to full credit card data, though we may receive limited information including credit card-related data (a secure token reflecting your payment method), data about products or services purchased, date, time, and amount of the purchase, the type of payment method used, and limited digits of your card number.

Feedback / Communications

We may also process your email and other information provided by you to us through customer support and other communications.

2.2. Data provided by third parties

When you use Sign in with Apple to register an account in the Service, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the Sign in with Apple screen.

When you decide to log in using Google, we receive personal data from your Google Account: name, email address, profile picture associated with your Google Account. You can revoke access on the Apps Permissions page. To know more about how Google processes your data, visit its Privacy Policy.

2.3. Data we collect automatically

Data about how you found us

We collect data about your referring Website (where on the web you were when you tapped/clicked on our ad).

Device and Location data

We collect data from your device. Examples: language settings, IP address, time zone, type and model of device, device settings, operating system, Internet service provider, device identifiers, hardware ID.

Usage data

We record how you interact with our Service. For example, we log what pages you have viewed, the features and content you interact with, how often you use the Service, how long you are on the Service, your purchases.

Advertising IDs

We collect your Apple Identifier for Advertising ("IDFA"), Identifier for Vendor ("IDFV"), or Google Advertising ID ("AAID") (depending on the operating system of your device) when you access our App or Website from a mobile device. You can typically reset these numbers through the settings of your device's operating system (but we do not control this).

Transaction data

When you make payments through the Service, you provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card data, though we may receive credit card-related data and data about the transaction (date, time, amount, payment method type).

Cookies

Some of the information we and our third-party partners collect automatically is captured using cookies — text files containing small amounts of information downloaded to your device — or related technologies such as web beacons, local shared objects, and tracking pixels.

3. For What Purposes We Process Your Personal Data

3.1. To provide our Service

We process your personal data for Service provision — namely, to give you access to learning courses and an AI system for self-improvement. This enables personalized interactions and tailored guidance based on your conversation inputs. We do not use your data to train our underlying AI models.

Enabling interactions and guidance

We process your conversations with the Service AI system along with your patterns, behaviors, values, and preferences to provide a personalized experience. This enables us to offer tailored insights, recommendations, and decision support. Please note that information you share during interactions with AI may be reproduced in future AI System Outputs generated by the Service.

To enable the core AI functionality, we use OpenAI and Google. ChatGPT (OpenAI) and Gemini (Google) models power the conversations and interactions. While your interactions are processed using their technology, we implement measures to ensure your personal data is protected according to our privacy standards. OpenAI and Google do not train their AI models on your personal data.

We use Qdrant to manage and process the data needed for our AI features (such as semantic search and recommendations). We use LiveKit to power our AI-based live audio and interactive communication features.

Technical functionality

We use your data to create your account, ensure seamless operation of the Service, prevent technical issues, and store your conversations.

• Amazon Web Services (AWS) — hosting and backend.
• Temporal — reliable execution of critical multi-step business processes (e.g., payment processing, user onboarding).
• Authentik — self-hosted Identity Provider for user authentication and SSO across our Website and App.
• Vault — secure credential management.
• MongoDB — database for operational data.

3.2. To improve our Service

We process your personal data for Service improvement — to conduct system analytics, monitor performance, and enhance features.

System analytics and monitoring

We collect and analyze technical performance metrics and error logs to identify and fix issues, optimize system performance, and ensure reliability.

Feature development and quality assurance

We analyze anonymized and aggregated usage statistics to understand which features are most valuable and identify areas for improvement. This helps us develop new functionalities without processing your personal content.

3.3. To provide you with customer support

We process your personal data to respond to requests for technical support, Service information, or any other communication you initiate. For this purpose, we may send you notifications or emails about Service performance, security, payment transactions, or notices regarding our Terms or this Privacy Policy.

3.4. To communicate with you regarding your use of our Service

We communicate with you, for example, by push notifications or by emails. These may include reminders or other information about the Service. To opt out of push notifications, change your device settings. To opt out of emails, click "unsubscribe" in the footer of each email.

3.5. To research and analyze your use of the Service

This helps us better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service. We use these insights for statistical analysis, to test and improve our offers.

• Tableau — usage pattern research and analysis.
• Amplitude — analytics on how customers use our Service (technical info, time zone, device type, advertising identifiers).
• Appsflyer — research and analysis of how users find and interact with the App.
• Facebook Analytics — aggregated demographics and engagement insights.
• Firebase Analytics — Google's analytics service.

3.6. To send you marketing communications

You may receive information about our products such as special offers or new features. We may show you advertisements on our Service and send you marketing emails. If you do not want to receive marketing emails from us, you can unsubscribe via the footer link.

3.7. To personalize our ads

We and our partners use your personal data to tailor ads. For example, if you visited our Website or installed the App, you might see ads of our products in your Facebook feed.

How to opt out or influence personalized advertising

• iOS: Settings → Privacy → Apple Advertising → deselect Personalized Ads.
• Android: Settings → Privacy → Ads → enable "Opt out of Ads personalization". You can also reset your advertising identifier in the same section.
• macOS: System Preferences → Security & Privacy → Privacy → Apple Advertising → deselect Personalized Ads.
• Windows 10: Start → Settings → Privacy → turn off "Let apps use advertising ID to make ads more interesting to you based on your app activity".

You may also opt out of some interest-based advertising:

• Network Advertising Initiative — optout.networkadvertising.org
• Digital Advertising Alliance — optout.aboutads.info
• DAA Canada — youradchoices.ca/choices
• DAA EU — youronlinechoices.com
• DAA AppChoices — aboutads.info/appchoices

You can also stop your browser from accepting cookies altogether via your browser's settings.

We use Facebook pixel on the Service to track conversions from Facebook ads, build targeted audiences, and remarket to people who have taken some action on the Service.

3.8. To process your payments

We provide paid products within the Service. For payment processing, we use Solidgate as our third-party payment processor. We do not store or collect your payment card details ourselves — this information goes directly to our third-party payment processors.

3.9. To enforce our Terms and to prevent and combat fraud

We use personal data to enforce our agreements and contractual commitments and to detect, prevent, and combat fraud. As a result, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms).

3.10. To comply with legal obligations

We may process, use, or share your data when the law requires it, in particular if a law enforcement agency requests your data by available legal means.

4. Under What Legal Bases We Process Your Personal Data

This section applies only to EEA or Turkey-based users. For more information on a particular purpose, see Section 3. We process your personal data under the following legal bases:

Your consent

Under this legal basis we will also send you marketing communications. You have the right to withdraw your consent any time by using the unsubscribe link in the footer of our emails or in your personal account, or by contacting [email protected]. We will also send you push notifications if you allow us to. You can disable notifications any time in your device settings.

To perform our contract with you

• Provide our Service (in accordance with our Terms);
• Customize your experience;
• Provide you with customer support;
• Communicate with you regarding your use of our Service;
• Process your payments.

For our (or others') legitimate interests

Unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data. We rely on legitimate interests:

• To communicate with you regarding your use of our Service — e.g., notifying you of new products or reminding you to finish a purchase. Our legitimate interest is to encourage you to use our Service more often.
• To research and analyze your use of the Service — to improve the Service and provide a better experience.
• To personalize our ads — to promote our Service in a reasonably targeted way.
• To enforce our Terms and to prevent and combat fraud — enforcing legal rights and addressing unauthorised use.

To comply with legal obligations

We may process your data when the law requires it.

5. With Whom We Share Your Personal Data

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular for purposes and with parties indicated in Section 3.

Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions:

• AI model and services providers: OpenAI, Google, Qdrant, LiveKit;
• Cloud storage providers: Amazon Web Services (AWS), MongoDB;
• Data analytics providers: Appsflyer, Amplitude, Tableau, Facebook, Firebase;
• Measurement partners: Facebook pixel;
• Infrastructure service providers: Temporal, Authentik, Vault;
• Marketing partners: social media networks, marketing agencies, email delivery services, Facebook, Google;
• Payment service providers: Solidgate.

Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms, to protect our rights, privacy, safety, or property — and/or that of our affiliates, you, or others — and to respond to requests from courts, law enforcement, regulatory agencies, and other public authorities.

Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers' information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g., parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as a sale, divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Affiliates

We may share your personal information with our partner organizations that are part of our corporate group — companies that are owned by, own, or are jointly owned with us. These partner organizations will use the information in ways that align with this Privacy Policy.

6. How You Can Exercise Your Privacy Rights

To be in control of your personal data, you have the following rights:

• Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Service.
• Deleting your personal data. You can request erasure as permitted by law. We will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such an event, we will fulfill your request after we have complied with our obligations.
• Right to request controllers to inform third parties. If you reside in Turkey and requested to rectify or delete your personal data, you can request reporting of such operations to third parties to whom your personal data have been transferred.
• Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data, or limit our use of it.
• Right to claim compensation. If you reside in Turkey, you have the right to claim compensation for damage arising from unlawful processing.

Additional rights for EEA-based users

• Right to lodge a complaint with a supervisory authority. We would love you to contact us directly so we can address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection authority — in particular in the EU Member State where you reside, work, or where the alleged infringement took place.
• Right to data portability. If you wish to receive your personal data in a machine-readable format, send a request to us as described below.

If you reside in Turkey, you can lodge a complaint with the Kişisel Verileri Koruma Kurumu using their official form.

To exercise any of your privacy rights, please send a request to [email protected].

7. Age Limitation

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.

8. International Data Transfers

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms, and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

For transfers from the EEA to countries that do not provide an adequate level of data protection, we use Standard Contractual Clauses approved by the European Commission. For transfers from Turkey, we use the Standard Contract.

9. U.S. States Privacy Notice

Applicability

If you reside in a state that has enacted consumer privacy laws, this section applies to you. This U.S. States Privacy Notice ("Notice") supplements our Privacy Policy and provides disclosures required by laws in states such as California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia.

This Notice is designed to supplement our Privacy Policy to ensure compliance with state-specific laws and applies to the collection, use, and sharing of your Personal Information through our websites, mobile applications, and other online or offline services (collectively, the "Services").

For California residents, this also serves as our California Notice at Collection.

The definition of "Personal Information" may vary by state law. Generally, it refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

9.1. Categories of Personal Information We Collect and For What Purposes

For additional details on the purposes of processing and third parties with whom data is shared for each specific purpose, see Section 3.

We may also process de-identified data, ensuring it cannot reasonably be linked back to you. We commit to maintaining and using de-identified data responsibly and will not attempt to re-identify such data unless required to validate our de-identification measures.

9.2. What Personal Information We Share

Certain state privacy laws, such as those in California, require us to disclose the categories of Personal Information that we have shared with third parties for business purposes over the past 12 months.

Some U.S. states grant residents the right to opt out of sharing their Personal Information with third parties in exchange for valuable consideration (which may be classified as a "sale" or "share" under state privacy laws, even if no monetary transaction occurs). If you reside in one of these states and would like to limit the disclosure of your Personal Information to third parties for advertising or marketing purposes, see Section 9.4.

For details regarding the categories of third parties with whom we share Personal Information, see Section 3 and Section 5.

9.3. Your Privacy Rights Under State Laws

Certain U.S. state privacy laws grant residents specific rights regarding their personal information. If you reside in a state with such laws, you may have the following rights:

To exercise any of these rights, submit a request via email: [email protected].

Verification

To ensure that we properly handle requests, we are required to verify them. Depending on the type of request, this may include your email, date of subscription purchase, date of last activity, date of account creation, or other Service use data that will reasonably identify you. We may also ask for additional proof of identity if necessary.

Right to Appeal

If we deny your request, you may have the right to appeal. Contact us and explain your concerns. If you are dissatisfied with the result of the appeal, you may escalate by contacting the Attorney General's office in your state of residence.

Authorized Agents

If you are an authorized agent acting on behalf of a consumer, you may submit an opt-out, access, deletion, or correction request by contacting us. If you are making a request on behalf of a California resident, you may be required to submit proof of authorization, such as a valid power of attorney or written permission signed by the consumer along with identity verification.

Retention of Personal Information

We retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. In many situations, we must retain your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent or illegal activity, or for another business purpose.

9.4. Sales, Sharing, and Targeted Advertising

Privacy laws in some U.S. states broadly define "sale" to include sharing of information via cookies, pixels, and similar tracking technologies for certain targeted advertising activities. We do not sell Personal Information for monetary compensation. However, when you visit our websites, we and our advertising partners may collect device data and behavioral insights through tracking technologies, which could be interpreted as a "sale" or "sharing" under state laws.

We do not knowingly engage in sales, sharing, or targeted advertising using the personal information of individuals under 18.

Opt-Out Rights

You may opt out of sales, sharing, or targeted advertising by contacting us at [email protected] and/or clicking the "unsubscribe" button. Your opt-out settings apply per device and browser. If you switch devices, clear cookies, or use a different browser, you may need to reapply your opt-out settings.

10. Changes to This Privacy Policy

We may modify this Privacy Policy from time to time. If we decide to make material changes, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

11. Data Retention

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Account Information

We retain your account information for as long as your account is active. If you delete your account, we will delete or anonymize it within 30 days, except where we need to retain certain information for legitimate business or legal purposes.

AI System Conversations Data

Your AI system conversations data is retained for as long as your account is active. If you delete your account, your data will be permanently deleted within 30 days.

Usage Data

We may retain anonymized or aggregated usage data for analytical purposes even after you delete your account, but this data cannot be used to identify you.

Backup Data

For disaster recovery purposes, we may retain backup copies of your data for a limited period even after deletion from our active systems.

12. How "Do Not Track" Requests Are Handled

Except as otherwise stipulated in this Privacy Policy, this Service does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.

13. Contact Us

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at [email protected].