Terms of Service

General Terms

• By accessing and placing an order with ImaginAI, you confirm that you are in agreement with and bound by the terms of service contained in the Terms & Conditions outlined below. These terms apply to the entire website and any email or other type of communication between you and ImaginAI.

• Under no circumstances shall ImaginAI team be liable for any direct, indirect, special, incidental or consequential damages, including, but not limited to, loss of data or profit, arising out of the use, or the inability to use, the materials on this site, even if ImaginAI team or an authorized representative has been advised of the possibility of such damages. If your use of materials from this site results in the need for servicing, repair or correction of equipment or data, you assume any costs thereof.

• ImaginAI will not be responsible for any outcome that may occur during the course of usage of our resources. We reserve the rights to change prices and revise the resources usage policy in any moment.

• License

• ImaginAI grants you a revocable, non-exclusive, non-transferable, limited license to download, install and use the app strictly in accordance with the terms of this Agreement.

• These Terms & Conditions are a contract between you and ImaginAI (referred to in these Terms & Conditions as "ImaginAI", "us", "we" or "our"), the provider of the ImaginAI website and the services accessible from the ImaginAI website (which are collectively referred to in these Terms & Conditions as the "ImaginAI Service").

• You are agreeing to be bound by these Terms & Conditions. If you do not agree to these Terms & Conditions, please do not use the ImaginAI Service. In these Terms & Conditions, "you" refers both to you as an individual and to the entity you represent. If you violate any of these Terms & Conditions, we reserve the right to cancel your account or block access to your account without notice.

• Definitions and key terms

• To help explain things as clearly as possible in this Terms & Conditions, every time any of these terms are referenced, are strictly defined as:

• Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics, remember information about you such as your language preference or login information.

• Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to Connectinno, AYDINTEPE MAH. AYDINLI YOLU CAD. NO: 43 I İÇ KAPI NO: 17 TUZLA/ İSTANBUL that is responsible for your information under this Terms & Conditions.

• Country: where ImaginAI or the owners/founders of ImaginAI are based, in this case is TR

• Device: any internet connected device such as a phone, tablet, computer or any other device that can be used to visit ImaginAI and use the services.

• Service: refers to the service provided by ImaginAI as described in the relative terms (if available) and on this platform.

• Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you.

• Website: ImaginAI's site, which can be accessed via this URL:

• You: a person or entity that is registered with ImaginAI to use the Services.

• Restrictions

• You agree not to, and you will not permit others to:

• License, sell, rent, lease, assign, distribute, transmit, host, outsource, disclose or otherwise commercially exploit the app or make the platform available to any third party.

• Modify, make derivative works of, disassemble, decrypt, reverse compile or reverse engineer any part of the app.

• Remove, alter or obscure any proprietary notice (including any notice of copyright or trademark) of ImaginAI or its affiliates, partners, suppliers or the licensors of the app.

• Return and Refund Policy

• Thanks for shopping at ImaginAI. We appreciate the fact that you like to buy the stuff we build. We also want to make sure you have a rewarding experience while you’re exploring, evaluating, and purchasing our products.

• As with any shopping experience, there are terms and conditions that apply to transactions at ImaginAI. We’ll be as brief as our attorneys will allow. The main thing to remember is that by placing an order or making a purchase at ImaginAI, you agree to the terms along with ImaginAI's Privacy Policy.

• If, for any reason, You are not completely satisfied with any good or service that we provide, don't hesitate to contact us and we will discuss any of the issues you are going through with our product.

• Your Suggestions

• Any feedback, comments, ideas, improvements or suggestions (collectively, "Suggestions") provided by you to ImaginAI with respect to the app shall remain the sole and exclusive property of ImaginAI.

• ImaginAI shall be free to use, copy, modify, publish, or redistribute the Suggestions for any purpose and in any way without any credit or any compensation to you.

• Your Consent

• We've updated our Terms & Conditions to provide you with complete transparency into what is being set when you visit our site and how it's being used. By using our app, registering an account, or making a purchase, you hereby consent to our Terms & Conditions.

• Links to Other Websites

• This Terms & Conditions applies only to the Services. The Services may contain links to other websites not operated or controlled by ImaginAI. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Terms & Conditions are no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

• Cookies

• ImaginAI uses "Cookies" to identify the areas of our website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to enhance the performance and functionality of our app but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the app as we would not be able to remember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personally Identifiable Information in Cookies.

• Changes To Our Terms & Conditions

• You acknowledge and agree that ImaginAI may stop (permanently or temporarily) providing the Service (or any features within the Service) to you or to users generally at ImaginAI's sole discretion, without prior notice to you. You may stop using the Service at any time. You do not need to specifically inform ImaginAI when you stop using the Service. You acknowledge and agree that if ImaginAI disables access to your account, you may be prevented from accessing the Service, your account details or any files or other materials which is contained in your account.

• If we decide to change our Terms & Conditions, we will post those changes on this page, and/or update the Terms & Conditions modification date below.

• Modifications to Our app

• ImaginAI reserves the right to modify, suspend or discontinue, temporarily or permanently, the app or any service to which it connects, with or without notice and without liability to you.

• Updates to Our app

• ImaginAI may from time to time provide enhancements or improvements to the features/ functionality of the app, which may include patches, bug fixes, updates, upgrades and other modifications ("Updates").

• Updates may modify or delete certain features and/or functionalities of the app. You agree that ImaginAI has no obligation to (i) provide any Updates, or (ii) continue to provide or enable any particular features and/or functionalities of the app to you.

• You further agree that all Updates will be (i) deemed to constitute an integral part of the app, and (ii) subject to the terms and conditions of this Agreement.

• Third-Party Services

• We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services ("Third-Party Services").

• You acknowledge and agree that ImaginAI shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. ImaginAI does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.

• Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties' terms and conditions.

• Term and Termination

• This Agreement shall remain in effect until terminated by you or ImaginAI.

• ImaginAI may, in its sole discretion, at any time and for any or no reason, suspend or terminate this Agreement with or without prior notice.

• This Agreement will terminate immediately, without prior notice from ImaginAI, in the event that you fail to comply with any provision of this Agreement. You may also terminate this Agreement by deleting the app and all copies thereof from your computer.

• Upon termination of this Agreement, you shall cease all use of the app and delete all copies of the app from your computer.

• Termination of this Agreement will not limit any of ImaginAI's rights or remedies at law or in equity in case of breach by you (during the term of this Agreement) of any of your obligations under the present Agreement.

• Copyright Infringement Notice

• If you are a copyright owner or such owner’s agent and believe any material on our app constitutes an infringement on your copyright, please contact us setting forth the following information: (a) a physical or electronic signature of the copyright owner or a person authorized to act on his behalf; (b) identification of the material that is claimed to be infringing; (c) your contact information, including your address, telephone number, and an email; (d) a statement by you that you have a good faith belief that use of the material is not authorized by the copyright owners; and (e) the a statement that the information in the notification is accurate, and, under penalty of perjury you are authorized to act on behalf of the owner.

• Indemnification

• You agree to indemnify and hold ImaginAI and its parents, subsidiaries, affiliates, officers, employees, agents, partners and licensors (if any) harmless from any claim or demand, including reasonable attorneys' fees, due to or arising out of your: (a) use of the app; (b) violation of this Agreement or any law or regulation; or (c) violation of any right of a third party.

• No Warranties

• The app is provided to you "AS IS" and "AS AVAILABLE" and with all faults and defects without warranty of any kind. To the maximum extent permitted under applicable law, ImaginAI, on its own behalf and on behalf of its affiliates and its and their respective licensors and service providers, expressly disclaims all warranties, whether express, implied, statutory or otherwise, with respect to the app, including all implied warranties of merchantability, fitness for a particular purpose, title and non-infringement, and warranties that may arise out of course of dealing, course of performance, usage or trade practice. Without limitation to the foregoing, ImaginAI provides no warranty or undertaking, and makes no representation of any kind that the app will meet your requirements, achieve any intended results, be compatible or work with any other software, , systems or services, operate without interruption, meet any performance or reliability standards or be error free or that any errors or defects can or will be corrected.

• Without limiting the foregoing, neither ImaginAI nor any ImaginAI's provider makes any representation or warranty of any kind, express or implied: (i) as to the operation or availability of the app, or the information, content, and materials or products included thereon; (ii) that the app will be uninterrupted or error-free; (iii) as to the accuracy, reliability, or currency of any information or content provided through the app; or (iv) that the app, its servers, the content, or e-mails sent from or on behalf of ImaginAI are free of viruses, scripts, trojan horses, worms, malware, timebombs or other harmful components.

• Some jurisdictions do not allow the exclusion of or limitations on implied warranties or the limitations on the applicable statutory rights of a consumer, so some or all of the above exclusions and limitations may not apply to you.

• Limitation of Liability

• Notwithstanding any damages that you might incur, the entire liability of ImaginAI and any of its suppliers under any provision of this Agreement and your exclusive remedy for all of the foregoing shall be limited to the amount actually paid by you for the app.

• To the maximum extent permitted by applicable law, in no event shall ImaginAI or its suppliers be liable for any special, incidental, indirect, or consequential damages whatsoever (including, but not limited to, damages for loss of profits, for loss of data or other information, for business interruption, for personal injury, for loss of privacy arising out of or in any way related to the use of or inability to use the app, third-party software and/or third-party hardware used with the app, or otherwise in connection with any provision of this Agreement), even if ImaginAI or any supplier has been advised of the possibility of such damages and even if the remedy fails of its essential purpose.

• Some states/jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, so the above limitation or exclusion may not apply to you.

• Severability

• If any provision of this Agreement is held to be unenforceable or invalid, such provision will be changed and interpreted to accomplish the objectives of such provision to the greatest extent possible under applicable law and the remaining provisions will continue in full force and effect.

• This Agreement, together with the Privacy Policy and any other legal notices published by ImaginAI on the Services, shall constitute the entire agreement between you and ImaginAI concerning the Services. If any provision of this Agreement is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Agreement, which shall remain in full force and effect. No waiver of any term of this Agreement shall be deemed a further or continuing waiver of such term or any other term, and ImaginAI's failure to assert any right or provision under this Agreement shall not constitute a waiver of such right or provision. YOU AND ImaginAI AGREE THAT ANY CAUSE OF ACTION ARISING OUT OF OR RELATED TO THE SERVICES MUST COMMENCE WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES. OTHERWISE, SUCH CAUSE OF ACTION IS PERMANENTLY BARRED.

• Waiver

• Except as provided herein, the failure to exercise a right or to require performance of an obligation under this Agreement shall not effect a party's ability to exercise such right or require such performance at any time thereafter nor shall be the waiver of a breach constitute waiver of any subsequent breach.

• o failure to exercise, and no delay in exercising, on the part of either party, any right or any power under this Agreement shall operate as a waiver of that right or power. Nor shall any single or partial exercise of any right or power under this Agreement preclude further exercise of that or any other right granted herein. In the event of a conflict between this Agreement and any applicable purchase or other terms, the terms of this Agreement shall govern.

• Amendments to this Agreement

• ImaginAI reserves the right, at its sole discretion, to modify or replace this Agreement at any time. If a revision is material we will provide at least 30 days' notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.

• By continuing to access or use our app after any revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, you are no longer authorized to use ImaginAI.

• Entire Agreement

• The Agreement constitutes the entire agreement between you and ImaginAI regarding your use of the app and supersedes all prior and contemporaneous written or oral agreements between you and ImaginAI.

• You may be subject to additional terms and conditions that apply when you use or purchase other ImaginAI's services, which ImaginAI will provide to you at the time of such use or purchase.

• Updates to Our Terms

• We may change our Service and policies, and we may need to make changes to these Terms so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to these Terms and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Terms. If you do not want to agree to these or any updated Terms, you can delete your account.

• Intellectual Property

• The app and its entire contents, features and functionality (including but not limited to all information, software, text, displays, images, video and audio, and the design, selection and arrangement thereof), are owned by ImaginAI, its licensors or other providers of such material and are protected by TR and international copyright, trademark, patent, trade secret and other intellectual property or proprietary rights laws. The material may not be copied, modified, reproduced, downloaded or distributed in any way, in whole or in part, without the express prior written permission of ImaginAI, unless and except as is expressly provided in these Terms & Conditions. Any unauthorized use of the material is prohibited.

• Agreement to Arbitrate

• This section applies to any dispute EXCEPT IT DOESN’T INCLUDE A DISPUTE RELATING TO CLAIMS FOR INJUNCTIVE OR EQUITABLE RELIEF REGARDING THE ENFORCEMENT OR VALIDITY OF YOUR OR ImaginAI's INTELLECTUAL PROPERTY RIGHTS. The term “dispute” means any dispute, action, or other controversy between you and ImaginAI concerning the Services or this agreement, whether in contract, warranty, tort, statute, regulation, ordinance, or any other legal or equitable basis. “Dispute” will be given the broadest possible meaning allowable under law.

• Notice of Dispute

• In the event of a dispute, you or ImaginAI must give the other a Notice of Dispute, which is a written statement that sets forth the name, address, and contact information of the party giving it, the facts giving rise to the dispute, and the relief requested. You must send any Notice of Dispute via email to: support@ImaginAIapp.ai ImaginAI will send any Notice of Dispute to you by mail to your address if we have it, or otherwise to your email address. You and ImaginAI will attempt to resolve any dispute through informal negotiation within sixty (60) days from the date the Notice of Dispute is sent. After sixty (60) days, you or ImaginAI may commence arbitration.

• Binding Arbitration

• If you and ImaginAI don’t resolve any dispute by informal negotiation, any other effort to resolve the dispute will be conducted exclusively by binding arbitration as described in this section. You are giving up the right to litigate (or participate in as a party or class member) all disputes in court before a judge or jury. The dispute shall be settled by binding arbitration in accordance with the commercial arbitration rules of the American Arbitration Association. Either party may seek any interim or preliminary injunctive relief from any court of competent jurisdiction, as necessary to protect the party’s rights or property pending the completion of arbitration. Any and all legal, accounting, and other costs, fees, and expenses incurred by the prevailing party shall be borne by the non-prevailing party.

• Submissions and Privacy

• In the event that you submit or post any ideas, creative suggestions, designs, photographs, information, advertisements, data or proposals, including ideas for new or improved products, services, features, technologies or promotions, you expressly agree that such submissions will automatically be treated as non-confidential and non-proprietary and will become the sole property of ImaginAI without any compensation or credit to you whatsoever. ImaginAI and its affiliates shall have no obligations with respect to such submissions or posts and may use the ideas contained in such submissions or posts for any purposes in any medium in perpetuity, including, but not limited to, developing, manufacturing, and marketing products and services using such ideas.

• Promotions

• ImaginAI may, from time to time, include contests, promotions, sweepstakes, or other activities (“Promotions”) that require you to submit material or information concerning yourself. Please note that all Promotions may be governed by separate rules that may contain certain eligibility requirements, such as restrictions as to age and geographic location. You are responsible to read all Promotions rules to determine whether or not you are eligible to participate. If you enter any Promotion, you agree to abide by and to comply with all Promotions Rules.

• Additional terms and conditions may apply to purchases of goods or services on or through the Services, which terms and conditions are made a part of this Agreement by this reference.

• Typographical Errors

• In the event a product and/or service is listed at an incorrect price or with incorrect information due to typographical error, we shall have the right to refuse or cancel any orders placed for the product and/or service listed at the incorrect price. We shall have the right to refuse or cancel any such order whether or not the order has been confirmed and your credit card charged. If your credit card has already been charged for the purchase and your order is canceled, we shall immediately issue a credit to your credit card account or other payment account in the amount of the charge.

• Miscellaneous

• If for any reason a court of competent jurisdiction finds any provision or portion of these Terms & Conditions to be unenforceable, the remainder of these Terms & Conditions will continue in full force and effect. Any waiver of any provision of these Terms & Conditions will be effective only if in writing and signed by an authorized representative of ImaginAI. ImaginAI will be entitled to injunctive or other equitable relief (without the obligations of posting any bond or surety) in the event of any breach or anticipatory breach by you. ImaginAI operates and controls the ImaginAI Service from its offices in TR. The Service is not intended for distribution to or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation. Accordingly, those persons who choose to access the ImaginAI Service from other locations do so on their own initiative and are solely responsible for compliance with local laws, if and to the extent local laws are applicable. These Terms & Conditions (which include and incorporate the ImaginAI Privacy Policy) contains the entire understanding, and supersedes all prior understandings, between you and ImaginAI concerning its subject matter, and cannot be changed or modified by you. The section headings used in this Agreement are for convenience only and will not be given any legal import.

• Disclaimer

• ImaginAI is not responsible for any content, code or any other imprecision.

• ImaginAI does not provide warranties or guarantees.

• In no event shall ImaginAI be liable for any special, direct, indirect, consequential, or incidental damages or any damages whatsoever, whether in an action of contract, negligence or other tort, arising out of or in connection with the use of the Service or the contents of the Service. The Company reserves the right to make additions, deletions, or modifications to the contents on the Service at any time without prior notice.

• The ImaginAI Service and its contents are provided "as is" and "as available" without any warranty or representations of any kind, whether express or implied. ImaginAI is a distributor and not a publisher of the content supplied by third parties; as such, ImaginAI exercises no editorial control over such content and makes no warranty or representation as to the accuracy, reliability or currency of any information, content, service or merchandise provided through or accessible via the ImaginAI Service. Without limiting the foregoing, ImaginAI specifically disclaims all warranties and representations in any content transmitted on or in connection with the ImaginAI Service or on sites that may appear as links on the ImaginAI Service, or in the products provided as a part of, or otherwise in connection with, the ImaginAI Service, including without limitation any warranties of merchantability, fitness for a particular purpose or non-infringement of third party rights. No oral advice or written information given by ImaginAI or any of its affiliates, employees, officers, directors, agents, or the like will create a warranty. Price and availability information is subject to change without notice. Without limiting the foregoing, ImaginAI does not warrant that the ImaginAI Service will be uninterrupted, uncorrupted, timely, or error-free.

• Contact Us

• Don't hesitate to contact us if you have any questions.

• Via Email: support@connectinno.com

Privacy Terms

Connectinno Oyun Yazılım Teknolojileri ve Ticaret Anonim Şirketi Privacy Policy and Personal Data Text

“ImaginAI”

1. Objective

Update Date: 12 September 2024

Connectinno Oyun Yazılım Teknolojileri ve Ticaret Anonim Şirketi (“Connectinno” or “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 Connectinno 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

Connectinno may process your personal data for the purposes specified in this Privacy Policy.

The personal data of users collected and used by Connectinno in particular, are as follows: your name and surname, e-mail address and phone number which we will receive once you contact Connectinno, your order information if you make a purchase through in-app purchase, the photo which you have uploaded to ImaginAI application (ImaginAI) 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. We collect your username, password and e-mail address information only when you sign up to ImaginAI and become a member through Registration.

Data Categories and Data Types

Identity Information: Name and surname

• Contact Information: Phone number, e-mail address

• 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 (IDFA) if permission is given

  • Identifier for vendors/developers (IDVF)

• Visual and Audio Records: The photo you have uploaded to ImaginAI

• Customer Transaction: Order information

• User Content: Messages, posts, communication, statements, information, phrases, entries, text, questions, images, photos, videos, visual and audio records, graphics, materials, and any content, record or data that you provide, upload, transmit, create, store, use, edit or share with or through AI Image Generator ImaginAI.

  We may ask for your permission to access your device’s photo file or gallery app or camera tool, in order to provide certain services, when you are using AI Image Generator ImaginAI, such as returning edited images. You can choose not to allow us to access your camera by either rejecting our access or later disabling such access in your device settings. However, you may not be able to use certain aspects of our services if you choose to opt out.

• Marketing Data: IDFA, IDFV

We may collect your above mentioned 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 o the service/application, and other statistics.

General Principles Regarding Personal Data Processing

In accordance with this Privacy Policy, personal data are processed by Connectinno 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.

Sharing and Storing Face Data with Third Parties

Third-Party Data Sharing: Connectinno shares face data collected through the ImaginAI application with third-party service providers such as Vertex AI and Gemini to enable specific functionalities within the app. This collaboration involves the analysis and transformation of face data. The face data is shared exclusively with these providers, strictly for the duration and purpose required to perform the requested services.

Third-Party Storage Practices: Our third-party service providers, Vertex AI and Gemini, adhere to stringent data privacy regulations such as GDPR and CCPA when processing and storing your face data. These entities store face data only for the period necessary to fulfill the functionalities requested by the ImaginAI application. The storage duration of face data is limited to the scope of the intended use, and once this period expires or the data is no longer needed for its intended purpose, it is promptly deleted, destroyed, or anonymized.

Duration and Reason for Data Storage: Face data is stored only as long as necessary for the processing activities for which it was collected. Throughout this period, all necessary technical and administrative measures are taken to ensure the security of the data. Once the storage period ends, or there are no longer legal obligations requiring the retention of the data, the information is immediately deleted or anonymized. The storage practices of our third-party processors are aligned with this policy and are designed to protect the rights of the data subjects throughout the process.

User Rights for Data Deletion

If you wish to request the deletion of your face data, or inquire about the data processing practices, you can do so by sending an email to support@connectinno.com. Upon receiving your request, Connectinno will take steps to ensure that your face data is deleted from our systems and also request our third-party processors to do the same. This process adheres to our commitment to your data privacy and is compliant with applicable data protection laws. You will receive confirmation once your data has been successfully deleted or if further actions are necessary.

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 o Connectinno provided that your fundamental rights and freedoms are protected.

1. 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:

Identity and Contact Information Uses

• Legal and Regulatory Compliance: Ensuring all operations conform to applicable laws, protecting individual rights, privacy, and safety.

• Service Commitments: Fulfilling obligations related to our products and services.

• Communication Operations: Managing interactions with users and stakeholders.

• Business Operations and Audits: Conducting and auditing our business activities for efficacy and compliance.

• After-Sales Services: Offering support post-purchase and engaging in communications related to services and, with your consent, marketing.

• Sales Process Management: Overseeing the sales of goods and services.

• Data Storage and Archiving: Maintaining and securing stored data.

• Contract Execution: Managing and fulfilling contractual obligations.

• Product Operation: Ensuring our products function effectively to meet user needs.

Process Security

• Information Security: Implementing processes to secure user information.

• Ethical and Compliance Audits: Ensuring business integrity and compliance with ethical standards.

• Business Continuity: Establishing protocols to maintain operations under various conditions.

• Authorized Sharing: Providing information to legally authorized entities.

Customer Transactions

• Business Activity Management: Monitoring and auditing business processes related to customer interactions.

• Customer Satisfaction: Engaging in activities to enhance the customer experience.

User Content Management

• Product Functionality: Utilizing user input to refine product responses and features.

• Crime Prevention: Implementing measures to prevent illegal activities.

• Service Improvement: Developing our services, including AI model training (opt-out available via the “Data Subject Application Form” at support@connectinno.com).

Marketing Data Usage

• Market Analysis: Conducting studies to understand market trends and customer needs.

• Promotions and Campaigns: Managing advertising efforts and promotional activities.

Updates to Data Processing Objectives

Our data processing purposes may be revised to align with company policy changes or new legislative requirements, ensuring our operations remain compliant and effective.

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

 Identity Information, Contact Information, 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

Visual and Audio Records

• 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

• Processing is necessary for our legitimate interests, provided that your fundamental rights and freedoms of are not harmed

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  and/or Google)

Third Party Websites and Applications (Third-Party Data Sharing Policy for ImaginAI: AI Image Generator)
Privacy Commitment:
We prioritize your privacy and are committed to protecting your personal information. In the operation of our ImaginAI: AI Image Generator, we may collect and process a variety of data types including messages, posts, communications, statements, phrases, entries, text, questions, images, photos, videos, visual and audio records, graphics, materials, and any other content or data that you provide, upload, transmit, create, store, use, edit, or share through the app.
Data Usage:
The data collected, such as face images and related content, is solely used to facilitate the app's functionalities. This encompasses image analysis, transformation, or generation utilizing machine learning models hosted on third-party platforms like Vertex AI and Gemini.
Third-Party Processors:
Vertex AI and Gemini act as our third-party data processors. These services undertake the processing and analysis of your data while observing stringent privacy and security measures. Your data, including face images and other personal details, are not shared with any entities beyond these specified platforms.
Device Access:
For certain services provided by ImaginAI, such as delivering edited images, we may request access to your device’s photo file, gallery app, or camera tool. You have the option to deny or later disable this access in your device settings. Please note that opting out may restrict your ability to fully utilize some features of our services.
Data Retention:
Data is processed only as long as necessary for the specific task at hand and is not retained in our system or on third-party platforms any longer than required. We ensure that no personal or facial data is stored permanently or utilized for any purposes outside those clearly outlined in this policy.
Compliance:
We confirm that our third-party processors, including Vertex AI and Gemini models, adhere to relevant data privacy regulations, such as GDPR and CCPA, ensuring the protection of your information.
Consent:
By utilizing our services, you agree to the processing of your data, including face images and additional content, by third-party platforms solely to provide the requested functionalities of ImaginAI: AI Image Generator.

ImaginAI; may contain links to other websites that are unknown to Connectinno and whose content is not controlled. These linked websites may contain terms and conditions other than Connectinno texts. Connectinno cannot be held responsible for the use or disclosure of information that these websites may process. Likewise, Connectinno shall not have any responsibility for any links from other sites provided to ImaginAI owned by Connectinno.

We collect information by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used. You are free to refuse our request for this information, with the understanding that we may be unable to provide you with some of your desired services without it.

Cookies

Cookies are little text files that are stored on the browser or hard drive of your computer or mobile device when you visit a webpage or application. Cookies allow a website to run more efficiently in addition to ensuring the presentation of personalized web pages in order to make you live a faster visit experience which is more fit for your specific personal needs and demands. Containing only data on your website visit history via the internet, cookies do not collect any information, including your personal data/files stored on your computer or mobile device. We may use cookies when it is necessary for operating our services, to enhance our service performance and functionality, and to deliver content, including ads relevant to your interests, on our sites, or third-party sites. You can delete cookies which are already present on your computer and prevent the recording/location of cookies on your internet explorer.

Internet browsers are predefined to automatically accept the cookies as default. As the management of cookies varies from browser to browser, you may look at the help menu of the browser or application to get detailed information.

Push Notifications

Connectinno may occasionally send you push notifications via its mobile applications regarding application upgrades or notifications about our services. You can always edit such communication and notifications through the settings on your device and stop receiving such communications and notifications.

Your data will be stored for the duration specified in the applicable legislation or for a reasonable time until the purpose of processing ceases to exist, or during legal periods of limitation.

Connectinno may continue to store your personal data, even after the expiry of the purpose of its use provided that it is required by other laws or a separate granted by you in this regard.

In cases that you allow Connectinno to store your personal data for additional time by giving your consent, such data shall be immediately deleted, destructed or anonymized upon the expiry of such additional time or once the purpose of processing no longer exists.

Technical and Administrative Measures

Connectinno stores the personal data it processes in accordance with relevant legislation for periods stipulated in relevant legislation or required for the purpose of processing. Connectinno undertakes to take all necessary technical and administrative measures and to take the due care to ensure the confidentiality, integrity and security of personal data. In this context, it takes the necessary measures to prevent unlawful processing of personal data, unauthorized access to data, unlawful disclosure, modification or destruction of data. Accordingly, Connectinno takes the following technical and administrative measures regarding the personal data it processes:

Anti-virus application. On all computers and servers in Connectinno's information technology infrastructure, a periodically updated anti-virus application is installed.

Firewall. The data center and disaster recovery centers hosting Connectinno servers are protected by periodically updated software-loaded firewalls; the relevant next generation firewalls control the internet connections of all staff and provide protection against viruses and similar threats during this control.

VPN. Suppliers can access Connectinno servers or systems through SSL-VPN defined on Firewalls. A separate SSL-VPN identification has been made for each supplier; with the identification made, the supplier only provides access to the systems that it should use or is authorized to use.

User identifications. Connectinno employees' authorization to Connectinno systems is limited only to the extent necessary by job descriptions; in case of any change of authority or duty, systemic authorizations are also updated.

Information security threat and event management. Events that occur on Connectinno servers and firewalls, are transferred to the “Information Security Threat and Event

Management” system. This system alerts the responsible staff when a security threat occurs and allows them to respond immediately to the threat.

Encryption. Sensitive data is stored with cryptographic methods and if required, transferred through environments encrypted with cryptographic methods and cryptographic keys are stored in secure and various environments.

Logging. All transaction records regarding sensitive data are securely logged.

Two-factor authentication. Remote access to sensitive data is allowed through at least two- factor authentication.

Penetration test. Periodically, penetration tests are performed on servers in the Connectinno system. The security gaps created as a result of this test are closed and a verification test is performed to show that the relevant security gaps have been closed. Besides, Information Security Threat and Event Management System automatically performs penetration tests. Test results are recorded.

Information Security Management System (ISMS). At the ISMS meetings made within Connectinno, the topics contained in the control forum are audited monthly by the director of information technology and the director of financial operations.

Training. In order to increase the awareness of Connectinno employees against various information security violations and to minimize the impact of the human factor in informatio violation incidents, trainings are provided to employees at regular intervals.

Physical data security. It ensures that personal data on papers is necessarily stored in lockers and accessed only by authorized persons. Adequate security measures (for situations such as electric leakage, fire, deluge, thievery etc.) are taken based on the nature of the environment where sensitive data is stored.

Backup. Connectinno periodically backs up the data it stores. As a backup mechanism, it uses the backup facilities provided by the cloud infrastructure providers, as well as the backup solutions it develops when deemed necessary, provided that it is in compliance with relevant legislation and provisions of this Policy.

Non-disclosure agreement. Non-disclosure agreements are concluded with employees taking part in sensitive personal data processing.

Transfer of sensitive personal data. If transfer of sensitive personal data is required through email; such transfer is done through (i) encrypted corporate email or (ii) Registered E-mail.

In the event that the personal data is damaged as a result of attacks on ImaginAI or on the Connectinno system, despite Connectinno taking the necessary information security measures, or the personal data is obtained by unauthorized third parties, Connectinno notifies this situation to Users immediately and, if necessary, to relevant data protection authority and takes necessary measures.

4. Transferring Personal Data to Third Parties

The procedures and principles to be applied for transferring of personal data are regulated in articles 8 and 9 of the PDP Law, and the personal and special categories of data of the supplier may be transferred to third parties within the country or abroad since we may use servers and cloud systems located abroad.

Your personal data may be transferred abroad for the following reasons:

•  Conducting storage and archive activities

• Conducting business activities

• Conducting after-sales support services for goods/services

• Managing customer relationship management processes

Connectinno may also transfer your personal data to services providers of our Company, third parties such as Facebook SDK, Adjust and Firebase Analytics which are embedded into our service for the following purposes:

• Sharing identity, communication and transaction security information with authorized public institutions and organizations for the purpose of execution of activities in compliance with legislation, monitor and execution of legal affairs, informing authorized persons, institutions and organizations.

• Sharing identity and contact information to manage after-sales support services, conduct business activities and manage customer relationship management processes.
  
  

5. Your Rights as the Data Subject

Pursuant to Article 11 of the PDP Law, you may request the following regarding your personal data by applying to Connectinno:

• Learn whether or not your personal data have been processed;

• Demand for information as to if your personal data have been processed;

• Learn the purpose of the processing of personal data and whether data are used in accordance with their purpose;

• Know the third parties in the country or abroad to whom your personal data have been transferred;

• In case the personal data is processed incompletely or inaccurately; requesting notification of the transactions made under this scope to third parties to whom personal data have been transferred;

• Request deletion, destruction or anonymization of personal data if the reasons for the processing have disappeared and request notification of the transactions made under this scope to third parties to whom personal data have been transferred;

• Object to occurrence of any result that is to your detriment by means of the analysis of personal data exclusively through automated systems;

• Request compensation for the damages in case you incur damages due to unlawful processing of your personal data.

Where General Data Protection Regulation (GDPR) is applicable, data subjects have the following rights:

• Right of access - Learning whether personal data is being processed and, if so, accessing your personal data and the information regarding the processing of your personal data,

• Right to correction -To request the correction of information that you believe is inaccurate or the completion of information that you believe is incomplete by Connectinno,

• Right to delete – To request deletion of personal data under the conditions stipulated in GDPR,

• The right to restrict processing - To request the restriction of the processing of personal data under the conditions stipulated in the GDPR,

• Right to object to processing - To object to the processing of personal data under the conditions stipulated in the GDPR,

• Right to data portability - To request the data collected by Connectinno to be transferred directly to another organization or under certain conditions,

• Objection to the occurrence of a result against the person himself/herself, by analyzing the processed data exclusively through automatic systems, including profiling.

In the application that includes your explanations about the right you have as the data subject and exercise your rights stated above and that you request to exercise; your request must be explicit and understandable, if the subject of your request is related to you or if you are acting on behalf of someone else, you must be specially authorized in this regard and your authority must be documented, the application must contain identity and address information and documents proving your identity must be attached to the application. Our Company will enable you to file such requests through the “Data Subject Application Form” at support@connectinno.com. In accordance with Article 13 of the PDP Law, our Company will finalize your requests, free of charge, within 30 (thirty) days at the latest depending on the nature of the request. In case the request is rejected, the reason or reasons for the rejection will be notified in writing or electronically along with its justification.

If you believe that we or someone with whom we have transferred your data is violating your rights, you can file a complaint to the data protection authority in your country and to other competent supervisory authorities.

This Privacy Policy may be revised by our Company when deemed necessary. If you continue to access ImaginAI and use or access ImaginAI without benefiting from the Services offered by Connectinno after the notification period, you shall be deemed to have allowed the changes in this Privacy Policy.

Company Title: Connectinno Oyun Yazılım Teknolojileri ve Ticaret Anonim Şirketi

Address:             Çınarlı Mah. Ozan Abay Cad. Egeperla No: 8 Iç Kapi No: Z17 Konak / Izmir

E-mail: support@connectinno.com