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1. Purpose

ClearSnap is committed to processing users' personal data in compliance with the general principles of privacy and the provisions of the Personal Data Protection Law No. 6698 ("PDP Law") and other applicable legislation.

ClearSnap processes personal data in a limited and measured manner for the purpose stated below, ensuring the accuracy and timeliness of the data provided or notified to the Company. The data may be recorded, stored, reorganized, and transferred to authorized institutions under the conditions specified by law. Personal data may also be shared with third parties within the country or abroad in accordance with applicable legislation.

This Privacy Policy explains how we collect, use, store, protect, and share personal data, how you can withdraw consent, correct, or update your data.

2. Collection and Processing of Personal Data

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

The personal data collected and used by ClearSnap may include, but are not limited to:

• Device Information: Identifier for Advertisers (IDFA), Identifier for Vendors (IDVF), IP address, device name, operating system version.

• Transaction Data: Order history, purchase records.

• Location Data: General location data such as country or city.

ClearSnap collects your data through:

a. Direct input by you: Such as information provided when contacting us.

b. Third-party platforms: For example, through Apple App Store, Google Play, or other app stores.

c. Automatically generated data: Such as log data, usage duration, device information, etc.

3. Data Categories and Types

a. Identity Information: Name, email address, phone number.

b. Device and Network Information: IDFA, IDVF, IP address, device type, operating system version.

c. Transaction Data: Order and purchase history.

d. Marketing Data: Data used for advertising and marketing, including IDFA and IDVF.

ClearSnap does not collect or process any Google user data when using Google APIs through ClearSnap. If you interact with Google services via ClearSnap, any data access will comply with Google's User Data Policy.

4. Basic Principles for Data Processing

In processing personal data, ClearSnap adheres to the following basic principles:

a. Legality and Fairness: All data will be processed in accordance with the law and in a fair manner.

b. Accuracy: The data will be accurate and, when necessary, kept up to date.

c. Specific, Legitimate Purpose: Personal data will only be processed for specific, legitimate purposes.

d. Data Minimization: Only the minimum amount of data necessary for the intended purpose will be processed.

e. Retention Period: Data will be retained for the period required by law or until the purpose of processing no longer exists.

5. Purposes and Legal Grounds for Data Processing

ClearSnap processes personal data for the following purposes:

a. Identity and Contact Information: To provide services, support, and communication, as well as for sales-related activities.

b. Security Processing: To ensure data security, business continuity, and legal compliance.

c. Marketing Data: To analyze user behavior and improve services, including personalized advertising.

Legal grounds for processing include:

• Contract Performance: To fulfill obligations under a contract.

• Legitimate Interest: For the legitimate interests of the Company, provided they do not outweigh your fundamental rights and freedoms.

• Legal Obligation: To comply with legal obligations.

• Consent: When you give explicit consent for data processing, such as for targeted advertising.

6. Third-Party Websites and Applications

ClearSnap's services may contain links to external websites or services that are not controlled by ClearSnap. We are not responsible for the privacy practices or content of these websites. Please review their privacy policies before using them.

7. Fees

We offer both free and paid Services. If you choose to subscribe to a paid Service, you agree to pay the fees ("Fees") as quoted to you when you purchase that Service. We may calculate taxes payable by you based on the billing information that you provide us at the time of purchase. You are responsible for all charges related to using the purchased Service (for example, data charges and currency exchange settlements). You will pay the Fees in the currency We quoted at the time of purchase. We reserve the right to change the eligible currencies at any time, except where not permitted by applicable law. We reserve the right to change its prices at any time. However, if we have offered a specific duration and Fee for your use of the Service, we agree that the Fee will remain in force for that duration.

8. Use of Cookies

ClearSnap uses cookies to enhance service functionality, improve user experience, and personalize content. Cookies are small text files stored on your device to track usage and preferences. You can delete or block cookies through your browser settings, but this may affect the performance of certain features.

9. Push Notifications

ClearSnap may send push notifications to your device regarding application updates or service-related notifications. You can manage or disable these notifications through your device settings.

10. Data Storage and Security

ClearSnap takes necessary technical and administrative measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These measures include encryption, access control, and secure data storage.

11. Sharing and Transferring Personal Data

In compliance with applicable laws, ClearSnap may share your personal data with third-party service providers, such as cloud hosting services, analytics companies, or for legal compliance purposes.

Personal data may be shared for the following reasons:

• Business operations: To conduct activities such as storage, archiving, customer relationship management, and support services.

• Legal compliance: To comply with legal obligations and cooperate with public authorities.

12. Your Rights

Under the PDP Law and GDPR, you have the following rights regarding your personal data:

a. Right of Access: To know whether your data has been processed and to request access to it.

b. Right to Correction: To correct inaccurate or incomplete data.

c. Right to Deletion: To request the deletion of your data when the processing purpose has ended.

d. Right to Withdraw Consent: To withdraw your consent at any time.

e. Right to Object: To object to the processing of your data for specific purposes, including automated decision-making.

f. Right to Data Portability: To request the transfer of your data to another service provider.

13. Complaints and Disputes

If you believe your rights have been violated, you can lodge a complaint with the relevant data protection authority. ClearSnap will assist in resolving any issues regarding your data rights.

14. Changes to the Privacy Policy

ClearSnap may update this Privacy Policy as needed. Any changes will be posted on this page, and they will take effect once they are published. By continuing to use our services, you agree to the updated policy.

15. Contact Us

If you have any questions or concerns regarding this Privacy Policy or would like to exercise your data rights, please contact us via email:

• Email: clearsnap_feedback@hotmail.com