Privacy Policy
==============
Last updated: June 14, 2026
This Privacy Policy describes Our policies and procedures on the collection,
use and disclosure of Your information when You use the Service and tells You
about Your privacy rights and how the law protects You.
We use Your Personal Data to provide and improve the Service. By using the
Service, You agree to the collection and use of information in accordance with
this Privacy Policy. This Privacy Policy has been created with the help of the
[Privacy Policy Generator](https://www.termsfeed.com/privacy-policy-
generator/).
Interpretation and Definitions
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Interpretation
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The words whose initial letters are capitalized have meanings defined under
the following conditions. The following definitions shall have the same
meaning regardless of whether they appear in singular or in plural.
Definitions
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For the purposes of this Privacy Policy:
* Account means a unique account created for You to access our Service or
parts of our Service.
* Affiliate means an entity that controls, is controlled by, or is under
common control with a party, where "control" means ownership of 50% or
more of the shares, equity interest or other securities entitled to vote
for election of directors or other managing authority.
* Application refers to Three-Two-One Action, the software program provided
by the Company.
* Company (referred to as either "the Company", "We", "Us" or "Our" in this
Privacy Policy) refers to Three-Two-One Action.
* Country refers to: Turkey
* Device means any device that can access the Service such as a computer, a
cell phone or a digital tablet.
* Personal Data (or "Personal Information") is any information that relates
to an identified or identifiable individual.
We use "Personal Data" and "Personal Information" interchangeably unless a
law uses a specific term.
* Service refers to the Application.
* Service Provider means any natural or legal person who processes the data
on behalf of the Company. It refers to third-party companies or
individuals employed by the Company to facilitate the Service, to provide
the Service on behalf of the Company, to perform services related to the
Service or to assist the Company in analyzing how the Service is used.
* Usage Data refers to data collected automatically, either generated by the
use of the Service or from the Service infrastructure itself (for example,
the duration of a page visit).
* You means the individual accessing or using the Service, or the company,
or other legal entity on behalf of which such individual is accessing or
using the Service, as applicable.
Collecting and Using Your Personal Data
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Types of Data Collected
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Personal Data
*************
While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You.
Personally identifiable information may include, but is not limited to:
Usage Data
**********
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our
Service that You visit, the time and date of Your visit, the time spent on
those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect
certain information automatically, including, but not limited to, the type of
mobile device You use, Your mobile device's unique ID, the IP address of Your
mobile device, Your mobile operating system, the type of mobile Internet
browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit Our
Service or when You access the Service by or through a mobile device.
Use of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~
The Company may use Personal Data for the following purposes:
* To provide and maintain our Service , including to monitor the usage of
our Service.
* To manage Your Account: to manage Your registration as a user of the
Service. The Personal Data You provide can give You access to different
functionalities of the Service that are available to You as a registered
user.
* For the performance of a contract: the development, compliance and
undertaking of the purchase contract for the products, items or services
You have purchased or of any other contract with Us through the Service.
* To contact You: To contact You by email, telephone calls, SMS, or other
equivalent forms of electronic communication, such as a mobile
application's push notifications regarding updates or informative
communications related to the functionalities, products or contracted
services, including the security updates, when necessary or reasonable for
their implementation.
* To provide You with news, special offers, and general information about
other goods, services and events which We offer that are similar to those
that you have already purchased or inquired about unless You have opted
not to receive such information.
* To manage Your requests: To attend and manage Your requests to Us.
* For business transfers: We may use Your Personal Data to evaluate or
conduct a merger, divestiture, restructuring, reorganization, dissolution,
or other sale or transfer of some or all of Our assets, whether as a going
concern or as part of bankruptcy, liquidation, or similar proceeding, in
which Personal Data held by Us about our Service users is among the assets
transferred.
* For other purposes : We may use Your information for other purposes, such
as data analysis, identifying usage trends, determining the effectiveness
of our promotional campaigns and to evaluate and improve our Service,
products, services, marketing and your experience.
We may share Your Personal Data in the following situations:
* With Service Providers: We may share Your Personal Data with Service
Providers to monitor and analyze the use of our Service, to contact You.
* For business transfers: We may share or transfer Your Personal Data in
connection with, or during negotiations of, any merger, sale of Company
assets, financing, or acquisition of all or a portion of Our business to
another company.
* With Affiliates: We may share Your Personal Data with Our affiliates, in
which case we will require those affiliates to honor this Privacy Policy.
Affiliates include Our parent company and any other subsidiaries, joint
venture partners or other companies that We control or that are under
common control with Us.
* With business partners: We may share Your Personal Data with Our business
partners to offer You certain products, services or promotions.
* With other users: If Our Service offers public areas, when You share
Personal Data or otherwise interact in the public areas with other users,
such information may be viewed by all users and may be publicly
distributed outside.
* With Your consent : We may disclose Your Personal Data for any other
purpose with Your consent.
Retention of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
The Company will retain Your Personal Data only for as long as is necessary
for the purposes set out in this Privacy Policy. We will retain and use Your
Personal Data to the extent necessary to comply with our legal obligations
(for example, if We are required to retain Your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.
Where possible, We apply shorter retention periods and/or reduce
identifiability by deleting, aggregating, or anonymizing data. Unless
otherwise stated, the retention periods below are maximum periods ("up to")
and We may delete or anonymize data sooner when it is no longer needed for the
relevant purpose. We apply different retention periods to different categories
of Personal Data based on the purpose of processing and legal obligations:
* Account Information
* User Accounts: retained for the duration of your account relationship
plus up to 24 months after account closure to handle any post-
termination issues or resolve disputes.
* Usage Data
* Application usage statistics: up to 24 months to understand feature
adoption and service improvements.
* Server logs (IP addresses, access times): up to 24 months for security
monitoring and troubleshooting purposes.
Usage Data is retained in accordance with the retention periods described
above, and may be retained longer only where necessary for security, fraud
prevention, or legal compliance.
We may retain Personal Data beyond the periods stated above for different
reasons:
* Legal obligation: We are required by law to retain specific data (e.g.,
financial records for tax authorities).
* Legal claims: Data is necessary to establish, exercise, or defend legal
claims.
* Your explicit request: You ask Us to retain specific information.
* Technical limitations: Data exists in backup systems that are scheduled
for routine deletion.
You may request information about how long We will retain Your Personal Data
by contacting Us.
When retention periods expire, We securely delete or anonymize Personal Data
according to the following procedures:
* Deletion: Personal Data is removed from Our systems and no longer actively
processed.
* Backup retention: Residual copies may remain in encrypted backups for a
limited period consistent with our backup retention schedule and are not
restored except where necessary for security, disaster recovery, or legal
compliance.
* Anonymization: In some cases, We convert Personal Data into anonymous
statistical data that cannot be linked back to You. This anonymized data
may be retained indefinitely for research and analytics.
Transfer of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Your information, including Personal Data, is processed at the Company's
operating offices and in any other places where the parties involved in the
processing are located. It means that this information may be transferred to —
and maintained on — computers located outside of Your state, province, country
or other governmental jurisdiction where the data protection laws may differ
from those from Your jurisdiction.
Where required by applicable law, We will ensure that international transfers
of Your Personal Data are subject to appropriate safeguards and supplementary
measures where appropriate. The Company will take all steps reasonably
necessary to ensure that Your data is treated securely and in accordance with
this Privacy Policy and no transfer of Your Personal Data will take place to
an organization or a country unless there are adequate controls in place
including the security of Your data and other personal information.
Delete Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~
You have the right to delete or request that We assist in deleting the
Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You
from within the Service.
You may update, amend, or delete Your information at any time by signing in to
Your Account, if you have one, and visiting the account settings section that
allows you to manage Your personal information. You may also contact Us to
request access to, correct, or delete any Personal Data that You have provided
to Us.
Please note, however, that We may need to retain certain information when we
have a legal obligation or lawful basis to do so.
Disclosure of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Business Transactions
*********************
If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your Personal
Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
***************
Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).
Other legal requirements
************************
The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:
* Comply with a legal obligation
* Protect and defend the rights or property of the Company
* Prevent or investigate possible wrongdoing in connection with the Service
* Protect the personal safety of Users of the Service or the public
* Protect against legal liability
Security of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
The security of Your Personal Data is important to Us, but remember that no
method of transmission over the Internet, or method of electronic storage is
100% secure. While We strive to use commercially reasonable means to protect
Your Personal Data, We cannot guarantee its absolute security.
Children's Privacy
------------------
Our Service does not address anyone under the age of 16. We do not knowingly
collect personally identifiable information from anyone under the age of 16.
If You are a parent or guardian and You are aware that Your child has provided
Us with Personal Data, please contact Us. If We become aware that We have
collected Personal Data from anyone under the age of 16 without verification
of parental consent, We take steps to remove that information from Our
servers.
If We need to rely on consent as a legal basis for processing Your information
and Your country requires consent from a parent, We may require Your parent's
consent before We collect and use that information.
Links to Other Websites
-----------------------
Our Service may contain links to other websites that are not operated by Us.
If You click on a third party link, You will be directed to that third party's
site. We strongly advise You to review the Privacy Policy of every site You
visit.
We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.
Changes to this Privacy Policy
------------------------------
We may update Our Privacy Policy from time to time. We will notify You of any
changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior
to the change becoming effective and update the "Last updated" date at the top
of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.
Contact Us
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If you have any questions about this Privacy Policy, You can contact us:
* By email: threetwooneactionerasmusplus@gmail.com