Privacy Policy

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Privacy Policy - Cync AI Proksi Yazilim Inc. (the “Company,” “we,” or “our”) hereby declares its commitment to protecting Personal Information by establishing a privacy policy (the “Policy”) for handling Users’ Personal Information. This policy promotes a system for Personal Information protection and ensures that all employees understand its importance and rigorously implement protective measures for Personal Information. (Personal Information) “Personal Information” in this Policy refers to data defined as “Personal Information” under the Act on the Protection of Personal Information of the Republic of Turkey, which includes any information that can identify a specific living individual by name, date of birth, or other descriptions, or a code that can identify a specific individual. Cync AI may access the User's external storage to facilitate the uploading of audio and video files. Additionally, we may collect and process images as part of our Services. (Face Data Collection) For specific features of Cync AI, such as Face Swap Images and Face Swap Videos, we collect and use Full Frontal Face Data that Users choose to upload. This face data includes a digital representation of a User’s face to enable the app's face-swapping functionality. (Purpose of Use of Personal Information) We may acquire and use Users’ Personal Information within the scope necessary for the following purposes. If we seek to use such information beyond these purposes, we will obtain prior written consent from the Users concerned: to perform the Services; to provide and maintain our Services; to notify Users about changes to our Services; to allow Users to participate in interactive features of our Services when Users choose to do so; to provide customer support; to gather analysis or valuable information to improve our Services; to monitor the usage of our Services; to detect, prevent, and address technical issues; to fulfill any other purpose for which Users provide it; to carry out obligations and enforce rights arising from any contracts with Users, including for billing and collection; to provide Users with account and subscription-related notices, including expiration and renewal notices, email instructions, etc.; to provide Users with news, special offers, and general information about goods, services, and events similar to those Users have already purchased or inquired about, unless they opt not to receive such information; and to identify Users who have violated the Terms of Use or who intend to use the Services for unlawful purposes, and to block their use of the Services. (Purpose of Use of Face Data) The Full Frontal Face Data collected from Users will be used solely for generating Face Swap Images and Face Swap Videos. This data will remain stored on our secure servers to facilitate access for face-swapping functionality as requested by the User. (Data Storage and Sharing) Face Data is stored securely on Cync AI’s servers and is not shared with any third parties. We employ stringent security measures to protect all stored data, ensuring that face data remains accessible only for the User's face-swapping activities within the app. Face Data is retained on the server to enable quick access for future face-swapping requests. (Retention of Face Data) Face Data is retained on our servers only as long as it is needed to provide face-swapping functionality or until the User deletes the data from the Face Gallery Page within the app. Once deleted by the User, the face data is permanently erased from our servers and is no longer accessible within the app. (Management and Protection of Personal Information) We will carefully and closely manage Personal Information and will not disclose or provide it to any third parties without prior written consent from the User, except in the following cases: if disclosure is necessary to protect the life, body, or property of a person and it is difficult to obtain consent; if disclosure is necessary for public health or children’s welfare, and obtaining consent is difficult; if disclosure is necessary to cooperate with a state organ, local government, or business operator in executing legal duties, and obtaining consent may hinder those duties; and if permitted by laws and regulations. We take preventive and corrective measures against risks resulting from any unauthorized access to Personal Information, or any loss, destruction, falsification, or leakage of Personal Information. Stored Face Data on our servers is secured through encryption, restricted access, and organizational and technical safeguards. In the unlikely event of a data-related incident, we will follow the procedures according to the Personal Information Protection Act and report to relevant authorities. (Entrustment of Personal Information Handling) We may entrust individuals or business operators to handle Personal Information in whole or part. In such cases, we will examine their eligibility, obligate confidentiality through contractual terms, and supervise their activities to ensure compliance. (Disclosure of Personal Information) Users may request the Company to disclose Personal Information held by us per Article 8. Upon receiving such a request, we will disclose the information without delay, unless: disclosure is likely to harm the life, body, property, or other rights of the User or any third party; disclosure is likely to hinder the proper execution of our business; or disclosure may result in a violation of any laws and regulations. (Correction of Retained Personal Data) If Personal Information held by us is inaccurate, Users may request corrections, additions, or deletions of such information (“Correction”) per Article 8. Upon receiving such a request, we will conduct necessary research and make corrections if necessary, notifying the User without delay. (Discontinuation of Personal Information Use) Users may request that we cease using, erase, or cease providing personal data to third parties (“Cessation”) per Article 8. If such a request is well-grounded, we will cease use promptly. If Cessation is unduly difficult, we may take alternative measures to protect the User’s rights and interests. (Procedures for Disclosure of Personal Information) To request information per Articles 5-7, Users must complete a designated request form and provide the following identification documents. A handling fee of 2,000 yen applies for each request. Identification documents User requests: Copy of the User’s driver’s license, passport, or health insurance card. Agent requests: Copy of the User’s identification, the representative’s identification, and a letter of attorney confirming representation. (User Control Over Face Data) Users can delete their Face Data anytime from the Face Gallery Page in the app. This action permanently erases the data from our servers, providing Users full control over their data and ensuring retention only as long as desired. (Procedures for Amending Privacy Policy) We review this Policy regularly to improve our practices. Amendments are valid once notified to all Users or uploaded on our website in accordance with our procedures. (Compliance with Laws, Regulations, and Norms) We comply with Turkish laws and other applicable regulations related to Personal Information. (Response to Complaints and Consultations) We will promptly address any complaints and provide consultations for Users regarding their Personal Information. (Security Measures) Personal Information is protected through organizational, physical, personal, and technical measures, such as restricting access to Personal Information files, recording access logs, and implementing security measures to prevent unauthorized access. In the event of an incident, we will notify relevant authorities per the Personal Information Protection Act and take corrective measures as instructed to prevent recurrence. (Customer Desk) E-mail: cyncai@proksiyazilim.com Established on and valid from October 14, 2024

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