Hancy AI: The Future of Photo Enhancement

1. How Do We Collect Your Data

In the operation of Hancy AI, we collect and process various types of personal data to provide and improve our services. This data is collected in the following ways:

Directly from You: This includes data you actively provide when creating avatars, such as your photos containing facial biometric data, and any contact information you choose to share with us.

Automatically Through App Usage: As you interact with our app, we automatically collect information including usage details, device information such as hardware models and operating system versions, unique device identifiers, mobile network information, and internet protocol (IP) addresses.

From Third Parties: We may receive information about you from our service providers, partners, and vendors, which aids in enhancing our services and your user experience.

2. What Data Do We Collect

Photos and Biometric Facial Data: Essential for avatar creation and personalization.

Device and Usage Data: To understand how you interact with our app and to improve app functionality.

Contact Information: Used for communication and customer support.

The processing of your photos and facial data is classified as 'biometric data' under the GDPR. We handle this sensitive data with the utmost care and security. The legal basis for processing this data includes your explicit consent and the necessity for the performance of our service to you.

We use this collected data to provide, maintain, and improve our services, facilitate avatar creation, and optimize your overall experience with Hancy AI. Our commitment to processing your data adheres to GDPR guidelines, ensuring its protection through stringent security measures.

Types of Data	Purpose/Usage	How We Collect	Legal Basis	Storage/Retention
User and Mobile Identifiers	To identify users for app functionality and personalization	Directly from users; Automatically through the app	Based on the contract (Art. 6.1.b GDPR)	10 years, then deleted or anonymized
Device Information	To optimize app performance and user experience	Automatically through the app	Legitimate interest (Art. 6.1.f GDPR)	10 years, then deleted or anonymized
Subscription Information	To manage user subscriptions and provide services	Directly from users	Contractual necessity (Art. 6.1.b GDPR)	10 years, then deleted or anonymized
App Interaction Data	To enhance app features and functionality	Automatically through the app	Legitimate interest (Art. 6.1.f GDPR)	10 years, then deleted or anonymized
Images, Videos, Audio	For avatar creation and personalization	Directly from users	User consent (Art. 6.1.a GDPR)	2 months, then automatically deleted
Facial Data	To generate personalized avatars	From uploaded images	User consent (Art. 6.1.a GDPR)	2 months, then automatically deleted
Contact Information	For communication and support	Directly from users	Contractual necessity (Art. 6.1.b GDPR)	10 years, then deleted or anonymized

3. Marketing and Advertising Practices

a) Marketing Activities:

We may engage in marketing activities to provide you with information about our apps, such as tips, offers, and newsletters, which may be sent through emails and push notifications. For these activities, we use data including user identifiers (like Apple ID), mobile identifiers (such as IP addresses and device identifiers), information about your interaction with the app, and inferences about your use of the app. The legal basis for these activities is your explicit consent (Article 6.1.a GDPR) and, for emails related to our products and services, our legitimate interest (Article 6.1.f GDPR) under the soft opt-in rule. You can manage your preferences and consent through the app's privacy settings. Personal data used for marketing is retained for up to ten years from your last interaction with the app or after your subscription expires, after which it is either deleted or anonymized, unless legal requirements dictate otherwise.

b) Targeted Advertising:

For targeted advertising, we use third-party tracking technologies. This includes data such as user identifiers (including Apple ID, IP address, IDFA, AAID), interaction details with the app, advertising data (like ad conversion information and viewed advertisements), and your preferences for ad tracking and receiving personalized ads. The collection of this data is based on your consent. You can control ad tracking in your device settings (for iOS: Settings > Privacy & Security > Tracking). The retention period for this data aligns with the policies of the third-party service providers, which are detailed in the "In-app tracking technologies" section.

4. Compliance with Legal Requirements

Legal Compliance: We may need to process your personal data to comply with legal obligations, like responding to requests from public authorities or proving our compliance with legal requirements. This can involve any kind of information required by law. The legal basis for this processing is either specific legal obligations (Article 6.1.c GDPR) or our legitimate interest in proving compliance (Article 6.1.f GDPR).

Defense: In situations like corporate transactions (bankruptcy, mergers, acquisitions), or to establish, exercise, or defend our rights and those of our employees, we may process any necessary personal data. This processing is based on our legitimate interest (Article 6.1.f GDPR). The retention period for such data is a maximum of ten years from your last app interaction or post-subscription expiration. Specific legal obligations might require different retention periods, and in such cases, those periods will apply. After the retention period, the data is either deleted or anonymized.

5. Who We Share Your Data With

At Hancy AI, we take your privacy seriously and only share your personal data with third parties when necessary and under lawful grounds. We assure you that we do not sell your data, including any images you upload, under any circumstances. The sharing of your personal data occurs in the following scenarios:

With Our Service Providers and Business Partners: We share your data with third parties who perform services on our behalf or assist us in operating our app. This includes cloud storage providers, analytics partners, and email delivery services. These entities act as data processors on our behalf and are bound by strict data processing agreements to ensure the security and confidentiality of your data.

For Personalized Advertising: If you consent to the use of tracking technologies, we may share your data with third parties specializing in personalized advertising. For more detailed information on these activities, please refer to the "In-app tracking technologies" section.

During Corporate Transactions: In the event of mergers, acquisitions, reorganizations, asset sales, or similar corporate transactions, your personal data may be transferred to advisors, new owners, or other relevant parties as part of the due diligence process.

To Public and Legal Authorities: We may disclose your data to public, judicial, or police authorities as required by law, or to protect our rights, property, and safety, or that of our users and the public. This includes responding to legal processes such as search warrants, court orders, or subpoenas.

In Other Necessary Circumstances: We may also share your data when necessary to comply with legal obligations, to protect against fraud and illegal activities, or if you give us your explicit consent for specific additional sharing.

Your personal data may also be disclosed in response to legal requests, for harm prevention, and in accordance with applicable laws and internationally recognized standards.

6. Transfers of Data Outside the European Economic Area

Hancy AI, operated by Fepar A.S., is headquartered in Turkey, and our servers are located in Germany. In the course of providing our services, there may be occasions where your personal data is transferred outside the European Economic Area (EEA).

We ensure that such transfers are conducted in compliance with applicable privacy laws and are safeguarded by appropriate measures. These measures include the use of standard contractual clauses approved by the European Commission, ensuring that the data protection standards upheld in these transfers are equivalent to those required within the EEA.

Our commitment is to maintain the security and confidentiality of your personal data, irrespective of where it is processed. This adherence to data protection standards is consistent across all our data processing activities, regardless of geographical location.

If you have any inquiries or need further information about the safeguards we employ for data transfers outside the EEA, please feel free to contact us at customer@hancy.ai.

7. Your Rights Under GDPR

As a user of Hancy AI, you are afforded certain rights under the General Data Protection Regulation (GDPR). We are committed to ensuring that you can exercise these rights easily and transparently. Below are the key rights you have regarding the processing of your personal data:

Right to Access: You have the right to request access to your personal data that we hold, and to obtain information about how we process it.
Right to Rectification: If you believe that any personal data we are holding about you is incorrect or incomplete, you have the right to request that we correct or complete it.
Right to Erasure (‘Right to be Forgotten’): You can request the deletion or removal of your personal data when there is no compelling reason for its continued processing.
Right to Restriction of Processing: You have the right to request the restriction of processing of your personal data, which means we can store it but not use or process it further.
Right to Data Portability: You have the right to obtain and reuse your personal data for your own purposes across different services, which includes transferring it to another data controller.
Right to Object: You have the right to object to the processing of your personal data based on legitimate interests, direct marketing (including profiling), and processing for scientific/historical research and statistics.
Rights Related to Automated Decision Making and Profiling: You have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to Withdraw Consent: Where the processing of your personal data is based on consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Right to Lodge a Complaint with a Supervisory Authority: If you feel that your rights have been infringed, you have the right to lodge a complaint with a data protection supervisory authority in the EU member state of your habitual residence, place of work, or place of the alleged infringement.

To exercise any of these rights, please contact us at customer@hancy.ai. We will respond to your request in accordance with GDPR requirements.

We may take some reasonable steps to verify your identity before responding to your request, such as asking you for information and making sure it matches the data available to us. If you submit a request to exercise a right as an authorized agent, we may ask you to provide proof of your authorization or we may contact the subject of the request for confirmation, in accordance with applicable privacy laws.

8. Children’s Privacy

Hancy AI is not designed for use by individuals under the age of 16. We are committed to protecting the privacy of children and do not knowingly collect personal data from anyone under 16 years of age.

If you believe that we have inadvertently collected personal data from a child under the age of 16, please contact us immediately at customer@hancy.ai. Upon confirmation, we will take appropriate measures to promptly remove such data from our records and deactivate any associated account.

It is important for parents and guardians to monitor their children's internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data through our app or any online services without their permission.

We take the privacy of children seriously and will continue to take steps to ensure compliance with applicable laws and regulations regarding the protection of children's data.

9. In-app Tracking Technologies

At Hancy AI, we utilize various tracking technologies to enhance user experience, improve app functionality, and provide personalized content and advertising.

Types of Tracking Technologies:

Technical Tracking Technologies: Essential for basic app functioning, such as session monitoring and facilitating online content use. Consent is not required for these technologies as they are necessary for the service.

Analytics Tracking Technologies: Used for app performance evaluation and user interaction analysis to improve our services. These collect aggregate data on user engagement and app usage patterns. Explicit consent is typically required, except in cases of aggregated statistical use.

Profiling Tracking Technologies: Analyze user behavior to create profiles for personalized services and targeted advertising. The use of these technologies is based on explicit user consent.

Specific Tracking Technologies Used in Hancy AI:

Firebase and Crashlytics (Google): For app functionality, performance monitoring, and backend interactions. More information can be found in Google's privacy policy: Google Privacy Policy.

Appsflyer: For measuring ad effectiveness and analytics. Their privacy policy is available at Appsflyer Privacy Policy.

Meta Audience Network: For advertising, allowing us to show personalized ads based on user preferences. This tool enables the delivery of targeted advertising content, enhancing the relevance of the ads you see. For detailed information on how Meta Audience Network processes personal data, please refer to the Meta Privacy Policy.

Your Rights and Tracking Technologies:

Your rights under data protection laws, such as access, rectification, or erasure, apply to data collected via these tracking technologies. For more information, refer to the "Your Rights Under GDPR" section of this policy.

If you have any questions or concerns about our use of tracking technologies, please contact us at customer@hancy.ai.

10. Additional Information for Users in California

If you are a resident of California, the California Consumer Privacy Act (CCPA) grants you certain rights regarding the use of your personal information. Hancy AI is committed to upholding these rights and providing California residents with the specific information required by state law.

Your Rights Under CCPA:

Right to Know: You have the right to request information about the categories of personal information we have collected about you, the sources of that information, the purposes for collecting the information, and the third parties with whom we share the information.

Right to Access: You have the right to access the specific pieces of personal information we have collected about you.

Right to Deletion: You can request the deletion of your personal information that we have collected, subject to certain exceptions.

Right to Opt-Out of Sale: While Hancy AI does not sell personal information in the traditional sense, you have the right to opt-out of the sale of your personal information under the CCPA's broad definition of "sale."

Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

Exercising Your Rights:

If you wish to exercise any of these rights, please contact us at [insert your dedicated contact email or method for CCPA requests]. We will verify your request using the information associated with your account, including email address. Government identification may be required. We will respond to your request within the timeframe required by law.

Additional Privacy Information:

For more detailed information about how we collect, use, and share your personal information, and how to manage your information preferences, please refer to the other sections of this Privacy Policy.

11. Additional Information for Users in Illinois

For users residing in Illinois, we provide the following additional information in line with Illinois state law regarding our collection and use of facial data. This is in reference to the practices outlined in our "Types of Data, How Data is Used, and Retention" section.

Facial Data Collection and Use:

Purpose: We collect and process facial data exclusively to enhance your photos and generate AI avatars and AI images within Hancy AI.

Limitation: We do not use facial data to improve our photo-video editing and generative features, nor do we use it to train our photo-video editor algorithms.

Retention: The retention of facial data aligns with our general data retention practices, as detailed in the "What Data Do We Collect, How Data is Used, and Retention" section.

Storage and Sharing:

Storage: Facial data is stored securely using cloud storage providers.

Non-Disclosure: We are committed to not selling, leasing, or trading facial data to third parties.

Additional Considerations:

Biometric Data: In some jurisdictions, facial data may be considered biometric data. However, we do not use facial data for identification or authentication purposes.

User Rights: Users in Illinois have the right to access, delete, or control the use of their facial data. For exercising these rights, please refer to the section "Your Rights Under GDPR."

This section is intended to provide transparency about our practices concerning facial data in compliance with Illinois law and to assure users of our commitment to responsibly handling this sensitive data.

12. Changes to This Privacy Policy

Hancy AI reserves the right to update or modify this Privacy Policy at any time and for any reason. We understand the importance of privacy to our users, and we are committed to being transparent about changes in our data processing practices.

Notifying Changes:

Updates: Whenever we make changes to this policy that materially affect your rights or the way we process your personal data, we will notify you through prominent means, such as by displaying a notice within the app.

Review: We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal data we collect. Your continued use of the app after any changes or revisions to this Privacy Policy indicates your agreement with the terms of the revised policy.

Last Revision: The date of the last revision of the Privacy Policy will always be posted at the top of this document.

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at customer@hancy.ai.

13. Contact Us

If you have any questions, comments, or concerns about our Privacy Policy or data processing practices, or if you wish to exercise any of your rights as described in this policy, please feel free to contact us. We are committed to addressing your concerns and ensuring the protection of your personal data.

E-mail: customer@hancy.ai

Physical Address:

YESILKÖY SB MAH. C BLOK SK. C BLOK NO: 1 IÇ KAPI NO: 13

BAKIRKÖY /ISTANBUL - TURKEY

Data Protection Officer: Naq Cyber B.V.;

Contact: Nadia Kadhim

Address: Vlamingstraat 4, 2712BZ Zoetermeer, Netherlands

Email: privacy@naqcyber.com

Our Data Protection Officer is responsible for overseeing our data protection strategy and ensuring compliance with data protection regulations. You can contact the DPO directly if you have any concerns regarding your personal data's processing and protection.

We are always available to engage with you and address any privacy-related issues you may encounter. Your privacy and the security of your personal data are of utmost importance to us at Hancy AI.