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PRIVACY POLICY

Last Update: 6 June 2023

Thank you for being part of the Eywin Bilgi Teknolojileri Anonim Şirketi (“Grooz Cleaner”,

“application”, “we” or “our”) family. We care about protecting your privacy and we respect

your privacy. With this Policy, we aim to inform you about our practices regarding the

collection, use, or sharing of personal data that we collect from you or that you provide to us

if you use the Services offered by Grooz Cleaner.

If you have any questions about how we use your personal data or related information, please

contact us at info@eywin.com.tr.

If you do not accept this policy, you should not use Grooz Cleaner.

This policy will also be applied to the Services offered under Grooz Cleaner and the data collected

in all sales, marketing, and events related to these Services.

1. INTRODUCTION

Grooz Cleaner is an application used to remove unnecessary or junk files from users' device.

Grooz Cleaner uses and stores the necessary information for the application to work properly and to

meet your needs.

At Grooz Cleaner, we work to give you the best possible experience and we care about your

privacy.

If you visit our website our mobile application, we recommend that you read this Privacy

Policy carefully to make it easier for you to understand what data we collect, how we use it,

and to give you more control over your data.

Grooz Cleaner can work with different platforms to perform its functions related to the Services.

The platforms we work with may have different policies from ours on how data is collected,

used, and shared.

In order to get detailed information about the data processing policies of these platforms, we

present the list of these platforms we work with below. You can learn about all data

collection, sharing, and use options of these platforms and review their privacy policies

through the relevant list.

○Google Firebase

Privacy Policy: https://policies.google.com/privacy?hl=tr

○Adapty

Privacy Policy: https://adapty.io/privacy

○Adjust

Privacy Policy: https://www.adjust.com/terms/privacy-policy/

○Amplitude

Privacy Policy: https://amplitude.com/privacy

2. WHAT TYPE OF DATA DO WE COLLECT?

We collect and process various information during your use of Grooz Cleaner. The information

collected and used by us is as follows:

Data Provided by You

The information we collect depends on; the context of your interactions with us and the

Services, the choices you make, and the products and features you use.

● Payment Information:

Grooz Cleaner will be able to offer you paid content. If you make a purchase through the app or on

our website, we may collect data necessary to process your payment; such as your payment

instrument number, your credit card number, and the security code associated with your

payment instrument. All payment data is stored by App Store In-App Purchases and Google

Play In-App Billing. You can find the Privacy Policy links of the relevant services here:

○ App Store In-App Purchases

Privacy Policy: https://www.apple.com/legal/privacy/en-ww/

○ Google Play In-App Billing

Privacy Policy: https://policies.google.com/privacy?hl=en-US

● Application Data:

We may collect the following information during the use of the application if you access or

give your permission. You can always disable this access in your device's settings. However,

please note that if you do not allow the stated accesses, the Grooz Cleaner may not work properly.

Due to our sensitivity to data privacy, we access such data only to the extent we need it and in

accordance with the relevant legislation.

Mobile Device Access and Device ID: We may use or collect related information if you

allow access to certain features from your mobile device during the use of Grooz Cleaner, including

your mobile device's camera, media and device ID. If you want to change application access

and permissions, you can do so in your device's settings. Grooz Cleaner detects identical or similar

photos, videos or files on your device. It also gives you the option to take action by

identifying unused, unnecessary and unopened files for a long time on your device.

The main features that Grooz Cleaner uses information and access to are as follows:

- Detect Duplicate Media

- Detect Duplicate Files

- Detect Similar Photos

- Detect and Zip Big Videos

- Detect and Zip Big Files

- Detect Unused Files

Automatically Collected Data: Some information about you is collected automatically when

you download Grooz Cleaner to your device, use the application or visit our website. Your choices

regarding the application content, the actions you will take through the notifications sent to

you, the delivery times and transcripts of the mail or contact forms you will send to us, the

identity information and features of your devices, your IP address, browser features,

operating system, language preferences, referring URLs, device name, country Information

such as location, device and usage information about when you use the application can be

automatically collected by us.

Information Collected Through Cookies: Cookies; are small files that save information to

your computer, television, mobile phone, and other devices via browsers. Thanks to these

cookies, different websites of institutions that installed cookies on your device; recognize you

in services, devices, and browsing sessions. Technologies associated with your other devices,

such as internet storage and identifier, may be used for similar purposes. We use cookies for

purposes such as; protecting your data and your account, identifying popular features,

counting visits to a page, improving the user experience, ensuring the security of servers and

services, making our website useful, and adjusting our website to the user's interests and

needs, and making online advertisements to users. Cookies remember information about you

to perform these functions and in this way help us to provide these services to you. In this

context, your information is collected and processed with cookies. These cookies include:

○ Daily Data and Usage Data

○ Device Data

○ Location Data

○ Exercise Data

This includes the information collected about your movements through intermediaries such as

Google Analytics and Amplitude.

In addition, we inform you that if you go to other websites, applications, or platforms through

a link in Grooz Cleaner, you will be subject to the privacy policies and terms of use of the platform

you access.

3. HOW DO WE USE YOUR PERSONAL DATA?

Information collected in line with the above are used to provide, develop and manage our

products and services; to inform you about changes in our products and services; to provide a

personalized platform for you; to facilitate account creation and authentication; to manage

user accounts; to request feedback; to provide personalized service in line with your interests

and requests; to respond to your requests; to ensure the system security, to prevent illegal

issues or content and to take measures against them; to control compliance with the our

Terms of Use and our other policies; to ensure the development of personalized or

recommended content; to provide communication with other users; to ensure that the service

is performed in the most effective way; to analyze the service or content that you are

interested in; to perform activities such as making advertisements to you in line with your

interests and preferences.

4. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Your information are shared with the third parties listed below:

Our Business Partners: We may share some of your information with our business partners

in order to provide you services within the scope of the application. We are working with

these partners in order to make the products ready for use and improve the service that is

provided (For example; Users who want to register through accounts in social networks must

provide their usernames and information about their public profiles, or allow the social

network to provide this information. Also, in case of in-app purchases, your data will be

shared with our payment provider partners.)

Service Providers: In order to provide the service presented by Grooz Cleaner properly and

securely, technical or necessary support is received from various service providers. In order

to fulfill the stated purposes, information and content are provided to service providers such

as advertising and marketing, security, infrastructure, cloud service providers. Your personal

data is shared with these service providers for the purpose of providing the services that

concern them. Except for these works, no authorization is made for the use or disclosure of

your data.

Analytics and Advertising Service Providers: Grooz Cleaner works with analytics providers for

the best service. Personalized application and advertising experience are provided by

analytics service providers. In addition, data is shared with advertising service providers in

order to determine the type and number of advertisements displayed by users. Accordingly,

advertisements that may be of interest to you and a personalized platform are presented to

you.

Legal Authorities: Your personal data can be shared with legal authorities if requested by

them within the framework of the law.

5. THIRD PARTY SITES AND SERVICES

Services offered by Grooz Cleaner; may connect to or integrate with other websites and services

operated by third parties, including social media platforms, advertising services, and other

websites and applications. These links and integrations do not mean that we are affiliated

with any third party. We do not control any third party websites, apps or services and are not

responsible for their actions. Third-party websites and services follow different rules

regarding the collection, use, and sharing of your personal information. We recommend that

you read their privacy policy to learn more about this.

6. IS YOUR INFORMATION TRANSFERRED ABROAD?

Grooz Cleaner can transfer and store your data to third parties residing abroad by taking the

necessary security measures in line with the legal personal data processing purposes. Personal

data is transferred to foreign countries declared to have adequate protection by the Turkish

Personal Data Protection Authority (In accordance with Articles 8 and 9 of the Personal Data

Protection Law and GDPR). In addition, in the absence of sufficient protection, it is

transferred to foreign countries where the data controllers in the relevant foreign country

undertake an adequate protection in writing and where the permission of the Turkish Personal

Data Protection Authority is available.

7. STORAGE OF YOUR PERSONAL DATA

We store the personal data that belongs to you and we collect on secure servers located at

home or abroad. We take certain measures (encrypted transfer, etc.) at the point of

transferring your information to these servers. However, due to the fact that the internet

environment is not completely secure; despite all the precautions taken, the security of the

transmitted information cannot be guaranteed. Thus, we inform you that there are risks during

the transfer. Necessary administrative and technical measures are taken regarding the

information held by us, and security is increased with updates in reasonable periods. We take

measures that are consistent with relevant privacy and data security legislation to protect your

data. We also make agreements with our service providers to protect the privacy and security

of your Personal Data. Depending on the state of the technology, implementation costs and

the content of the data to be protected; we implement technical and organizational measures

to prevent risks such as destruction, loss, alteration, unauthorized disclosure or unauthorized

access to your data.

Your personal data is stored as long as you receive service through Grooz Cleaner or use the

application. We retain your data for as long as necessary to fulfill the purposes for which

your data was collected. Please note that in some cases a longer storage period may be

required or permitted by law.

Among the criteria we use to determine storage periods are the following:

● Periods accepted as per the general custom in the sector in which we operate,

●The duration of the legal relationship we have established with you,

●The period in which the legitimate interests of our company will be valid in

accordance with the law and the rule of good faith,

●The statute of limitations for asserting a right,

●The period when we have to keep your personal data in accordance with our legal

obligations

When we do not have an ongoing legitimate service to process your personal information, we

delete or anonymize such information from our system. However, if it is not possible (for

example, if your personal information is stored in backup archives), we will securely store

your personal information and stop processing it until it is possible to delete it.

8. CHANGES TO OUR PRIVACY POLICY

We can change the provisions of this Privacy Policy at any time, and the current text becomes

effective on the date it is published in the application or on the site. Updated Policy will be

published with the last date of the change being written into the text. Changes will be notified

to you via application notification or e-mail. Use of Grooz Cleaner after notification of changes will

constitute your acceptance and consent of the changes.

9. HOW CAN YOU MANAGE OR DELETE YOUR PERSONAL DATA? WHAT

ARE YOUR RIGHTS?

You are responsible for the accuracy of the information that you share with us while signing

up for Grooz Cleaner. The records and data that are kept on your behalf in the application consist of

data that is provided by you or collected automatically. It is possible to update the

information you have provided during registration via the application. We remind you that it

is your responsibility to ensure that the personal data that you provide to us is accurate,

complete and up-to-date. In addition, if you share Personal Data with us from other persons

(for example, your dependents), it is your responsibility to collect this data in accordance

with applicable local legislation. For example, you must inform others to whom you have

provided personal data about the content of this notice and, if required by law, obtain their

consent for the use of their personal data as set forth in this notice.

Based on the applicable laws of your country, you may have the right to request access to,

change or, in some cases, delete your personal information. You can contact us at

info@eywin.com.tr to request the review, update or deletion of your personal information.

10. WHAT   HAPPENS   TO   YOUR   INFORMATION   IF   YOU   WANT   TO

PERMANENTLY DELETE YOUR PROFILE?

If the account created by you in Grooz Cleaner is deleted, your personal data is permanently deleted

in a way that cannot be obtained retrospectively.

11. ABOUT CHILDREN

Grooz Cleaner does not knowingly collect information about children under the age of 16, does not

transfer to other organizations, and does not engage in activities that require parental

notification or consent. If you believe that Grooz Cleaner is unintentionally processing the

information of a person under the age of 16, please contact us at info@eywin.com.tr.

12. PLEASE CONTACT US FOR YOUR RIGHTS

You have the following rights in accordance with the applicable law:

●Learning whether your personal data is processed or not,

●If your personal data has been processed, requesting information about it,

●To learn the purpose of processing your personal data and whether they are used in

accordance with the purpose of processing,

●Receiving information about third parties to whom your personal data is transferred,

at home or abroad,

●Requesting correction of personal data in case of incomplete or incorrect processing

and request to notify this situation to third parties that your personal data has been

transferred,

●Requesting the deletion or destruction of your personal data if the necessary

conditions are met and request to notify this situation to third parties that your

personal data has been transferred,

●Objecting to the result against you due to the analysis of your data through automatic

systems,

●Requesting compensation of your damage in case you suffer damage due to

unlawful processing of your personal data.

In order to exercise your above-mentioned rights or if you have questions or requests about

your personal data, please send an e-mail to info@eywin.com.tr.

Depending on the nature of the request, it will be concluded free of charge as soon as possible

and within thirty days at the latest. However, if the period requires an extra cost, the fee

determined in accordance with the legislation may be charged by you.

Eywin Bilgi Teknolojileri Anonim Şirketi