Novelty Privacy Policy

Effective Date: Nov 16, 2024

PLEASE READ THESE TERMS OF SERVICE CAREFULLY.

Welcome to Novelty! VLMedia Yazilim Bilisim Tanitim Danismanlik İc ve Dis Tic. A.S. (“Novelty”, "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard ("process") your information when you use our mobile application and website, Novelty ("Services"). If you do not agree with our policies and practices, please do not use our Services. If you have any questions or concerns about our privacy practices, please contact us at [email protected].

Table of Contents

1. Information We Collect

2. Use of Information

3. Sharing of Information

4. Lawful Basis for Processing

5. Your Rights

6. Data Retention

7. Children's Privacy

8. Security Measures

9. International Data Transfers

10. Changes to This Privacy Policy

11. Contact Us

1. Information We Collect

We collect personal information that you voluntarily provide to us when you register on the Services, when you participate in activities on the Services, or otherwise when you contact us. Please note that if you use our Services in Guest Mode, we will collect usage data and automatically collected data, but personal information (such as your name and email address) will not be collected until you decide to sign up for an account.

• Personal Information: When you register for an account, we may collect your name, email address and gender.

• Technical Data: Information such as IP address, device type, operating system, usage data (e.g., viewing history), and unique device identifiers may be collected automatically.

• Usage Data: We collect information about your activity on our Services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, search preferences, clicks, and pages which have been shown to you, referring web page address) and how you interact with content.

1.1 Personal Information

We collect information that you voluntarily provide to us when you register for an account, use certain features of our app, or communicate with us. This includes:

• Name: For identification purposes and to personalize your experience.

• Email Address: To communicate with you, send you updates, and respond to inquiries.

• Gender: To personalize your content. It is not required, if you decide to share your gender we can personalize recommended stories. We do not use your gender for profiling or anything else and we do not share gender data with any other third parties.

• Date of Birth: To ensure compliance with age-related regulations and provide age-appropriate content.

• Customer Desk Correspondence: To provide customer support and resolve user issues.

Guest Mode: If you use Novelty in Guest Mode, your name, email, gender or other personally identifiable information will not be collected until you register for an account. However, we still collect technical and usage data as outlined in this privacy policy.

1.2 Usage Information

We may also collect the following information if you choose to provide us with access or permission:

• App Usage Patterns: Information on the features you use, your activity within the app, and your preferences to improve user experience.

• Device Information: Details about the device you use to access Novelty, such as IP address, operating system, browser type, time zone, and language settings.

• Device ID: A unique identifier associated with your device, used for tracking, analyzing and improving app functionality and marketing efforts.

• User ID: A unique identifier assigned to you when you use our services, used to track your interactions within the app.

• Advertising IDs: We may collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device) with your consent. You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

Guest Mode: When using the app in Guest Mode, we still collect your Device ID and usage data to enhance app performance and for analytical purposes and provide you with a User ID.

1.3 Automatically Collected Information

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal specifically your identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Information: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files.

This log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

• Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information

• Location Data: We collect and process information about your device's location, which can be either precise or approximate. The amount of location data we collect depends on your device type and settings. For instance, we may use GPS and other technologies to determine your current location based on your IP address.

You can opt out of location data collection by refusing access or disabling the Location setting on your device. Please note that opting out may limit your ability to use certain features of our Services.

We use location data to:

• Provide localized content and recommendations.

• Enhance security and prevent fraudulent activities.

• Improve our services based on geographical usage trends.

• Determine the legal requirements that we should abide by

1.4 Data From Third Parties

We may receive information about you from third-party sources. This includes:

• Social Media Accounts: If you log in through a social media account, we may receive information from that account. For example, Apple ID account, when you sign in with Apple to register an account in the App, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the sign in with the Apple screen.

• Third-Party Services: Information from services like Google Analytics, Firebase, or payment processors like Apple.

2. Use of Information

We use the information we collect for various purposes, which may be seen below:

• Provide and Manage Services: Ensuring the app functions correctly and efficiently.

  • Legal Basis: Performance of a contract

• Improve Our App: Analyzing usage data to develop new features, enhance existing ones, and improve overall app performance. We use data analytics tools such as Google Analytics and Adjust to understand user interactions and optimize the app accordingly.

  • Legal Basis: Legitimate interests

• Communicate with You: Sending updates, responding to inquiries, providing customer support, and delivering important notices. This includes communicating with you via email about updates, changes, and promotional offers.

  • Legal Basis: Performance of a contract, Legitimate interests

• Ensure Legal Compliance: Meeting legal and regulatory requirements and data protection obligations.

  • Legal Basis: Legal obligation

• Marketing Communications: Sending you promotional materials, updates, and special offers. With your consent, we may use your email address to send you marketing communications about our services and partners. You can opt-out of these communications at any time.

  • Legal Basis: Consent

• Analyze Ad Performance: Using tools like Adjust to measure the performance of our ads, understand how users find our app, and improve our advertising strategies. This includes analyzing which ads are effective.

  • Legal Basis: Legitimate interests

• Enhance Security and Prevent Fraudulent Activities: Using device information, IP addresses, and location data to detect and prevent fraudulent activities, ensure the security of our services, and protect user data.

  • Legal Basis: Legitimate interests, Legal obligation

• Research and Development: Conducting research and analysis to understand user behavior, preferences, and trends. This helps us innovate and improve our services to better meet your needs. We use various analytics tools to gather insights and make data-driven decisions.

  • Legal Basis: Legitimate interests

3. Sharing of Information

We collaborate with external partners to execute specific services or business functions on our behalf. These partners utilize their own technologies and resources based on our guidelines. This arrangement often involves processing your data through their tools, such as software development kits (SDKs), APIs, and cookies. Consequently, your information is processed on their servers, generally without their direct access to detailed information, to meet our operational needs.

Such processing of personal data can be viewed as sharing information with third parties. To regulate this, we (Data Controller) enter into detailed data processing agreements with these partners (Data Processors), specifying the rules for handling your data strictly on our behalf. These agreements ensure your data is processed exclusively for our purposes.

Our partners assist us in various areas, including the operation, enhancement, integration, customization, support, and marketing of our services. The types of third parties we share information with include:

• Service Providers: We partner with third-party service providers to perform functions on our behalf, such as marketing platforms and data analysis. These providers have access to your information only to perform specific tasks and are obligated to protect it.

• Firebase: To monitor infrastructure and the App’s performance,services provided by Google.

• Adjust: An analytics and ad performance measurement tool, used to perform research and analysis about how users interact with our app. Adjust helps us understand how users find us, such as which advertiser delivered an ad that led to the app store. Adjust also provides us with various analytics tools to research and analyze your use of the service.

• Google Analytics: For data analysis and service improvement.

• Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

• Affiliates: We may share your personal information with our affiliated companies within our corporate group, including entities that we own, that own us, or that are under common ownership. These affiliated companies will use your information in accordance with this Privacy Policy, ensuring that your privacy is consistently respected and protected across all our related fitness and wellness services.

• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of the transaction. We will notify you via email and/or a prominent notice on our app before your information becomes subject to a different privacy policy.

4. Lawful Basis for Processing

We process your personal data based on one or more of the following lawful bases:

• Consent: Where you have given clear consent for us to process your personal data for specific purposes.

• Performance of a Contract: To provide the services you request, including creating an account and delivering app features.

• Legal Obligation: Where processing is necessary for compliance with a legal obligation (e.g., retaining data for tax purposes).

• Legitimate Interests: For our legitimate business interests, such as improving our services and ensuring security, provided these interests are not overridden by your rights and interests.

5. Your Rights

Depending on your state of residence in the US or in other regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, Canada,etc. you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than your consent.

‍Opting out of marketing and promotional communications: We will only send you marketing ad promotional communications conditional to your consent. In case you want to revoke such consent, you can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided. You will then be removed from the marketing lists. However, we may still communicate with you for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

‍Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at [email protected].

5.1 GDPR

Under GDPR, You have certain rights around the use of your data, including the ability to opt-out of promotional emails, cookies, and the collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. We want you to be in control of your information, so we have provided you with the following tools:

Access: You can request a copy of your personal data we hold.

Rectification: You can request corrections to any inaccurate or incomplete data.

Erasure: You can request the deletion of your personal data under certain conditions. You may also delete your account by using the corresponding functionality directly on the app.

Restriction of Processing: You can request the restriction of processing your personal data in certain situations.

Data Portability: You can request a copy of your data in a structured, commonly used, and machine-readable format.

Object to Processing: You can object to the processing of your data in certain circumstances.

Email marketing: we provide you with the ability to unsubscribe from email marketing communication by following the unsubscribe link in every email or by contacting our support team.

iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.

Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less personalized ads).

The right to lodge a complaint with supervisory authority: We would love you to contact us directly, so we could address your concerns as customer satisfaction is our top priority, thus we strive to appoint sufficient resources and efforts to provide you with top of the market customer support and most likely will be able to satisfy your request directly. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority.

Exercising your rights

To exercise these rights, please contact us at [email protected]. We will respond to your request within a reasonable timeframe.

Verification: To ensure that we properly handle the requests you make regarding your rights, we are required to verify those requests. Depending on the type of request and the product used by you, this may include your name, age, email, date of subscription purchase, date of last activity, date of account creation or some other Service use data that will reasonably identify you as an owner of the account, etc. We may also ask you for additional proof of identity, if necessary, but we strive to require as little as possible (for example, for some requests we will send you a verification code or link.) These proofs of identity are immediately deleted after the verification process is completed.

An authorized agent: You may also designate an authorized agent to exercise your rights on your behalf. If you have provided an authorized agent with a power of attorney, we will work directly with your authorized agent to complete your request. Where you have not provided an authorized agent with a proper power of attorney or similar authorization, we will reach out to you directly to confirm the authorized agent’s authority and collect the verification Information. The authorized agent shall verify the identity of both himself and the consumer.

5.2 United States

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. This Section shall apply to Users who are resident in those states. More information is provided below.

Categories of Personal Information We Collect

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

‍The categories of Personal Data collected by Novelty in the last 12 months are described in the Privacy Notice and, for the purposes of the CCPA, correspond to the following categories of Personal Information listed in the CCPA:

To deliver our services, we may share your personal information with entities that perform tasks on our behalf or support our objectives. These entities may be classified as service providers (or contractors) and third parties under the California Privacy Rights Act (CPRA), based on their roles and relationships with us.

To clarify which personal data is shared with these entities and for what purposes, we have included a table below. The table outlines the categories of service providers and third parties we collaborate with.

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‍‍Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "Sharing of Information"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information.

‍Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request the deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to non-discrimination for exercising your rights

• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)

• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon's privacy law)

• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law)

• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida's privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting or by referring to the contact details at the bottom of this document.

By emailing us at [email protected].

You can opt out from the selling of your personal information, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will Inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83. also known as the "Shine The Light" law. permits our users who are

California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the “Contact US” section.

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6. Data Retention

We 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 information to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you delete your account, all your data along with your account will be permanently deleted within 6 months. Additionally, if there is no activity on your account for 10 years, all associated data and your account will be deleted.

Please note that if you have an active subscription and you delete your account or the app, your subscription will continue until you cancel it directly.

7. Children's Privacy

Novelty is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children under 18. If we become aware that we have inadvertently collected such data, we will take steps to delete it as soon as possible. Parents or guardians who believe that their child has provided us with personal data without their consent should contact us immediately.

8. Security Measures

We take the security of your personal data very seriously and have implemented a range of technical and organizational measures to protect your information. These measures include:

8.1 Technical Measures:

• Encryption: All sensitive data is encrypted during transmission and at rest to ensure it is protected from unauthorized access.

• Access Controls: We use strict access controls, including authentication and authorization protocols, to ensure that only authorized personnel can access your data.

• Monitoring: Our systems are continuously monitored for potential vulnerabilities and breaches, allowing us to respond promptly to any security incidents.

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8.2 Organizational Measures:

• Training: Our staff undergoes regular training on data protection and security best practices to ensure they handle your data with the utmost care.

• Policies: We have established comprehensive internal policies that govern the handling and protection of personal data, ensuring compliance with relevant laws and regulations.

9. International Data Transfers

Your information, including personal data, may be transferred to and maintained on servers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new policy on this page and updating the effective date. We encourage you to review this policy periodically to stay informed about how we are protecting your information.

11. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at: [email protected]

VLMEDİA YAZILIM A.Ş.

Üniversiteler Mah. İhsan Doğramacı Bulv. Gümüş Blok

No:29 B K1-1 Odtü Teknokent Çankaya /ANKARA

Legal Notice

For European citizens or residents:

You can exercise your rights as a data subject (right to be informed; right of access; right to rectification; right to erasure; right to restriction; right of data portability; and the right to object) by contacting our European representative:

Naq Cyber B.V.;

Contact: Nadia Kadhim

Address: Vlamingstraat 4, 2712BZ Zoetermeer, Netherlands

Email: [email protected]

This representative may be contacted at any time for inquiries or complaints related to the processing of your data if you are a European national or resident. You may contact our representative to exercise your rights as described in this privacy policy.

When contacting our European representative, always mention our name and the nature of your request or inquiry in the subject of your email.