Privacy Policy

PLAYA TEKNOLOJİ LİMİTED ŞİRKETİ, a company registered under the laws of Turkey, having its registered office at İdealtepe Mah. Dik Sk. No: 13 İÇ Kapi No: 2 Maltepe, 34841, Istanbul, Turkey will be the controller of your personal data.

We collect data you give us voluntarily (for example, your email address). We also collect data automatically (for example, cookies and technical information about your device) or from third parties (for example, advertisers).

Data we receive directly from you

Identifiers

You may provide us with your name and email address when you create an account with the Service, make a purchase, or contact us by any other means.

Account Data

This includes your login information (email and password) and user ID.

Quiz Data

When you complete our quiz on the Service, we collect your responses to questions about your demographics, psychological traits, behaviors and preferences, or other personal information ("Quiz Data") which is used to tailor Services to your requirements. This includes, but is not limited to, information about:

• Your general demographic information (age and gender)
• Your psychological traits (such as satisfaction with life, activity levels, decision-making patterns, stress handling, and risk tolerance)
• Your perspectives on challenges (such as how you handle changes, what causes frustration, and preferences for managing difficult situations)
• Other similar lifestyle information you provide when using Service

User Inputs and AI System Outputs

When you interact with our AI-powered Service, we collect information about your interactions with the Service ("User Inputs") and the resulting responses generated by the Service ("AI System Outputs"). User Inputs include:

• All prompts (including in the form of text, video or audio), instructions, questions, or other inputs you provide to the Service
• Information about decisions you have made or are considering
• Records of your conversations with the AI system, including frequency and duration of interactions
• Preferences you express during these interactions
• Feedback you provide about the AI system's responses, and
• Any additional information you voluntarily disclose during these interactions that may reveal your opinions, interests, or personal circumstances

Purchase Data

When you make payments through the Service, you need to provide your billing data, such as your credit card number, to our payment service providers. We do not collect, store, or have access to full credit card number data, though we may receive some limited information, including credit card-related data (including a secure token reflecting your payment method), data about products or services purchased, date, time and amount of the purchase, the type of payment method used, limited digits of your card number.

Feedback / Communications

We may also process your email and other information provided by you to us through customer support and other communications.

Data provided by third parties

When you use Sign in with Apple to register an account in the Service, 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 Apple screen. Find more about Sign in with Apple here: https://support.apple.com/en-ng/HT208650

When you decide to log in using Google, we receive personal data from your Google Account: name, email address, profile picture associated with your Google Account. You can revoke access provided to us on the Apps Permissions page: https://myaccount.google.com/permissions. To know more about how Google processes your data, visit its Privacy Policy: https://policies.google.com/privacy

Data we collect automatically

Data about how you found us

We collect data about your referring Website (place on the web where you were when you tapped/clicked on our ad).

Device and Location data

We collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, device identifiers, hardware ID.

Usage data

We record how you interact with our Service. For example, we log what pages you have viewed, the features and content you interact with, how often you use the Service, how long you are on the Service, your purchases.

Advertising IDs

We collect your Apple Identifier for Advertising ("IDFA"), Identifier for Vendor ("IDFV") or Google Advertising ID ("AAID") (depending on the operating system of your device) when you access our App or Website from a mobile device. You can typically reset these numbers through the settings of your device's operating system (but we do not control this).

Transaction data

When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.

Cookies

Some of the information we and our third-party partners collect automatically is captured using cookies, which are text files containing small amounts of information that are downloaded to your device or related technologies, such as web beacons, local shared objects, and tracking pixels, to collect and/or store information. To learn more, please refer to our Cookie Policy.

We process your personal data:

To provide our Service

We process your personal data for Service provision, namely to provide access to learning courses and AI system for self-improvement. This enables personalized interactions and tailored guidance based on your conversation inputs. We do not use your data to train our underlying AI models.

Enabling interactions and guidance

We process your conversations with the Service AI system along with your patterns, behaviors, values, and preferences to provide a personalized experience. This enables us to offer tailored insights, recommendations, and decision support that help you understand your strengths and areas for growth, make more informed decisions aligned with your values, and develop deeper self-awareness through recognizing your behavioral and thought patterns. Please note that information you share during interactions with AI may be reproduced in future AI System Outputs generated by the Service.

To enable the core AI functionality of our Service, we use OpenAI and Google. ChatGPT (provided by OpenAI) and Gemini models (provided by Google) power the conversations and interactions with our AI system, allowing us to generate human-like responses, process natural language, and create personalized experiences based on your inputs. These technologies enable us to analyze text, understand context, and generate appropriate responses. For more information about how OpenAI handles data, you can review OpenAI's Privacy Policy: https://openai.com/privacy/. For more information about how Google handles data, you can review Google's Privacy Policy: https://support.google.com/gemini/answer/13594961. While your interactions are processed using OpenAI's or Google's technology, we implement measures to ensure your personal data is protected according to our privacy standards. OpenAI or Google does not train its AI models on your personal data.

We use Qdrant to manage and process the data needed for our artificial intelligence features, such as semantic search and recommendations. For details on their data handling, please review the Privacy Policy: https://qdrant.tech/legal/privacy-policy/

We use LiveKit to power our AI-based live audio and/or interactive communication features. Please see more details on processing in the Privacy Policy: https://livekit.io/legal/privacy-policy

Technical functionality

We use your data to create your account, ensure seamless operation of the Service, prevent technical issues, and store your conversations.

To host personal data and enable this Service to operate and be distributed we use Amazon Web Services (AWS), which is a hosting and backend service provided by Amazon. For information about Amazon Web Services data practices, you can review their Privacy Policy: https://aws.amazon.com/privacy/

We use Temporal to ensure the reliable and resilient execution of critical, multi-step business processes (e.g., payment processing, user onboarding). Please see their Privacy Policy: https://temporal.io/global-privacy-policy

We use an identity provider for user authentication and authorization. It processes essential identity data to manage user access and enable Single Sign-On (SSO) across our Website and App.

Our Service uses MongoDB as a database to store and manage a wide range of operational data. Please see more details on processing in the Privacy Policy: https://www.mongodb.com/legal/privacy

To improve our Service

We process your personal data for Service improvement, namely to conduct system analytics, monitor performance, and enhance features.

System analytics and monitoring

We collect and analyze technical performance metrics and error logs to identify and fix issues, optimize system performance, and ensure reliability.

Feature development and quality assurance

We analyze anonymized and aggregated usage statistics to understand which features are most valuable and identify areas for improvement. This helps us develop new functionalities without processing your personal content.

To provide you with customer support

We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms of Use or this Privacy Policy.

To communicate with you regarding your use of our Service

We communicate with you, for example, by push notifications or by emails. These may include reminders or other information about the Service. As a result, you will, for example, receive a push notification that a new feature has been deployed in the Service. To opt out of receiving push notifications, you need to change the settings on your device. To opt-out of receiving emails, you should click the unsubscribe link in the footer of each email.

The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service's users, as well as when they interacted with it, such as by tapping/clicking on links included in the message.

To research and analyze your use of the Service

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.

To research and analyze usage patterns across our Service, we use Tableau. For more information about Tableau's data practices, you can review Tableau's Privacy Policy: https://www.tableau.com/privacy. The insights gained through Tableau help us continue evolving our Service to better meet your needs.

We use Amplitude, which is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone, tablet or laptop), unique identifiers (including advertising identifiers). Amplitude also allows us to track various interactions that occur on our Website. As a result, Amplitude helps us to decide what features we should focus on. Amplitude provides more information on how they process data in its Privacy Policy: https://amplitude.com/privacy

To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy Policy: https://www.appsflyer.com/legal/processing-customer-data/. Appsflyer allows you to opt out of having data from your device sent to Appsflyer's servers for app usage collection.

We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people visit our Website, how often users make purchases and other interactions. Learn more about Facebook's approach to data from its Privacy Policy: https://www.facebook.com/privacy/policy/

We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google's use of data, consult Google's partner policy. Firebase Privacy information: https://firebase.google.com/support/privacy/

To send you marketing communications

We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Service. We may show you advertisements on our Service, and send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.

To personalize our ads

We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our Website or installed the App, you might see ads of our products in your Facebook feed.

How to opt out or influence personalized advertising:

• iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads.
• Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here: http://www.networkadvertising.org/mobile-choice
• macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads.
• Windows: On your laptop running Windows 10, select Start > Settings > Privacy and then turn off the setting for "Let apps use advertising ID to make ads more interesting to you based on your app activity". If you have another Windows version, please follow the steps here: https://account.microsoft.com/privacy/ad-settings/signedout

In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

• Network Advertising Initiative — http://optout.networkadvertising.org/
• Digital Advertising Alliance — http://optout.aboutads.info/
• Digital Advertising Alliance (Canada) — http://youradchoices.ca/choices
• Digital Advertising Alliance (EU) — http://www.youronlinechoices.com/
• DAA AppChoices page — http://www.aboutads.info/appchoices/

Browsers: It is also possible to stop your browser from accepting cookies altogether by changing your browser's cookie settings. You can usually find these settings in the "options" or "preferences" menu of your browser. The following links may be helpful:

• Cookie settings in Internet Explorer: http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
• Cookie settings in Firefox: http://support.mozilla.com/en-US/kb/Cookies
• Cookie settings in Chrome: https://support.google.com/chrome/answer/95647
• Cookie settings in Safari (web): https://support.apple.com/kb/PH17191 and iOS: http://support.apple.com/kb/HT1677

Google allows its users to opt out of Google's personalized ads: https://adssettings.google.com/authenticated and to prevent their data from being used by Google Analytics: https://tools.google.com/dlpage/gaoptout/

We use Facebook pixel on the Service. Facebook pixel is a code placed on the Service collecting data that helps us track conversions from Facebook ads, build targeted audiences and remarket to people who have taken some action on the Service (for example, made a purchase).

Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here: https://www.facebook.com/help/146952742043748 or adjust your ads settings on Facebook: https://www.facebook.com/ads/preferences/

To process your payments

We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made.

We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.

To enable purchases and to process your payments, we use Solidgate (Privacy Policy: https://solidgate.com/privacy-policy/) as our payment processing provider.

To enforce our Terms and to prevent and combat fraud

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms of Use).

To comply with legal obligations

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA or Turkey-based users.

We process your personal data under the following legal bases:

Your consent

Under this legal basis we will also send you marketing communications. You have the right to withdraw your consent any time by using the unsubscribe link in the footer of our emails or in your personal account or by contacting support@loku.info. We will also send you push notifications if you allow us to. You can disable notifications any time in the settings of your device.

To perform our contract with you

Under this legal basis we:

• Provide our Service (in accordance with our Terms of Use)
• Customize your experience
• Provide you with customer support
• Communicate with you regarding your use of our Service
• Process your payments

For our (or others') legitimate interests

Unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data, we rely on legitimate interests:

• To communicate with you regarding your use of our Service (our interest to encourage you to use our Service more often)
• To research and analyze your use of the Service (our interest in improving our Service)
• To personalize our ads (our interest to promote our Service in a reasonably targeted way)
• To enforce our Terms of Use and to prevent and combat fraud (enforcing our legal rights, preventing fraud)
• To comply with legal obligations

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

• AI model and services providers (OpenAI, Google, Qdrant, LiveKit)
• Cloud storage providers (Amazon Web Services (AWS), MongoDB)
• Data analytics providers (Appsflyer, Amplitude, Tableau, Facebook, Firebase)
• Measurement partners (Facebook pixel)
• Infrastructure service providers (Temporal)
• Marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google)
• Payment service providers (Solidgate)

Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers' information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Affiliates

We may share your personal information with our partner organizations that are part of our corporate group — these are companies that are owned by, own, or are jointly owned with us. These partner organizations will use the information in ways that align with this Privacy Policy.

To be in control of your personal data, you have the following rights:

• Accessing / reviewing / updating (rectifying) / correcting your personal data
• Deleting your personal data
• Right to request controllers to inform third parties (Turkey)
• Objecting to or restricting the use of your personal data
• Right to claim compensation (Turkey)

Additional information for EEA or Turkey-based users

• The right to lodge a complaint with a supervisory authority
• If you reside in Turkey, you can lodge a complaint with Kişisel Verileri Koruma Kurumu: https://kvkk.gov.tr/
• The right to data portability

To exercise any of your privacy rights, please send a request to support@loku.info.

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms of Use, and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

If we transfer personal data originating from the EEA to countries that do not provide an adequate level of data protection, we use Standard Contractual Clauses approved by the European Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en

If we transfer data from Turkey to other countries that do not provide an adequate level of data protection, we use the Standard Contract: https://www.kvkk.gov.tr/Icerik/7938/

9.1 Applicability

If you reside in a state that has enacted consumer privacy laws, this section applies to you. This applies to states such as California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia.

9.2 Categories of Personal Information We Collect and For What Purposes

9.3 What Personal Information We Share

Certain state privacy laws require us to disclose the categories of Personal Information shared with third parties for business purposes. We share the categories listed above with service providers, analytics partners, payment processors, and as otherwise described in Section 5 of this Privacy Policy.

9.4 Your Privacy Rights Under State Laws

Depending on your state of residence, you may have the following rights:

• Right to Know — the categories and specific pieces of personal information we collect about you
• Right to Access — a portable copy of your personal information
• Right to Delete — request deletion of your personal information
• Right to Correct — request correction of inaccurate personal information
• Right to Opt-Out — opt out of the sale or sharing of personal information
• Right to Data Portability — receive your data in a portable format
• Right to Non-Discrimination — we will not discriminate against you for exercising your privacy rights
• Right to Withdraw Consent — withdraw consent where processing is based on consent
• Right to Limit Use of Sensitive Personal Information — limit use of sensitive personal information to permitted purposes

To exercise any of these rights, please contact us at support@loku.info.

9.5 Sales, Sharing, and Targeted Advertising

We do not sell Personal Information for monetary compensation. However, our use of certain tracking technologies (such as advertising pixels and cookies) may be considered "sale" or "sharing" under some state privacy laws.

To opt out, please contact us at support@loku.info or click the "unsubscribe" button in any marketing communication.

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy.

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy.

• Account Information: Retained while the account is active; deleted within 30 days of account deletion.
• AI System Conversations Data: Retained while the account is active; deleted within 30 days of account deletion.
• Usage Data: Anonymized/aggregated data may be retained for analytics purposes.
• Backup Data: Retained for a limited period for disaster recovery purposes.

Except as otherwise stipulated in this Privacy Policy, this Service does not support "Do Not Track" requests.

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at: