Pure Privacy Policy

PulpoLabs”, the "Company", “We”, and through similar words such as “us”, “our”, etc.) we respect your privacy and are committed to providing a personalized skin coaching experience through our application: “Pure.” (the “App”, “Platform”) by getting to know your skin characteristics, enabling you to trace your skin improvements, build lifestyle habits, and follow tailored routines to reach your lifestyle goals.

This Privacy Policy (the “Policy”) describes PulpoLab’s practices and policies with regard to the use and processing of personal information while operating the App and providing the services thereunder (the “Services”). This Policy describes the types of personal information we collect through the App, how we use that information, our legal basis for doing so, with whom we share it, your rights and choices in this regard, and how you can contact us about our privacy practices as well as your ability to control certain uses of such personal information. This Policy does not apply to third-party sites, products, or services, even if they link to our Services or the App, and you should consider the privacy practices and terms of conditions of those third parties carefully.

Capitalized words not defined under this Policy shall be understood as described under our Terms of Use (the “Terms”). It is of utmost importance to read the Policy provided herein in tandem with the Terms to better grasp the key concepts provided and explained therein. By accepting this Policy, you agree to the collection, use, and disclosure of your information as described in this Policy and agree to the Terms which are incorporated by reference. 

Please note that by accepting this Policy, you are familiarized yourself with this Policy, understood and are agreeing with the terms and practices described in this Policy (including new versions of this Privacy Policy when and as they come into effect), and the Terms, which governs this Policy and contains all disclaimers of warranties and limitation of liabilities. If you do not agree to this Policy, please do not further access or use the App and the Services.

1. DEFINITIONS

Within the scope of this Policy, following terms shall have the meanings ascribed to them below: 
The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Account: An account on the App, allowing the Users to access the contents of the App and use the Services following the account creation process.

App: Mobile application called “Pure.” developed and created by the Company to provide the Service(s).

Business: Business, for the purpose of the CCPA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

CCPA: The California Consumer Privacy Act of 2018, signed into law on June 28, 2018, by the State of California.

Company: PulpoLabs Bilişim Anonim Şirketi a company, incorporated and validly operating in the Republic of Turkey.

‍For the purposes of the GDPR, the Company is the Data Controller.

Consumer: For the purposes of the CCPA, a natural person who is a California resident, including (i) every individual who is in the USA for other than a temporary or transitory purpose, and (ii) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Data Controller: For the purposes of the GDPR, the Company as the legal person which determines the purposes and means of process of Personal Data solely.

Do Not Track (DNT): A concept that has been promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
‍
Data Subject: A natural person who can be identified or rendered identifiable through the personal data related to.
‍
Device: Any device that is suitable to access the Service such as a cellphone, or a digital tablet.

GDPR: The General Data Protection Regulation, signed into law on May 25, 2018, by the European Union

Personal Information / Personal Data: Any information/data that relates to an identified or identifiable individual.

‍For the purposes for GDPR, any information relating to you such as a name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.

‍For the purposes of the CCPA, any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
‍
Personal Data Breach: A breach of security whether accidental or on purpose results in accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

Sales of Data: For the purposes of the CCPA, selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable. consideration.
‍
Special Category of Personal Data: Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership and, genetic and biometric information, information. concerning Data Subject’s sex life or sexual orientation.

Service Provider: Any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered as Data Processors.

Third-party: Any other natural or legal person that is not part of PulpoLabs.

Third-Party Social Media Service: Any website/app or any social network website/app through which a User can share its reviews regarding the Service.
‍
Usage Data: Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
‍
User: A natural person who creates an Account on his/her own behalf, and who may access and use the Services on the App.

‍For the purposes of the GDPR, User can be referred to as the Data Subject.

‍For the purposes of the CCPA, User can be referred to as the Consumer.

Visitor: Any person who accesses the App and is not a User.

‍For the purposes of the GDPR, Visitor can be referred to as the Data Subject.

‍For the purposes of the CCPA, Visitor can be referred to as the Consumer.

‍
2. GENERAL

‍Since PulpoLabs is a Turkey-based company but has numerous Users from different countries; it is hard to determine which legislation should be applied to its activities and business. Therefore, PulpoLabs intends to reflect its compliance with different legislations about privacy and data protection in a global perspective. For this reason, PulpoLabs shows considerable effort to act in accordance with General Data Protection Regulation (“GDPR”), California Consumer Privacy Act (“CCPA”), Turkish Personal Data Protection Law (“PDPL”) and other applicable data protection regulations.
‍

3. DATA SUBJECTS

‍Since the App cannot be used without creating an account, the account holder (that is the User) is deemed as the Data Subject in terms of the data that PulpoLabs is processing. However, even though the Data Subject may be referred to as the User, This Policy also includes Visitors with various motives such as downloading the App and/or somehow accessing, accepting to receive e-commerce messages, making an application, complaint, or any request to PulpoLabs.  

3.1. App Visitors
‍If you download, access or visit our App, we may collect your personal information. For example, we collect Personal Data that you shared with us via membership form, or when you contact us by e-mail.
‍
3.2. App Users
‍Your access to and use of the App and the Services are contingent on signing up for an Account. There are two kinds of Users according to the process of their special category of personal data:

• Users that benefit the Services through uploading a photo or taking a selfie
• Users that benefit the Services through their description of skin characteristics and lifestyle habits
‍
PulpoLabs obtains personal information concerning you from you and certain sources to provide the Services and manage the App.
‍

4. HOW WE COLLECT INFORMATION

‍PulpoLabs obtains personal information concerning you from certain sources to provide the Services and to manage the App. We also obtain information from you and from Third Parties as detailed below. “You” may be a Visitor or User regarding our Services. 

Please note that if you decline to provide any of the required information requested by the Company, you may not be able to take full advantage of the Services and their features.

‍a) Website Visitors, Users and the Services
‍We collect information from and about you and your other interactions with us. This may include, but is not limited to, when you download our App, use the Services, register for an Account, sign up for our catalog, interact with online customer support, sign up for newsletters or email lists, participate in sweepstakes, engage in contests or other promotions, participate in a product review, survey, or other similar programs, send a gift or virtual gift card to a person, or otherwise contact us through any channels provided by the Company for such purpose. 

‍b) Third Party Analytics and Advertisements
‍We also may use Third Party advertisements, analytics, and tracking tools to better understand who is using the Website, how people are using the Website, how to improve the effectiveness of the Services and related content, and to help us or those Third Parties serve more targeted advertising to you across our media channels. These Third Parties may use technology such as cookies, pixel tags, log files, flash cookies, or other technologies to collect and store information. They may also combine information they collect from your interaction with the App with information they collect from other sources, which combination may be subject to the Third Party’s control and privacy policy thereupon.

Links to the privacy policy of third-party service providers used by the app:
Firebase Analytics
‍Facebook
‍Crashlytics
‍Amplitude
Fabric

‍c) Third Party Social Media Services
‍We collect and obtain personal information from social media platforms and networks that you use in connection with our App and Services, or that share or allow you to share information with us, such as Facebook, Twitter, Pinterest, or Instagram. For example, if you use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with our App (e.g., to share inspiration and other content with your friends and followers on social media), we will obtain the information that you share with us, or that those social media platforms or networks share with us. Third Party Social Media Services are prohibited from using personal information for any other purpose and are contractually required to comply with all applicable laws and requirements.For more information about social media platform and network privacy practices, please review the privacy policies and settings of such social media platforms and networks. 

‍d) Cookies and Automatic Collection Methods
‍We may also collect information about your online activities on the App and connected Devices over time and across Third-Party websites, Devices, apps, and other online features and services. This collection includes automatically collected information, and generally does not include personal information unless you provide it through our App, or you choose to share it with us by other means. For more information, please check our “Cookie Policy” section.
‍

5. TYPES OF DATA COLLECTED

a. Personal Data that We Collect from You
‍While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. The personal data we request varies in line with your usage of the App and Services.

Creating an Account: To be able to access our Services, you should create an account via one of your Google, Facebook, or Apple accounts or with your e-mail address. If you sign up with your e-mail, we asked you to provide the following personal information.

• First name and last name
• Email address
• Usage Data
• Password

‍Accessing the Service: After creating an Account, to benefit from the Service, Users are provided with two methods to describe their skin features each of which is specified below with the respected personal information processed:

Users may upload/take their selfies;

• Biometric data to be processed due to face-scanning for analyzing skin (for further information please see Section 5 (b).
• Gender (if specified)
• Age (if specified)
• Skin Type (whether your skin is dry, normal, oily, sensitive etc.)
• Stress Rate (if specified)
• Sleep Cycle (if specified)
• Hydration Cycle (if specified)
• Body Movement Cycle (if specified)

‍Users do not upload/take their selfies;

‍If you do not upload your selfie, we cannot assess your skin type, or the problematic area or trace the process automatically. Therefore, in order to benefit from the Service, analyze and track your skin process, you should add them manually. 

• Skin Analysis (whether your skin has acne, wrinkles, redness, eye bags, dark circles, etc.)
• Gender (if specified)
• Age (if specified)
• Skin Type (whether your skin is dry, normal, oily, sensitive etc.)
• Stress Rate (if specified)
• Sleep Cycle (if specified)
• Hydration Cycle (if specified)
• Body Movement Cycle (if specified)
• Communication and interactions: Other than accessing and using the Services, we collect your e-mail address, name, and any other information you choose to include in the body of your e-mail when you contact PulpoLabs by e-mail. 
‍
You may also opt-in to submitting information through other methods, including:

• By participating in an offer, program, or promotion
• Through our social media accounts or online forums
• In connection with a real or potential business relationship with us
• In response to your marketing or other e-mail communications
• By giving us your business card or contact information.

‍b. Special Category of Personal Data that We Collect from You

‍As PulpoLabs, we perform certain technologic data processing activities while providing our skin analysis technology to you. Required by our technology, we assess your skin type, or the problematic area or trace the process automatically through biometric means (i.e., face-scanning, creating facial geometry). Therefore, if you want to experience our Services by preferring to upload/take selfies, we will process your biometric data upon your explicit consent in this regard.

‍c. Information that We Collect Automatically on Our App and Services

Our App uses technologies to function effectively. These technologies record information about your usage of our App and Service, including;

Device Data, such as IP address, Device type, internet browser type, screen resolution, operating system’s name and version, Device manufacturer and model, language, plug-ins, add-ons, brand, model, technical specification and operating system information of the Device used, and the language version of the App you are accessing to/using of;

Log Data, in a case of an error in the app, we collect data and information (through third-party products) on your phone called “Log Dat”a. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the app configuration when utilizing our Service, the time and date of your use of the Service, and other statistics;

Usage Data, such as time spent on the App, pages visited, links clicked, language preferences, App usage time, communication preferences, approaches to in-app notifications/offers/campaigns, habits, likes, behaviors, routines, preferences, segments, and Device ID, and the pages that led or referred you to our App.

Face Data, of our users, is not shared with any third-party services. All the data of our users are held securely in our Google Cloud ve Amazon AWS servers located in the US.

While using our Service, in order to provide features of our App and Services, we may collect, with your prior permission, photos and other information from your Device's camera, photo library, and files.  We use this information to provide features of our Service, to improve and customize our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it be simply stored on your Device. For example, when you prefer using the Service through uploading/taking your selfie, we will ask you prior permission to access your Device photo library/camera. You can enable or disable access to this information at any time, through your Device settings. 

We also may collect information about your online activities on the App and connected Devices over time and across third-party sites, devices, apps, and other online features and services.
Please note that Google Play Store and Apple App Store have their own privacy policies and practices, which we encourage you to read prior to downloading the App from such platforms.
‍

6. HOW WE USE INFORMATION

a. Our Services

‍We use the information that we collect/obtain to conduct our business and to provide you with the best possible Services, and virtual skin coaching experiences. We rely upon several legal grounds to ensure that our use of the information we collect/obtain is compliant with the applicable laws. We use information to facilitate the business relationships we have with you, to comply with legal obligations, to pursue our legitimate business interests.

‍Pre-contractual, contractual, and post-contractual business relationships. We use personal information to enter business relationships with prospective Users and to perform the contractual obligations under the contacts that we have with our Users. Examples of how we use information within this condition include:

• To provide you with products and Services, such as to,
- Process, maintain, and service your account(s) and memberships,
• To respond or communicate with you such as when you;
- Make a request or inquiry through contact form or any other channel dedicated for such use,
- Ask a function through the channels provided you on the App,
- Share a comment/review or concern regarding a product or the Service,
- Ask for customer support through any channels dedicated fur such use.

‍Legal and regulatory compliance. We use Personal Data to verify the identity of our Users in order to comply with laws. These obligations are imposed on us by the operation of law, and industry standards, and may require us to report our compliance to third parties and to submit to third-party verification audits.Examples of how we use information within this condition include:

• Mitigating financial loss, claims, liabilities, or other harm to our Users, the Company, our employees, property; respond to court orders, lawsuits, subpoenas, and government requests; address legal and regulatory compliance.

‍Legitimate business interests. We rely on our legitimate business interests to process certain personal information concerning you. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals whose personal information we process. Examples of how we use information within this condition include:

• Mitigating financial loss, claims, liabilities, or other harm to Users and PulpoLabs;
• Protecting the security or integrity of our App and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorized users;
• Responding to inquiries, sending service notices, and providing customer support;
• Personalizing your experience with us, including to remember your interests and preferences (i.e., your language preference, suggesting tailored skin improvement tips and lifestyle habits), customize the Services we share with you; tracking and categorizing your activity and interests on our App,
• Promoting, analyzing, modifying, and improving our App, Service, systems, and tools, and developing new services;
• Managing, operating, and improving the performance of our App and the Services by understanding their effectiveness and optimizing our digital assets;
• Improving our App and Services, customer service, and user experience;
• Analyzing and advertising our Services;
• Conducting aggregate analysis and developing business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our business;
• Sharing personal information with Third-Party Service Providers that provide services on our behalf and business partners who help us operate and improve our business;
• Ensuring network and information security throughout the App and our Services.

If we need to use your Personal Data in other ways, we will make a specific notice at the time of collection and we will get your consent if applicable law requires so.

‍b. Marketing and Advertising Activities

‍We may send you marketing and advertising communications about PulpoLaps, the App, and Services, invite you to participate in our events or surveys, introduce our new technologies or solutions, or otherwise communicate with you for marketing purposes, and to customize the marketing and advertising that we provide to you (we offer choices about marketing and advertising as set forth under "Your Communication Choices" section below); provided that we do so in accordance with the consent requirements that are imposed by applicable law. If we collect your contact details through our participation at events, we may use the information to follow-up with you regarding an event, send you information that you have requested, and with your prior explicit consent, include you in our marketing information campaigns. 

We would also like to point out that the App would ask you whether you want to receive push notifications. You can change your preferences at any time from the “Settings” tab within the App or on your Device settings. If you provide us with your explicit consent on marketing activities, we may conduct marketing activities via email as well as push notifications within the App. 

‍c. Interest-based Advertising

‍When you visit our App, both certain third parties and we collect information about your online activities over time and across different apps/websites to provide you with advertising products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These third parties may place or recognize a unique cookie or other technology on your browser. Where required by applicable law, we will obtain your consent prior to processing your information for interest-based advertising.Since we also participate in advertising networks, you may see our ads on other websites or mobile apps. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests, and browsing context (for example, the time and date of your visit to our App, the pages that you viewed, and the links that you clicked). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.

We work with advertising networks (Google AdWords, Facebook, etc.). To learn more about managing your privacy and storage settings and opting out from receiving Network Advertising Initiative member companies ‘cookies, please visit the Network Advertising Initiative’s opt-out page. If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at here. If you opt-out from interest-based advertising, you may see advertising that is not relevant to you. If you opt out from interest-based advertising, you may see advertising that is not relevant to you.To learn more about managing your privacy and storage settings and opting out from receiving other Third Parties’ cookies, please see our “Exercising of Your GDPR Privacy Rights” and “Exercising of Your California Privacy Rights” sections.We do not guarantee that all of the Third Parties we work with will honor the elections you make using those options, but we strive to work with Third Parties that do.

7. HOW WE SHARE PERSONAL DATA

‍We may share your personal information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Policy and our Terms, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; (v) protect our rights, property or safety, our Users, and the public; or (vi) fulfill our obligations arising of or in connection with the contracts with Users. 

We share Personal Data with a limited number of our Service Providers. We have Service Providers that provide services on our behalf, such as hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These Service Providers may need to access Personal Data to perform their services properly. We authorize such Service Providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such Service Providers to contractually commit to protecting security and confidentiality of the Personal Data they process on our behalf. Our Service Providers are predominantly located in the Republic of Turkey, the European Union and the United States of America.

We may disclose information in the aggregate form to third parties relating to user behavior in connection with actual or prospective business relationships with those third parties, such as advertisers and content distributors (the “Service Partners”). We may also disclose information in the aggregate form to Third Parties in cases such as to help with auditing interactions and transactions with you, addressing security, fixing errors, helping us with advertising or marketing, maintaining accounts and verifying service quality or safety, and performing any of the other actions or activities allowed under this Policy. We will encourage our Service Partners to adopt and post transparent privacy policies. However, use of your Personal Data by our Service Partners is governed by their privacy policies and is not under our control. You acknowledge that we are not responsible for the violations caused by our Service Partners.

We may share personal information with Third Parties we work with for our purposes, though in general we do not share personal information about you with Third Parties for Third-Party marketing or advertising purposes. For information about the choices you have about the online advertising practices described in this section, please see the " Exercising Your GDPR Privacy Rights” and “Exercising Your California Privacy Rights“ sections below.

Third Parties are prohibited from using personal information for any other purpose and are contractually required to comply with all applicable laws and requirements.

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing such transaction.

We share personal information as we believe necessary: (i) to comply with applicable laws, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety, and property of the Company, you, or others; and (iv) to respond requests of the courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your jurisdiction.

Unless requested otherwise by you, we will never share your information, such as selfie pictures/photos, with outside sources for research or machine learning purposes without your consent. In addition, we may share your non-personal data with external sources for marketing and product development purposes.
‍
The AI analysis feature with the selfie image/photo in the application flow is a value proposition that we developed as a core feature. All of these user data are kept confidential on AWS and Firebase servers.
‍
We collaborate only with trusted third parties who assist us in operating our website and/or continuing our services, conducting/sustaining our business, or servicing you, so long as those parties agree to keep this information confidential and comply with all applicable data privacy laws. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others' rights, property, or safety.


8. ACCESSING AND UPDATING INFORMATION

‍If you have registered for an online Account, you may access and update certain personal information that you provided to us by logging into your online account and using the features and functionalities available therein. Once logged in, you can view or update your name, password, and email address also your preferences. Unless alternate procedures are noted for your jurisdiction in the " Exercising of Your GDPR Privacy Rights” and “Exercising of Your California Privacy Rights” sections, you may also make a request for access to personal information by sending an email or contacting us via email to access or update any of this information.

We are not able to grant all access requests, and we may request additional information from you to verify your identity before accommodating an access request.

Residents of California and certain countries, including European Union member states (and the United Kingdom), may have additional rights listed under the sections of " Your Rights and Choices Under the California Privacy Law " and " Your Rights and Choices Under the GDPR".


9. EUROPEAN UNION PRIVACY INFORMATION

Your Rights and Choices Under the GDPR

‍We undertake to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights properly.You have the right under this Privacy Policy, and by law if you are within the EU, to: 

‍Right of Access: You have the right to obtain confirmation from us as to whether Personal Data concerning you is processed, and, where that is the case, you have the right to request and get access to such Personal Data. 

‍Right to Rectification: You have the right to request rectification by us of inaccurate Personal Data and you have the right to provide additional Personal Data to complete any incomplete Personal Data as required by the Company.

‍Right to Erasure (“Right to be Forgotten”): In certain cases, you have the right to request from us the erasure of your Personal Data. For the avoidance of any doubt, we may not be able to grant this right to you in certain cases, due to our obligations to fulfill certain legal requirements.

‍Right to Restriction of Processing: You have the right to request from us restriction of processing, for a certain period and/or for certain situations.

‍Right to Data Portability: You have the right to receive your Personal Data from us in a structured format and you have the right to (let) transmit such Personal Data to another controller.

‍Right to Object: In certain cases, you have the right to object to the processing of your Personal Data including with regards to profiling. You have the right to object to the further processing of your Personal Data in so far as such data has been collected for direct marketing purposes.

‍Right to be Not Subject to Automated Individual Decision-Making: You have the right to not be subject to a decision based solely on automated processing.

‍Right to Filing Complaint: You have the right to file complaints with the applicable data protection authority on our processing of your Personal Data.

‍Right to Compensation of Damages: In case we breach applicable legislation on processing of your Personal Data, you have the right to claim damages from us for any damages such breach may cause to you.

‍Exercising of Your GDPR Privacy Rights

‍You may exercise your rights of access, rectification, cancellation and opposition by simply contacting us. Please note that we may ask you to verify your identity before responding to such requests. If You make a request, we will try our best to respond to you as soon as possible.You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (the “EEA”), please contact your local data protection authority in the EEA.
‍

10. CALIFORNIA PRIVACY INFORMATION

Your Rights and Choices Under California Privacy Law

‍Under this Policy, and by law, if you are a resident of California, you have the following rights:

‍Right to Notice: You must be properly notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.

‍The Rright to Access / Request: The CCPA permits you to request and obtain from the Company information regarding disclosure of your Personal Information that has been collected in the past 12 (twelve) months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.

‍The Right to Say No to the Sale of Personal Data (Do not Sell): You have the right to ask the Company not to sell your Personal Information to third parties. You can submit such a request by visiting our Website and contacting through the channels, features, and functionabilities provided on the Website and this Policy.

The Right to Know about Your Personal Data: You have the right to request and obtain from the Company information regarding disclosure of the following:

• The categories of Personal Information collected
• The sources from which the Personal Information was collected
• The business or commercial purpose for collecting or Selling the Personal Information
• Categories of Third Parties with whom we share Personal Information
• The specific pieces of Personal Information we collected about you

‍The Right to Delete Personal Data: You also have the right to request the deletion of your Personal Information that have been collected in the past 12 (twelve) months.

‍The Right Not to be Discriminated against: You have the right not to be discriminated against for exercising any of your rights as a consumer, including the following:

• Denying to provide products or Services to you
• Charging different prices or rates for products or Services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of products or Services to you
• Suggesting that you will receive a different price or rate for products or Services or a different level or quality of products or Services.

‍Exercising Your California Privacy Rights

‍In order to exercise any of your rights under the CCPA, as a California resident, you can contact us through channels, features, and functionalities (i.e., email address, phone number, interactive customer support chat, contact form) provided on the Website.

Once we receive your request, we will validate the information that you provide and send a message to the email address you provide in the request, asking you to verify that it is your email address. Please follow the instructions in that email to verify your email address. We will begin processing your request once you verify your email address.

The Company will disclose and deliver the required information free of charge within 45 (forty five) days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

‍Please note that if you do not include necessary information concerning you in your requests, we may ask you to verify your identity before responding to such requests.

Do Not Sell My Personal Information

We may continue to collect and share personal information about you with Third Parties as described in our Policy if that sharing is not a "sale" of personal information, such as to continue to provide Services to you. 

We do not provide personal information about you to Third Parties in exchange for money. We do share personal information with Third Parties that we work with, including to help us market or advertise our Services to you and mostly with regard to your prior consent. When this information is in a format that directly identifies you by name, it is generally not shared with any Third Parties for Third-Party marketing or advertising purposes. You can find more detail about our practices in our Policy, set forth under "Marketing and Advertising Activities" section. 

Even though we do not provide personal information to these Third Parties in exchange for money, the CCPA may characterize our providing the following categories of information we share with Third Parties that provide services to you or to us, such as personalizing your experience with us or helping us to market or advertise our products and Services to you, as "sales" of personal information; (i) Device and browsing information and other internet activity information; (ii) purchase or other commercial information; and (iii) identifiers. 

The Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA, you may do so by following the instructions below;

You can opt out of Selling your personal information as to the extent prescribed under the CCPA, by adjusting settings using each Device and browser you use. 

The opt out will place a cookie on your Device that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

‍Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

‍Mobile Devices

Your mobile device may give you the ability to opt-out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
‍
• "Opt-out of Interest-Based Ads" or "Opt-out of Ads Personalization" on Android devices
• "Limit Ad Tracking" on iOS devices
‍
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

‍"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

‍Our Service does not respond to Do Not Track signals. However, some third-party mobile applications do keep track of your application activities. If you are visiting such an application, you can set your preferences on your mobile device to inform the application that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your mobile device.

‍California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

‍California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.

We do not knowingly process personal information of California residents under the age of 18. If you have reason to believe that anyone under the age of 18 has provided us with any personal information, please contact us.


11. SECURITY AND RETENTION

‍We are making reasonable efforts to provide you with an appropriate level of security for the risks associated with the process of your Personal Data. We take organizational, technical, and administrative measures designed to protect your Personal Data against unauthorized access, destruction, loss, alteration, or abuse. Your Personal Data may only be accessed by a limited number of personnel who need access to such information in order to perform their duties properly. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have a reason to believe that your interaction with us is no longer secure, please contact us immediately.

If you are a User, we retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services to you, to the extent necessary to comply with our legal and regulatory obligations. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data due to our contractual commitments to our financial and business partners. Where we retain data, we do so in accordance with any limitation periods and record retention obligations that are imposed by applicable laws.


12. YOUR COMMUNICATIONS CHOICES

‍You may receive marketing and advertising communications about the Company, the App, the Services, if you provide clear consent. To receive marketing and advertising communications from the Company, you can sign up for our newsletter, contact our customer service, or give your clear consent in the applicable areas. We provide our Users with the opportunity to "opt out" of receiving marketing and advertising communications other than those for purposes directly related to placement, processing, fulfillment or delivery of a contractual obligation or your transactions with us. We provide you with the following options if you prefer to "opt out" of receiving information or materials that we think may be of interest to you: 

• At all times, you have the option of "opting out" of receiving marketing and advertising emails from the sender only by clicking the "unsubscribe" link in any of the marketing and advertising emails you receive. In addition, if you have an online Account, you may change your email preferences regarding email from us by logging into your Account. 
• At all times, you can disable marketing related push notifications from “Settings” of the App or through your Device settings and preferences.
• In all cases, you may email us at pure@pulpolabs.tech.


13. SECURITY 

‍We are making reasonable efforts to provide you with an appropriate level of security at the risk associated with the processing of your personal information. We take organizational, physical, technical, and administrative measures to safeguard your personal information against unauthorized access, destruction, loss, alteration, or abuse. Your personal information may only be accessed by a limited number of personnel who need access to such information in order to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have a reason to believe that your interaction with us is no longer secure (for example, if you think your Account is compromised), please contact us immediately. 

‍
14. RETENTION

‍Your personal information may be retained for as long as is reasonably necessary to perform the purposes listed under the "How We Use Information" section. For example, if you register an online account with us, we will store any personal information associated with your account for as long as you remain a customer or we believe we may be in a position to provide Services to you. The servers and databases in which information may be stored may be located outside the country from which you accessed the Services and, in a country, where the data protection and other laws may differ from your country of residence. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.

Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable laws.


15. INTERNATIONAL DATA TRANSFERS

‍We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage Service Providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected. Those countries may have data protection rules that are different from those of your country. However, we will take the necessary measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.

For Users that are residents of the Republic of Turkey; according to the Personal Data Protection Law No. 6698 (“PDPL”) of the Republic of Turkey, Personal Data cannot be transferred abroad without the explicit consent of the Data Subject unless some requirements are met stipulated under Article 9 of the PDPL. Since the servers of our Service Providers and the infrastructure we prefer due to higher security procedures are located abroad, your Personal Data will be transferred abroad upon your prior explicit consent.
‍

16. USE BY MINORS

We comply with the requirements of COPPA (Children’s Online Privacy Protection Act), and we do not collect any information from anyone under 13 years of age. Our website, products, and services are all directed to people at least 13 years old or older.
‍
‍The Services are not directed to individuals under the age of 18 (eighteen), and they shall not provide personal information through the Website or the Services. If you have reason to believe that anyone under the age of 18 has provided us with any personal information, please contact us. If we learn that an individual under the age of 18 has provided personal information to the Website, we will use reasonable efforts to remove such information from our files.
‍

17. UPDATES TO THIS POLICY AND NOTIFICATIONS

‍We may change this Policy from time to time to reflect new services, changes in our personal information processing practices, or applicable laws. The “Last Updated Date” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Website. If we change our practices in a way that requires revising this Policy in a material way, we will provide appropriate notice to you. We may provide you with disclosures and alerts regarding the Policy or personal information collected by push notifications or alerts or by contacting you through your email address.
‍

18. DATA DELETION
‍
Historical face data and analysis for the change report are kept under the full authority of the user. All the data held by users on the servers are permanently deleted when the users delete their accounts.
‍
If the users use Pure actively, the face data is kept unless the user deletes it. Facial data of users who have been inactive in the last 90 days will automatically be deleted. 
‍
If the users want to delete their data without deleting their account, please email pure@pulpolabs.tech, stating the user name and email used for the Pure account, and we will have the user data permanently removed.


19. LINKS TO OTHER WEBSITES

‍The Services or App may provide the ability to connect to other websites/apps. These websites/apps may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website/app is not owned or controlled by us, we are not responsible for its content, any use of such website/app, or the privacy practices of the website’s/app’s operator.
‍

20. JURISDICTION

‍PulpoLabs focuses on multinational compliance regulations including but not limited to United States Privacy Law and, the GDPR to make sure privacy is a “go-to” rather than a thing to be worried about. You have the right to request further information on our personal data processing activities based on your country's laws. 

‍
21. CONTACT US

‍We welcome you to reach out if you have any questions or concerns regarding our privacy practices. Please feel free to contact us at pure@pulpolabs.tech.