PRIVACY POLICY

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• contact preferences

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's calendar, sms messages, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific 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 Data. 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. Depending on how you interact with us, 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 location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

If you interact with us on a social media platform using your social media account (e.g., Facebook or X), we receive personal information about you from such platforms such as your name, email address, and gender. You may have the right to withdraw your consent to processing your personal information. Learn more about withdrawing your consent. Any personal information that we collect from your social media account depends on your social media account's privacy settings. Please note that their own use of your information is not governed by this Privacy Notice.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Third-Party Service Providers

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work.

The categories of third parties we may share personal information with are as follows:

• Website Hosting Service Providers
• Sales & Marketing Tools
• Performance Monitoring Tools
• Payment Processors
• Finance & Accounting Tools
• Data Storage Service Providers
• Data Analytics Services
• Cloud Computing Services
• Ad Networks

Other Sharing Situations

We also may need to share your personal information in the following situations:

• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We will provide notice before your personal information is transferred and becomes subject to a different privacy notice.
• Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions. If you do not want us to share your personal information with these companies, contact us using the contact information provided.
• Offer Wall: Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.
• With Your Consent: We may disclose your personal information for any other purpose with your consent.

In Short: We may use cookies and other tracking technologies to collect and store your information.

Types of Tracking Technologies We Use

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Third-Party Tracking Technologies

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to:

• Help manage and display advertisements
• Tailor advertisements to your interests
• Send abandoned shopping cart reminders (depending on your communication preferences)
• Provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites

Cookie Management

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice. Most Web browsers are set to accept cookies by default. If you prefer, you can usually:

• Choose to set your browser to remove cookies
• Reject cookies
• Be notified when you receive a cookie, allowing you to choose whether to accept it

Please note that if you choose to remove or reject cookies, this could affect certain features or services of our Services.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include:

• Google Analytics Demographics and Interests Reporting
• Remarketing with Google Analytics and Google Display Network Impressions Reporting

Opting Out of Analytics

You can opt out of tracking by:

• Visiting https://tools.google.com/dlpage/gaoptout to opt out of Google Analytics tracking
• Using Google Ads Settings and Ad Settings for mobile apps
• Visiting http://optout.networkadvertising.org
• Visiting http://www.networkadvertising.org/mobile-choice

For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Social Login Options

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider.

Information We Receive

The profile information we receive may vary depending on the social media provider concerned, but will often include:

• Your name
• Email address
• Friends list
• Profile picture
• Other information you choose to make public on such a social media platform

How We Use Social Login Information

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. This may include:

• Creating and managing your account
• Personalizing your experience
• Connecting with your friends who also use our Services
• Providing you with a more seamless social experience

Third-Party Social Media Privacy

Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you:

• Review their privacy notice to understand how they collect, use, and share your personal information
• Review and set your privacy preferences on their sites and apps
• Contact them directly for any questions about how they use your information

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

Retention Period

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Account-Based Retention

No purpose in this notice will require us keeping your personal information for longer than:

• The period of time in which users have an account with us
• The time required to comply with legal obligations
• The time necessary to fulfill the purposes outlined in this notice

When We Delete Your Information

When we have no ongoing legitimate business need to process your personal information, we will either:

• Delete your personal information
• Anonymize such information
• Securely store your personal information and isolate it from any further processing until deletion is possible (if immediate deletion is not possible)

Backup Retention

In some cases, personal information may be stored in backup archives. If deletion from backup archives is not immediately possible, we will:

• Securely store your personal information
• Isolate it from any further processing
• Delete it when technically feasible

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

Our Security Measures

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures include:

• Encryption of data in transit and at rest
• Firewalls and secure network configurations
• Access controls and authentication requirements
• Regular security assessments and audits
• Employee training on security practices

Security Limitations

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. This means we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to:

• Defeat our security measures
• Improperly collect your information
• Access your information
• Steal your information
• Modify your information

Your Role in Information Security

Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should:

• Only access the Services within a secure environment
• Use strong passwords
• Enable two-factor authentication when available
• Be cautious when sharing personal information
• Report any suspicious activities or potential security breaches

Security Updates and Notifications

We regularly review and update our security measures to ensure the safety of your information. In the event of a security breach that affects your personal information, we will:

• Notify you as required by applicable laws
• Provide information about the breach and our response
• Take appropriate measures to address the breach

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Your Privacy Rights

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

• Request access to your personal information
• Request correction of your personal information
• Request deletion of your personal information
• Withdraw your consent to our processing of your information
• Object to our processing of your personal information
• Request restrictions on our processing of your personal information
• Request portability of your personal information

Withdrawing Your Consent

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by:

• Contacting us using the contact details provided below
• Adjusting your preferences in your account settings

However, please note that this will not affect:

• The lawfulness of the processing before your withdrawal
• Processing of your personal information conducted in reliance on lawful processing grounds other than consent

Marketing Communications

You can unsubscribe from our marketing and promotional communications at any time by:

• Clicking on the unsubscribe link in the emails
• Replying "STOP" or "UNSUBSCRIBE" to SMS messages
• Contacting us using the contact details provided

However, you will still receive:

• Service-related messages necessary for administration
• Messages related to your account
• Responses to your service requests

Account Information

If you would like to review, change, or terminate your account, you can:

• Log in to your account settings
• Contact us using the contact information provided

Upon your request to terminate your account, we will:

• Deactivate or delete your account
• Remove your information from our active databases
• Retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms and/or comply with legal requirements

Cookie Preferences

Most web browsers are set to accept cookies by default. You can usually:

• Choose to set your browser to remove cookies
• Reject cookies
• Be notified when you receive a cookie

Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Questions or Concerns

If you have questions or comments about your privacy rights, you may:

• Email us at [email protected]
• Visit our privacy portal at: __________

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage:

• No uniform technology standard for recognizing and implementing DNT signals has been finalized
• We do not currently respond to DNT browser signals
• We do not respond to any other mechanism that automatically communicates your choice not to be tracked online
• If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

Updates to This Notice

We may update this Privacy Notice from time to time. Updates may occur for various reasons, including:

• Changes in our business practices
• Updates to our Services
• Legal or regulatory requirements
• Feedback from our users

How We Notify You

When we make changes to this Privacy Notice:

• The updated version will be indicated by an updated "Revised" date
• For material changes, we may notify you by prominently posting a notice of such changes
• We may directly send you a notification
• We encourage you to review this Privacy Notice frequently to stay informed

Contact Methods

If you have questions or comments about this Privacy Notice, you can contact us by:

• Email: [email protected]
• Website: www.gowellfly.com/contact
• Mail: GoWellFly, İstanbul, Türkiye, İstanbul, İstanbul 34360, Turkey

What to Include

To help us respond effectively to your inquiry, please include:

• Your contact information
• The nature of your request
• Any relevant account information
• Any specific privacy concerns

Response Time

We strive to respond to all legitimate inquiries within:

• 24-48 hours for urgent matters
• 5-7 business days for general inquiries
• 30 days for complex requests requiring detailed investigation

In Short: Based on your location, you have certain rights regarding your personal information, and we're here to help you exercise those rights.

Your Data Rights

Depending on your location and applicable laws, you may have the following rights regarding your personal information:

• Access your personal data and receive a copy of it
• Know how we process your data and for what purposes
• Request correction of inaccurate or incomplete data
• Request deletion of your personal data (right to be forgotten)
• Withdraw your consent to data processing
• Object to certain data processing activities

How to Exercise Your Rights

You can exercise your rights in the following ways:

• Through your account settings (if you have an account)
• By submitting a request through our privacy portal: __________
• By contacting our privacy team at [email protected]
• By mail to our physical address listed in the contact section

Response Timeline

When you submit a request:

• We will acknowledge receipt within 48 hours
• We will respond to your request within 30 days
• If we need more time, we'll notify you and may extend the response period by up to 60 days
• We will inform you of any action taken or reasons why action cannot be taken

Verification Process

To protect your privacy and security, we will verify your identity before processing your request. We may ask you to provide:

• Account login credentials
• Government-issued ID
• Proof of address
• Other information to confirm your identity

Limitations and Exceptions

Please note that your rights may be limited in certain circumstances:

• Legal requirements to retain certain data
• Ongoing investigations or legal proceedings
• Rights of others that may be violated by the request
• Technical limitations or legitimate business purposes

If you have any questions about exercising your rights or need assistance with your request, please don't hesitate to contact us using the information provided in the contact section above.