AI Cleanup Privacy Policy

Key Points Summary

1. Data Controller and Objectives

The personal data you provide to us, or that we obtain through other means, may be processed by us as the "Data Controller."

We aim to process users' personal data in line with general privacy principles and the data protection laws applicable to the individuals involved, particularly the Turkish Republic's Law No. 6698 on the Protection of Personal Data and other relevant laws and regulations.

We commit to complying with this Privacy Policy in accordance with all applicable laws in each region where we operate. Additional regional privacy notices apply where required, including Section 11 for individuals in the European Economic Area, the United Kingdom, and Switzerland, and Section 12 for California residents.

In line with this Privacy Policy, we process personal data in compliance with the following basic principles:

• Compliance with law and good faith.
• Accuracy and, where necessary, keeping data up to date.
• Processing for specific, explicit, and legitimate purposes.
• Limiting processing to the stated purposes and minimizing data collection.
• Storing data only for the period required by law or the processing purpose.

Unless defined separately in this policy, terms used here have the meanings specified in our Terms and Conditions.

2. Collection of Personal Data and Methods

We may process the following data for the purposes outlined in this Privacy Policy.

Identity and Contact Information

When you contact us via email, we may process your first name, last name, phone number, email address, other contact details you choose to provide, and the content of your communication.

Technical Information

When you access, use, or engage with our services, we may collect:

• Usage Data: time spent in the app, access dates and times, data you access, features you use, content you view, searches, actions you take, error reports, and in-app or web purchase history.
• Log Data: internet traffic data, network activity, IP address, device information, operating system version, browser type and settings, language preferences, time zone, app configuration, and related statistical information.
• Device Information: device name, device ID, model, manufacturer, region information, operating system, device identifiers, and hardware model.
• Location Information: general regional location inferred from your IP address and device region information.
• Identifiers: unique user ID and device token ID, especially if you allow notifications.

Email Account Information

To provide our services, such as managing your inbox, we may request access to your email account. You can deny or later disable this access in your device settings, but some features may become unavailable. If you grant permission, we may access and manage your emails, including read, compose, send, and delete actions.

• Email Account Information: Google User ID, nickname, username, profile picture, user token, Open ID, phone number, and email address.
• Information Related to Email Accounts: emails, subjects, header information, lists, and other email-related metadata.

User Content

We process data you provide when interacting with our services. This includes materials, files, documents, images, photos, videos, visual or audio records, voice recordings, graphics, media, selections, contact lists, and any content, inputs, records, or data you upload, transmit, create, store, use, edit, or share through the app.

To provide features such as identifying similar photos in your gallery, we may request access to your device's photo library or your preferred cloud service. You can deny or later revoke this access in your device settings, but doing so may limit functionality.

Customer Transactions

We may collect order information directly from you, our marketing providers, or our payment processors to process orders, manage subscriptions, and ensure proper payment and subscription handling. This may include:

• Order date and payment date.
• Subscription type, billing period, and billing file.
• Payment amount, due amount, and payment status.
• Related transaction identifiers, including billing ID and your email address.

Marketing Data

With your permission, we may collect usage data together with the advertiser identifier (IDFA), vendor or developer identifier (IDFV), Google Advertising ID (GAID), and Firebase Analytics Identifier.

Explanation of Information Sources

• We may collect data directly from you through electronic or physical media.
• We may collect data through your device, browser, or third-party apps and websites.
• We may receive data from external sources such as the Apple App Store to operate our products, comply with legal obligations, enhance services, and help you navigate our services more easily.

3. Purposes and Legal Bases for Processing Personal Data

Your personal data may be processed automatically or manually for the purposes below in compliance with applicable laws, including Articles 5 and 6 of the PDP Law. Processing is lawful where a contract exists or is being formed with you, where processing is necessary to fulfill contractual obligations, where it serves our legitimate interests without harming your fundamental rights and freedoms, or where it fulfills legal duties.

For individuals in the European Economic Area, the United Kingdom, and Switzerland, please also refer to Section 11. For California residents, please refer to Section 12.

3.1 Purposes of Processing Personal Data

Your personal data may be processed for the following purposes:

• Executing goods and services sales processes.
• Executing contract-related processes.
• Fulfilling company, product, and service commitments.
• Operating our products.
• Creating user accounts for service recipients and app users.
• Conducting storage and archiving activities.
• Conducting communication activities.
• Providing after-sales support.
• Ensuring compliance with legislation.
• Executing and auditing business activities.
• Implementing information security processes.
• Conducting audit and ethics activities.
• Ensuring business continuity.
• Protecting individuals' rights, privacy, and security.
• Providing information to authorized persons, institutions, and organizations.
• Preventing crimes and other illegal activities.
• Conducting customer satisfaction activities.
• Customizing services, understanding user preferences, and improving service quality.
• Managing digital subscriptions and in-app purchases.
• Managing automatic renewal subscriptions for content, services, or premium features.
• Handling financial and accounting transactions.
• Following up on requests and complaints.

If you provide explicit consent, marketing data may also be used for marketing analysis and advertising, including personalized advertising, campaigns, and promotions. If you provide explicit consent, your identity and contact information may also be used to communicate marketing updates, new product or service announcements, and promotional offers.

4. Third-Party Websites/Applications, Cookies, and Notifications

The app may contain links to other websites or apps that are not controlled by us and may be subject to terms and policies different from ours. We are not responsible for how those third parties collect, use, or disclose your information.

We collect information fairly, lawfully, with your knowledge and consent, and explain why we collect it and how it will be used. You may refuse our requests for information, but some services may become unavailable as a result.

If you provide information to third-party sites or apps through our app, your rights and responsibilities toward those third parties remain governed by their own rules and policies.

Cookies

Cookies are small text files stored on your computer or mobile device when you visit a webpage. They help websites operate more efficiently and deliver personalized content. Cookies contain data from your website visit history and do not collect personal files from your device.

We may use cookies to operate our services, enhance performance and functionality, and provide relevant content, including ads, on our site or third-party sites. You can delete existing cookies and block new ones through your browser settings.

Browsers are usually set to accept cookies by default. Cookie management varies by browser, so please refer to your browser's help menu for details.

5. Data Storage

Your data will be stored for the periods specified in applicable laws or until the processing purposes no longer exist.

Even after processing purposes expire, we may retain personal data if required by other laws or based on your separate consent.

If you consent to extended storage, your data will be deleted, destroyed, or anonymized immediately after the extension expires or you withdraw consent.

After processing purposes have been fulfilled, your data may also be stored until the end of the relevant legal statute of limitations in order to establish, exercise, or protect our legal rights.

6. Technical and Administrative Measures

We store personal data in line with relevant laws and for the periods required by law or by the processing purposes. We commit to taking the technical and administrative measures necessary to ensure confidentiality, integrity, and security and to prevent unlawful processing, unauthorized access, disclosure, alteration, or destruction.

Our measures include:

• Periodically updated antivirus software on company computers and servers.
• Periodically updated software firewalls in data centers and disaster recovery centers.
• SSL-VPN access controls for suppliers with unique identification.
• Role-based user authorization for employees.
• Threat and event management systems with immediate alerting.
• Encryption for sensitive data in storage and transmission.
• Secure logging of transactions involving sensitive data.
• Regular penetration testing and automated security testing.
• Periodic employee training on data protection and security.
• Physical security for paper-based records and premises.
• Periodic backups using compliant cloud infrastructure or custom solutions.
• Non-disclosure agreements for employees handling sensitive data.

If sensitive personal data needs to be transferred outside the region, we rely on mechanisms such as standard contractual clauses issued by the Turkish Data Protection Authority to ensure compliance with applicable data protection laws.

7. Age Restrictions

Our application is not intended for use by individuals under 16 years of age. We do not knowingly collect or process personal data from children under 16.

If you become aware that someone under 16 has provided us with personal data, please contact us by email. Users under 18 must obtain permission from a parent or legal guardian before using our services.

8. Transfer of Personal Data to Third Parties

The procedures and principles for transferring personal data are governed by relevant laws. Your data may be transferred to third parties domestically or internationally, including to servers and cloud systems located in other countries.

We rely on standard contractual clauses and other lawful mechanisms to ensure the secure international transfer of your data in accordance with data protection laws.

The following categories of personal data may be transferred abroad to service providers:

• Technical information, identity and contact information, customer information, and user content for storage and archiving activities, including cloud and database services.
• Email account information for user account authentication.
• Technical information for correcting technical specifications, errors, and defects.

We may also transfer marketing data to service providers, including Google, Apple, Facebook SDK, Adjust, and Firebase Analytics, for marketing analysis and advertising, including personalized advertising, campaigns, and promotions.

We may be required to share personal data with authorized public institutions, organizations, and judicial authorities to fulfill our legal obligations.

9. Your Rights as a Data Subject

In accordance with applicable data protection laws, you have the right to:

• Learn whether your personal data is being processed.
• Request information about the processing if it is occurring.
• Learn the purpose of the processing and whether the data is used for that purpose.
• Know the domestic and international third parties to whom data has been transferred.
• Request correction of incomplete or inaccurate personal data.
• Request deletion, destruction, or anonymization of personal data if the reasons for processing cease to exist.
• Object to results arising against you from the exclusive analysis of personal data by automated systems.
• Claim compensation for damage caused by unlawful processing.
• Withdraw explicit consent for processing based on consent at any time.

To exercise your rights, you must submit a clear request, identify yourself, and provide the necessary documentation using the contact information in Section 10. We will address your request free of charge, typically within 30 days. If we reject your request, we will notify you of the reasons electronically.

10. Contact Information

If you have any questions, comments, requests, or wish to exercise your rights regarding this Privacy Policy, you may contact us at: zhuangyuweizyw@icloud.com

11. For Individuals in the European Economic Area, the United Kingdom, and Switzerland

Please read this section alongside the main Privacy Policy for a comprehensive understanding of our data practices under the GDPR, the UK Data Protection Act, and the Swiss Federal Data Protection Act.

Purposes and Legal Bases for Processing Personal Data

Your personal data may be processed for the purposes and on the legal bases described in the main sections above, which are aligned with the principles of the GDPR.

Transfer of Personal Data to Third Parties

When transferring personal data outside the EEA, Switzerland, or the UK, we implement the following mechanisms to ensure an adequate level of data protection:

• Adequacy decisions issued by the European Commission.
• Standard Contractual Clauses supplemented by safeguards such as encryption, data minimization, and technical controls where necessary.
• Binding Corporate Rules where applicable.

Your Rights as a Data Subject under the GDPR

Under the GDPR, you have the right to:

• Access your personal data.
• Rectify inaccurate or incomplete data.
• Erase your personal data under certain conditions.
• Restrict the processing of your data.
• Data portability.
• Object to processing, including profiling and direct marketing.
• Not be subject to decisions based solely on automated processing that produce legal effects or similarly significant effects.
• Withdraw your consent at any time.

You can exercise these rights by contacting us. We will respond within one month, with a possible extension of two additional months for complex requests. You also have the right to lodge a complaint with your local data protection authority.

12. For California Residents

This section supplements the main Privacy Policy for residents of California under the California Consumer Privacy Act and other applicable laws.

Your Rights

As a California resident, you have the right to:

• Know what personal information we collect, use, disclose, and "sell" or "share".
• Request deletion of your personal information.
• Correct inaccurate personal information.
• Opt out of the "sale" or "sharing" of your personal information.
• Limit the use and disclosure of sensitive personal information. We do not collect such information.
• Not be discriminated against for exercising these rights.

We do not "sell" personal information in the traditional sense. However, sharing data with analytics and advertising partners for personalized ads or analytics may be considered a "sale" or "share" under California law. You can opt out or withdraw permission at any time via your account settings or by contacting us.

Disclosure Regarding Collection of Personal Data

We may collect the categories of personal information described in Section 2, which may align with CCPA categories such as Identifiers, Personal Information, Internet or Network Activity, and Inferences.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. The updated date will be shown at the top of this page.

If we make material changes that significantly affect your rights or how we process your data, we will provide prominent notice through the app interface, by email, or by other reasonable means before the changes take effect.

Your continued use of our services after the effective date constitutes your acknowledgment of the updated terms unless the law requires a different form of acceptance.

14. Subscription

14.1 Subscription Information

Auto-Renewable Subscription Terms

• Title: AI Cleaner Premium
• Duration: 1 Week / 1 Year
• Weekly Plan: US$8.99 per week, price may vary by region, with a 7-day free trial, auto-renewal, and cancel anytime.
• Annual Plan: US$29.99 per year, price may vary by region.

This subscription automatically renews unless canceled at least 24 hours before the end of the current period. Payment will be charged to your Apple ID account upon confirmation of purchase.

Terms of Use (EULA): https://aicleanup-ios.web.app/terms.html

Privacy Policy: https://aicleanup-ios.web.app/privacy.html

14.2 Subscription Content

During the subscription period, you gain full access to all features, including:

• Similar Photo Cleanup
• Duplicate Photo Cleanup
• Similar Video Cleanup
• Similar Screenshot Cleanup
• Large Videos
• Contact Management
• Video Compressor
• Screenshots Clean
• Other Photos & Videos

14.3 Auto-Renewal

App Store official subscriptions are auto-renewable and confirmed for payment through your iTunes account. Users must manually manage auto-renewal in their iTunes or Apple ID settings. If auto-renewal is not turned off at least 24 hours before the current subscription period ends, the subscription will automatically renew.