Privacy Policy — serFoto Effective Date: 2025-12-02 Last Updated: 2025-12-02 Owner / Data Controller: Serenay Yazılım Ltd. Şti. (“Service Provider”) Email: info@serenay.net.tr This Privacy Policy describes how the serFoto mobile application (“Application”) collects, uses, and protects your information. By using the Application, you agree to the terms outlined in this Privacy Policy. 1. Information We Collect 1.1 Automatically Collected Information When you download and use the Application, certain information may be collected automatically, including: • Device Internet Protocol (IP) address • Device information (operating system, device model) • Usage data (screens visited, actions taken, time spent in the app) • Crash logs and performance data • Analytics data for improving the Application The Application does not collect precise or real-time location data. 1.2 User-Provided Information For a better experience, you may voluntarily provide: • Full name (optional) • Email address (optional) • Other information requested within the Application This information is stored securely and used only as specified in this policy. 2. How We Use Your Information The Service Provider may use collected information for the following purposes: • To operate and improve the Application • To analyze performance and usage • To contact you with important updates, notifications, or support messages • To comply with legal obligations • To prevent fraud and enhance security We do not sell or rent personal data to third parties. 3. Third-Party Services The Application uses third-party tools that may collect data under their own policies: • Google Play Services • Google Analytics for Firebase These services may collect anonymous, aggregated data to help improve Application performance. Links to their privacy policies: Google Play Services: https://policies.google.com/privacy Firebase: https://firebase.google.com/support/privacy 4. Legal Basis for Processing (GDPR Requirements) If you are located in the European Economic Area (EEA), we process your data under the following legal bases: • Consent: When you voluntarily provide information. • Legitimate Interest: To improve the Application, analytics, and security. • Legal Obligation: When required by law or regulatory authorities. 5. Data Sharing Your information may be shared only under the following circumstances: • When required by law (subpoena, court order, legal request) • To protect rights, safety, and prevent fraud • With trusted service providers who operate under confidentiality agreements • During company merger, acquisition, or asset transfer (data will remain protected) We ensure that third parties do not use the shared data for any purpose other than providing the requested service. 6. Data Retention The Service Provider will retain your data: • For as long as you use the Application • For a reasonable period after you stop using it, unless deletion is requested If you want your data deleted, contact: info@serenay.net.tr. We commit to responding within a reasonable timeframe. 7. Opt-Out Rights You can stop all data collection by uninstalling the Application at any time. This can be done through your device’s standard uninstall process or app marketplace. 8. Children’s Privacy The Application does not knowingly collect data from children under 13 years old. If we learn that data from a child under 13 has been collected, it will be deleted immediately. If you suspect such a case, please contact us at info@serenay.net.tr. 9. Security The Service Provider takes reasonable measures to protect your data, including: • Encrypted network communication (HTTPS) • Secure storage and restricted access • Technical and procedural safeguards to prevent unauthorized access No method of transmission is 100% secure, but we strive to use industry-standard protection. 10. Your Rights Under GDPR / KVKK Depending on your region, you may have the right to: • Access your personal data • Request corrections • Request deletion • Restrict processing • Request a copy of your data (data portability) • Withdraw consent at any time For all requests, email: info@serenay.net.tr 11. Changes to This Privacy Policy This Privacy Policy may be updated from time to time. Users will be notified by: • Updating this page • Updating the “Effective Date” above Continued use of the Application after updates constitutes acceptance of the new terms. 12. Contact Us If you have any questions regarding privacy or data protection, please contact: Serenay Yazılım Ltd. Şti. Email: info@serenay.net.tr Türkiye