Privacy Policy

I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)

Denali Digital Bilişim Limited Şirketi (“we,” “us” or “our”) takes your privacy seriously. This Privacy Policy (“Privacy Policy”) explains our data protection policy and describes the types of information we may process when you install and/or use the Aura Scanner software application for mobile devices (the "App", "our App").

Aura Scanner is an AI-powered wellness and self-reflection application that allows users to take or upload a face photo to receive AI-generated aura-related insights, including aura colors, daily mood interpretation, aura color chart, energy balance, and aura references. The App may also include features such as daily affirmation cards, manifestation guidance, and meditation timer experiences.

When we refer to personal data or personal information, we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, by reference to such data.

A natural person can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to their physical, physiological, mental, economic, cultural, or social identity.

Our Privacy Policy applies to all users and others who access the App (“Users”).

For the purposes of the General Data Protection Regulation (GDPR), we are the data controller, unless otherwise stated.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. WHEN YOU USE THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY.

IMPORTANT NOTICE ABOUT AI-GENERATED CONTENT

The App uses artificial intelligence technologies to generate aura readings, aura colors, mood-related interpretations, energy balance results, affirmation suggestions, manifestation guidance, meditation-related content, charts, and other wellness-related outputs.

All content, interpretations, scores, colors, charts, results, references, suggestions, and recommendations provided by the App are generated by artificial intelligence and are intended solely for informational, entertainment, self-reflection, and personal wellness purposes.

The App does not provide medical, psychological, psychiatric, diagnostic, legal, financial, or professional advice. The App is not intended to diagnose, treat, cure, prevent, or evaluate any disease, condition, mental health issue, emotional disorder, or physical health status.

Users should not rely on the App’s AI-generated content for healthcare, mental health, emergency, legal, financial, or other professional decisions. If you have any medical, psychological, or mental health concerns, you should consult a qualified professional.

IMPORTANT NOTICE ABOUT FACE DATA

The Aura Scanner feature may require you to voluntarily take or upload a photo that includes your face. This photo is processed only to generate the requested AI-based aura and wellness result.

The App does not use face photos or face data to identify you, authenticate you, verify your identity, perform facial recognition, create biometric identifiers, create biometric templates, analyze facial geometry for identification, or track you across apps or services.

The App does not use face data or user photos to build, improve, train, test, or develop artificial intelligence, machine learning, facial recognition, biometric recognition, or similar technologies.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE READ THE FOLLOWING IMPORTANT NOTICE

Under the California Consumer Privacy Act of 2023 (CCPA), California residents have the right to request:

The categories of personal information that is processed.

The categories of sources from which personal information is obtained.

The purpose for processing user personal data.

The categories of third parties with whom we may share your personal information.

The specific pieces of personal information that we might have obtained about a particular user, provided that the data given in the request is reliable enough to identify the user.

Please use the navigation links within this Privacy Policy:

PERSONAL INFORMATION

All about the categories of information, its sources, and purposes of processing.

Please note that according to CCPA, personal information does not include de-identified or aggregated consumer information.

SHARING

How your information can be shared.

Please note that all third parties engaged in processing user data are service providers that use such information on the basis of an agreement and pursuant to a business purpose.

OPT-OUT OPTIONS

If you don’t want us to process your personal information anymore, please contact us via email at support@denalidigital.co.

In most cases, there is no way to maintain the App’s further operation without functional data, therefore, you may be advised to stop using the relevant App features or remove the App from your device.

If you don’t want us to share device identifiers and analytics-related data with service providers, please check your device settings to opt out as described below.

REQUESTS

To submit a verifiable consumer request for access, portability, or deletion of personal data, please contact us via email at support@denalidigital.co.

Please include the following phrase in the text of your appeal:

"Your rights to maintain confidentiality in the state of California.”

When submitting a verifiable request, you should be ready to:

Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.

This may include your name, address, city, state, zip code, and email address.

We may use this information to verify your identity.

If you are making a request through an authorized agent, the agent must provide a written authorization or power of attorney, signed by you.

Describe your request with sufficient detail so that we can properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide personal information if we cannot:

Verify your identity or authority to make the request.

Confirm that the personal information relates to you.

We may ask for additional information or documents to verify your identity. As a security measure, we may also conduct third-party identity verification checks before taking action.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose.

We will keep such information only for the duration necessary for the verification purpose and will delete it afterward.

We aim to respond within forty-five (45) days of receiving a verifiable consumer request. If we require more time, we will inform you of the reason and extension period in writing.

Please note that we are only required to respond to two requests per customer per year.

EQUAL RIGHTS

Nothing in the way we handle your request shall be interpreted as discrimination.

This means that we will not impose different pricing or product access restrictions based on your privacy choices. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.

SALE OF DATA

We do not sell any of your personal data to third parties.

II. INFORMATION WE PROCESS

There are several categories of information that can be processed.

Functional Information

We process the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information, it may be impossible to provide the complete functionality of the App and perform the requested services.

What data can be processed:

Content Information: Photos, pictures, text inputs, user-selected options, manifestation intentions, manifestation length, manifestation phrases, meditation duration, meditation music preferences, affirmation interactions, aura scan history, and other content that you voluntarily provide or select while using the App.

Aura Scanner Photos: When you choose to use the Aura Scanner feature, you may voluntarily take or upload a photo of your face. The photo is processed solely to generate AI-powered aura-related results, including aura colors, daily mood interpretation, aura color chart, energy balance, aura references, and related wellness content.

Face Data: For the purposes of this Privacy Policy, “face data” refers only to the user-submitted photo or image that may contain a visible face. The App does not extract, create, collect, store, or retain biometric identifiers, biometric templates, facial geometry maps, faceprints, facial recognition templates, or similar biometric information.

AI Data Consent: By choosing to use AI-powered features, including Aura Scanner, Affirmations, Manifesting, and Meditation-related AI suggestions, you acknowledge that your submitted or selected content may be processed by artificial intelligence systems solely to generate the requested result. You may choose not to use these features if you do not want your content to be processed for AI-generated outputs.

Contact Information: Name, email address, and any other content included in the email, which you may provide when contacting us via email or support form. We may collect, store, and process this data through our cloud storage or support service providers. This information is used to respond effectively to your inquiries, fulfill your requests, and send you communications that you request.

Camera and Photo Library Access

The App may request access to your camera or photo library only when you choose to take or upload a photo for the Aura Scanner feature.

We use camera or photo library access only to allow you to provide the image needed for the requested feature.

We do not access your camera or photo library in the background.

We do not collect photos from your device without your action.

We do not scan your photo library.

You may manage or revoke camera and photo library permissions at any time from your device settings.

Face Data and Biometric Information

The App may temporarily process a photo containing your face solely to provide the Aura Scanner functionality requested by you.

The App does not:

perform facial recognition;

identify individuals;

authenticate users;

verify identity;

create biometric identifiers;

create biometric templates;

store face geometry;

create faceprints;

track users through facial data;

use face data for advertising;

use face data for profiling;

use face data for surveillance;

use face data for law enforcement purposes;

use face data for AI model training.

Face photos are processed only to generate the result requested by the user. The App does not use face data or user photos to build, improve, train, test, or develop artificial intelligence, machine learning, facial recognition, biometric recognition, or similar technologies.

Photos submitted for Aura Scanner may be temporarily transmitted to our secure servers or service providers solely for processing the requested AI-generated result. These providers are not permitted to use your photos or face data for their own purposes, advertising, profiling, model training, or identification.

User photos are retained only for the time necessary to provide the requested result and maintain technical security. Unless a longer retention period is required by law, Aura Scanner photos are deleted after processing or within a limited technical retention period.

Information That Is Processed Automatically

When you use the App, some information about your device and user behavior may be processed automatically. This information is generally non-personal, meaning it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form.

We process this information based on our legitimate interest in improving our App and providing users with the best possible experience. If we do not access such data, we may not be able to provide you with all the features of the App.

We may use third-party automatic data processing technologies to analyze certain information sent by your device via our App, such as analytics, crash reporting, attribution, subscription analytics, or advertising tools. Some of them may engage in automated processing of your personal data, including profiling, which means evaluating certain personal aspects relating to you, such as preferences, interests, behavior, location, or movements.

Processing through these technologies may start automatically when you first launch the App, depending on your device settings, consent choices, and applicable law.

Device Details

When you use a mobile device to access our App, some details about your device may be collected, including device identifiers.

Device identifiers are small data files or similar data structures stored on or associated with your mobile device, uniquely identifying it but not directly identifying your personality. Device identifiers enable generalized reporting, analytics, personalized content, or ads by third parties where permitted by law and your device settings.

What data can be processed:

Device Information:

Type of your device

Operating system and version

Model and manufacturer

Screen size, screen density, orientation

Audio volume, battery status

Device memory usage

Internet Connection Details:

Mobile carrier

Network provider

Network type

IP address

Timestamp and duration of sessions

Connection speed

Browser type

Location-Related Information:

IP address

Country code, region, state, city associated with your device connection

Language settings

Time zone

We do not require precise GPS location to provide the Aura Scanner, Affirmations, Manifesting, or Meditation features unless a specific feature clearly asks for it and you grant permission.

Device Identifiers:

Identity for Advertisers for iOS devices, where permitted by Apple’s App Tracking Transparency framework

Advertising ID or Android ID for Android devices, where permitted by your device settings

User identifiers, if set up by the App’s developer

Application Information:

App name

API key or application identifier

App version

Properties of the App

Some services may also record a list of applications and/or processes installed or running on your device if required for fraud prevention, analytics, attribution, or security purposes and where permitted by applicable law.

Cookies and Similar Technologies

When you use the App, cookies and similar tracking technologies such as pixels, web beacons, scripts, SDKs, and local storage may be used.

A cookie or similar technology is a small file or data structure containing information downloaded to your device when you access the App. This information may then be sent back to the server each time you use the App.

Why do we use cookies and similar technologies?

To optimize how our App operates.

To analyze how many users access specific areas or features within our App.

To understand how users interact with Aura Scanner, Affirmations, Manifesting, and Meditation features.

To detect crashes, bugs, or technical issues.

To track which links or ads users click on, where permitted.

To enhance marketing efforts and provide personalized or contextual content, where permitted.

We may also allow advertisers and other partners to serve ads or provide services through the App using cookies or similar technologies, where permitted by applicable law and your device settings.

Log File Information

Log file information is automatically recorded each time you request access to the App.

When you use our App, analytics tools may automatically log:

The time and date when you start and stop using the App.

How you interact with the App.

Aura Scanner feature usage events.

Affirmation card usage events.

Manifesting feature usage events.

Meditation timer usage events.

Any errors or crashes encountered.

Ad-Related Information

The following data might be recorded about ads displayed in the App:

Date and time a particular ad is served.

Whether the ad was clicked or resulted in a conversion event.

Type of ad, such as text, image, or video.

Ad placement, meaning where the ad appears within the App.

Whether you respond to the ad.

In-App Events

When you use our App, analytics tools may automatically record user activity, such as:

Onboarding progress

Aura scan creation events

Affirmation card views

Manifesting selections

Meditation timer usage

Subscription events

Payments and in-app purchases

Custom events

User progression events

Methods for limiting the processing of user data

Third-Party Data Processing

Information processed automatically by advertising, analytics, attribution, cloud, crash reporting, subscription, or AI processing tools does not generally come under our direct control.

Some third-party services may engage in personal data profiling, meaning they may analyze your device data or app usage data using their own independent technologies.

For example, if your user ID is linked to a third-party advertising or analytics account, such third party may use your device data in combination with categorized data already recorded in its databases.

We do not control, supervise, or guarantee how independent third parties process your personal data outside of our instructions. If you wish to inquire about your personal data held by these third parties, please contact them directly.

Payment Information

Our e-commerce provider, Apple, is responsible for billing, processing, and charging for in-app purchases.

Apple handles your personal payment information securely, and we do not have access to your credit or debit card details.

For more information, please refer to Apple’s in-app purchase policies directly on the App Store.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

(a) To make our service available. We use functional information and information that is processed automatically to provide you with all requested services.

(b) To provide the Aura Scanner feature. We may temporarily process your submitted face photo solely to generate AI-powered aura colors, daily mood interpretation, aura color chart, energy balance, aura references, and related wellness content requested by you.

(c) To provide AI-generated wellness content. We use uploaded photos, selected options, manifestation inputs, affirmation interactions, meditation preferences, and other user-provided content solely to generate aura-related insights, affirmation suggestions, manifestation guidance, meditation-related suggestions, charts, and other AI-powered wellness experiences requested by the user.

(d) To provide Affirmations. We may process your interactions with daily affirmation cards to show affirmation content, maintain feature functionality, and improve the user experience.

(e) To provide Manifesting. We may process your selected manifestation intention, manifestation length, and manifestation phrase to generate or display manifestation-related content requested by you.

(f) To provide Meditation. We may process your selected meditation duration, timer settings, and music preferences to provide the meditation timer experience.

(g) To improve, test, and monitor the effectiveness of our App. We use information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, and operate, protect, improve, and optimize our App.

(h) To provide you with interest-based or contextual advertising or other targeted content, where permitted. We may use information that is processed automatically for marketing purposes to show ads that may be of interest to you based on your preferences. We provide personalized content and information to you, which can include online ads or other forms of marketing, where permitted by applicable law and your consent choices.

(i) To communicate with you. We use the information we have to communicate with you, receive your feedback about our App experience, inform you about our policies and terms, and respond to you when you contact us.

(j) To prevent fraud and spam, to enforce the law. We want our App to be free of spam and fraudulent content so that you feel safe and secure. We may use your information to prevent, detect, and investigate fraud, security breaches, or potentially prohibited or illegal activities, protect our trademarks, and enforce our Terms of Use.

If any new purposes for processing your personal data arise, we will notify you before we start processing information for that other purpose by introducing the corresponding changes to this Privacy Policy.

IV. SHARING OF YOUR INFORMATION

We do not rent or sell your personal data to third parties.

We may temporarily process user-submitted photos containing faces solely to provide the Aura Scanner functionality requested by the user.

Face photos are not used for identification, authentication, facial recognition, biometric recognition, advertising, profiling, surveillance, law enforcement purposes, or AI model training.

We do not sell, rent, trade, license, disclose, or otherwise monetize face photos or any information derived from them.

We do not create or retain biometric identifiers, biometric templates, facial geometry maps, faceprints, or similar biometric information.

We may share information from tools like cookies, log files, device identifiers, analytics events, crash logs, and app usage data with third-party organizations that provide automatic data processing technologies for the App.

This information allows third-party service providers to provide analytics, crash reporting, attribution, subscription management, advertising, cloud hosting, AI processing, security, fraud prevention, and other technical services.

Where an AI processing or cloud service provider processes user-submitted photos or content on our behalf, such processing is performed solely to provide the requested App functionality. These providers are not permitted to use user photos, face data, or user content for their own advertising, profiling, identification, or AI model training purposes.

Third-Party Service Providers

If you want to learn more about these services and their privacy options, including opt-out options, please refer to their respective websites and privacy policies.

We are not responsible for any use of your personal data by third parties mentioned above if such use is outside our instructions or outside the scope of services provided to us.

Our App may contain links to third-party websites or services, or you may access the App from a third-party site. We are not responsible for the privacy practices of third-party sites or services linked to or from our App, including the information or content contained within them.

Disclosure of Personal Information

We may disclose your personal information under the following circumstances:

As required by law;

When we believe, in good faith, that disclosure is necessary to protect our rights, ensure user safety, investigate fraud, or respond to government requests;

If we are involved in a merger, acquisition, or sale of all or part of our assets, you will be notified via email and/or a prominent notice in our App about any changes in ownership or how your personal information will be used.

V. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our App to users worldwide.

We, along with third-party organizations that provide automatic data processing technologies for the App, cloud hosting providers, AI processing providers, analytics providers, advertising partners, or other service providers, may transfer automatically processed information and functional information across borders and from your country or jurisdiction to other countries or jurisdictions worldwide.

If you are located in the European Union or other regions with data protection laws that may differ from those in the United States, please note that we may transfer your personal information to a country or jurisdiction that does not have the same data protection laws as your country.

This means that your personal information can be transferred to:

A third country.

A territory or one or more specified sectors within that third country.

An international organization, where data protection and confidentiality regulations may not provide the same level of protection as your country.

We take reasonable steps to ensure that the recipient of any personal data provides adequate protection in compliance with applicable data protection laws.

For data storage and processing, we may use third-party hosting, cloud, AI, analytics, and security services. We take your privacy seriously and use reasonable technical and organizational measures, including encryption where possible, to protect personal data during transfer and storage.

VI. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as necessary to:

Provide the functional services of the App.

Provide Aura Scanner, Affirmations, Manifesting, and Meditation features.

Comply with legal obligations.

Maintain security, prevent fraud, and resolve disputes.

If you no longer want us to use your information, you may request that we erase your personal data and close your account, if an account-based feature is available.

Aura Scanner Photos and Face Data

User-submitted photos used for Aura Scanner functionality are retained only for the period necessary to provide the requested service and maintain system security.

After processing is completed, photos are deleted automatically within a limited technical retention period, unless a longer retention period is required by law, security, fraud prevention, or dispute resolution obligations.

We do not retain biometric identifiers, biometric templates, facial geometry maps, faceprints, or facial recognition data because the App does not create or collect such data.

AI Processing Data

User-submitted photos, selected options, manifestation inputs, affirmation interactions, meditation preferences, and other content may be temporarily processed to generate AI-powered results.

We do not use this data to train, improve, test, or develop artificial intelligence, machine learning, facial recognition, biometric recognition, or similar technologies.

However, some data may still be retained for a certain period, but no longer than required for the storage purpose, for:

Legal compliance, such as taxation, accounting, audits, and regulatory obligations.

Security and backup purposes.

Fraud prevention or protection against malicious acts.

Technical diagnostics and crash investigation.

VII. EXERCISING YOUR RIGHTS

Applicable data protection laws provide you with certain rights regarding your personal information.

You have the right to:

• Access & Portability – Request copies of your personal information.
• Correction – Request corrections to inaccurate or outdated personal data.
• Data Retention & Deletion – Request that your personal data be deleted.
• Restriction of Processing – Under certain circumstances, limit the ways in which your data is processed.
• Objection – Object to certain processing activities, including direct marketing.
• Withdrawal of Consent – Withdraw consent where processing is based on your consent.

To exercise any of these rights, you can contact us at:

support@denalidigital.co

We enforce the above-mentioned rights only concerning information that we physically access and store.

Where your personal data is processed automatically, you may object to such processing under certain circumstances.

If your personal data is processed for direct marketing purposes, you have the right to opt out of such processing at any time.

To exercise this right, you should contact the third-party service providers listed in Section IV of this Privacy Policy or adjust your device settings as described below.

VIII. HOW TO OPT OUT

Opt-out of Marketing Tracking

If you do not want third-party service providers to personalize ads based on your interests, follow the instructions below:

iOS: Settings \> Privacy & Security \> Tracking \> Allow Apps to Request to Track \> Off, or manage tracking permission for the App individually.

Android: Settings \> Google \> Ads \> Delete advertising ID or Opt out of Ads Personalization, depending on your Android version.

Visit YourAdChoices for additional options.

Please note that even if you opt out of interest-based advertising, you may still receive contextual ads based on other non-personal information.

Opt-out of Camera or Photo Library Access

If you do not want the App to access your camera or photo library, you can manage permissions from your device settings.

iOS: Settings \> Privacy & Security \> Camera / Photos \> Aura Scanner \> Disable or limit access.

Android: Settings \> Apps \> Aura Scanner \> Permissions \> Camera / Photos \> Deny.

Please note that if you disable camera or photo library access, the Aura Scanner feature may not function properly.

Opt-out of AI Photo Processing

If you do not want your photo to be processed by AI systems, do not use the Aura Scanner feature.

You may still be able to use other parts of the App, such as Affirmations, Manifesting, or Meditation, depending on the App version and available functionality.

Opt-out of Location Data Processing

The App does not require precise location data for its core Aura Scanner, Affirmations, Manifesting, or Meditation features.

If any App feature requests location permission and you do not want third-party service providers to use your precise location data, follow the instructions below:

iOS: Settings \> Privacy & Security \> Location Services \> Aura Scanner \> Never.

Android: Settings \> Apps \> Aura Scanner \> Permissions \> Location \> Deny.

IX. SECURITY

The security of your personal information is highly important to us.

We follow generally accepted industry standards to protect personal data both during transmission and once received.

We take reasonable and appropriate measures to protect personal information from:

Loss

Misuse

Unauthorized access

Disclosure

Alteration

Destruction

We implement technical and organizational security measures, including:

Data Minimization – Only collecting data necessary for the App’s functionality.

Encryption – Encrypting personal data where reasonably possible.

Access Control – Restricting access to personal data.

Temporary Processing – Processing Aura Scanner photos only for the time necessary to generate the requested result.

No Biometric Templates – Not creating or storing biometric identifiers, faceprints, facial geometry maps, or biometric templates.

Despite our best efforts, no system is 100% secure. In the event of a data breach, we will promptly notify affected users in compliance with applicable laws.

For security concerns, contact us at:

support@denalidigital.co

X. CHILDREN’S PRIVACY

Our App is not directed to children under the age of 13.

We do not knowingly collect personal information from children under 13.

If we discover that we have inadvertently collected personal information from someone under 13 without verifiable parental consent, we will delete such information immediately.

If you are under 13, please do not use the App or submit any personal information, including photos.

If you believe that we may have inadvertently collected data from someone under the age of 13, please reach out to us at:

support@denalidigital.co

XI. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

If we make material changes to this Privacy Policy, we may notify you by updating the “Last Updated” date, displaying a notice in the App, or using other appropriate communication methods.

Your continued use of the App after any changes to this Privacy Policy means that you acknowledge the updated Privacy Policy.

XII. HOW TO CONTACT US

If you have any questions about this Privacy Policy, you may contact us at:

support@denalidigital.co

Denali Digital Bilişim Limited Şirketi

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