ASTAIRO – PRIVACY POLICY

Introduction

We respect your privacy and are committed to protecting your personal data. With this Privacy Policy ("Policy"), IANDROOTS Yazılım Teknolojileri ve Ticaret Anonim Şirketi ("IANDROOTS") explains how your information and personal data are collected and processed, the measures taken for protection, confidentiality and data security, as well as your rights.

This Policy applies to ASTAIRO's application, website and ASTAIRO's social media platforms (collectively "ASTAIRO / Services / App").

Your access to and use of ASTAIRO are governed by this Privacy Policy and the Terms of Use ("Terms"). The Terms apply to the definitions contained within this Policy and to provisions not included in this Policy. We recommend that you review the Terms of Use to learn about the definitions, functions and features of ASTAIRO.

By accessing or using ASTAIRO, you agree to the collection and use of your information and personal data in accordance with this Policy, and acknowledge that you have reviewed and understood the processing of your information and personal data, including your rights. If you do not agree with the Terms or this Privacy Policy, please do not use the Website and/or the Services provided by ASTAIRO.

1. Collection of Information and Processing Purposes

When you access ASTAIRO or use the Website and/or Services, the following information and personal data may be collected:

1. Personal Information and Contact Information

  • • Google Account or Apple ID (whichever you preferred to download the app)
  • • Name, Gender, Date of Birth, Place of Birth, Time of Birth

This information is used to create your ASTAIRO profile, identify your horoscope, generate personal insights, and communicate with you through or about ASTAIRO (updates, your requests). This data is processed within the scope of contract performance and provision of ASTAIRO services.

2. Technical Data

  • • IP address, log records, device type and name, operating system, type and date of subscription

This data is processed for ensuring app functionality, detecting crashes and errors, conducting technical analysis, carrying out activities in accordance with legal requirements, and ensuring technical data security.

3. Customer Transactions

  • • Subscription plan, billing cycle

This data is processed to determine the user's subscription plan, to provide and improve services and membership plans. Credit card information is not collected by us.

4. Photos and Images

If you choose to use features related to visuals, you may upload a photo or image. Prior to accessing your device's camera or photo gallery, the app will request your permission. Images provided are processed in real time and are not stored on our servers. They remain solely on your device and are used exclusively for enabling relevant app functionalities.

5. Marketing and Analytics Data

  • • Analytics data (session duration, feature interaction), user preferences (language, theme), identifiers, in-app interactions, marketing emails or ads

This data is processed to deliver and personalize in-app content, run promotional campaigns, measure marketing performance, and obtain insights to improve our products and features. We may send marketing notifications and use advertising identifiers (IDFA on iOS, GAID on Android, Firebase, Appsflyer). These data are processed for marketing purposes, personalized content, and product development insights. You may withdraw your consent at any time.

6. Information Disclosed by Users

In accordance with the data minimization principle adopted under GDPR, ASTAIRO takes care not to process any data unnecessary for the application. Data not required within the app but shared through contact or other means are deemed disclosed by users. Such data are also protected under the applicable legislation.

2. Age Restriction and Parent/Guardian Use

ASTAIRO is not intended for users under the age of 13. If you are under 13, please do not use or access the app or website at any time. By using the app and website, you affirm that you are over the age of 13. Parents and guardians are strongly encouraged to notify ASTAIRO if they become aware that their children under 13 are using the app.

In accordance with the Children's Online Privacy Protection Act ("COPPA"), no information is collected from children under 13. For users under 18, parental/guardian consent is required.

3. Sharing of Information

Your personal data will not be sold, transferred, or otherwise shared with third parties for commercial purposes. Your data may be transferred only for the purposes explained below:

Mobile App Stores:

We use Google and Apple services (depending on where you download the app) for you to download, log in and update the app. Transfers to these providers are carried out in compliance with GDPR data transfer rules and safeguards.

IT, Hosting and Analytics Service Providers:

We may share your data with trusted third-party service providers who assist us in delivering and improving our services. This includes cloud infrastructure, analytics, and app performance tools. Google Cloud and Firebase are used for data storage, hosting, and backend support; Appsflyer is used for analytics and user engagement insights.

Legal, Tax and Financial Advisors:

We may share your data with legal, tax, and financial advisors for professional consultancy, limited to what is necessary and in compliance with GDPR.

Public Authorities:

We may disclose your personal data to legally authorized public institutions and government authorities in compliance with applicable laws, regulations, or judicial/administrative decisions.

Anonymized Data:

Anonymized data may be used for analytical purposes. Anonymization is carried out in such a way that the data can no longer be linked to a specific individual.

4. Storage of Information

We are committed to ensuring that your personal data is stored securely and in compliance with applicable laws.

Retention Period:

Personal data will be retained only as long as necessary for the purposes for which it was collected, and in accordance with statutory retention periods. Once expired, data will be securely deleted or anonymized.

Access Control:

Access to personal data is restricted to authorized personnel who require it to perform their duties. Strict access controls are implemented to prevent unauthorized access.

Data Deletion and Anonymization:

When personal data is no longer necessary or the retention period has expired, data will be securely deleted or anonymized.

5. Security Measures

We take GDPR-compliant measures to ensure the protection of your personal data:

  • • Access only by authorized personnel
  • • Regular security audits
  • • Application of the data minimization principle
  • • An incident response plan in case of potential data breaches

Since digital environments cannot be entirely secure, users are encouraged to take their own precautions (up-to-date antivirus software, secure firewall, safe Wi-Fi, etc.).

In the event of any data breach, you may notify IANDROOTS immediately.

6. Corporate Affiliates and Business Sale

In the event of a sale, merger, or transfer of all or substantially all assets of ASTAIRO or its corporate affiliates, personal data may be transferred to third parties. Such affiliates will process your data in accordance with this Policy.

7. User Rights

Under the Personal Data Protection Law of Turkey (KVKK), the General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA), users have the following rights:

  • • Right of Access
  • • Right of Rectification
  • • Right to Erasure
  • • Right to Restrict Processing
  • • Right to Data Portability
  • • Right to Object
  • • Right to Object to Automated Decision-Making

To exercise these rights, you must send an e-mail or written request clearly stating the right you wish to exercise along with your name and contact details. A response will be provided within the legal timeframe.

8. Updates to Privacy Policy

This Privacy Policy may be updated due to app changes, legal obligations, or operational needs. Users are encouraged to review it regularly. Updates will take effect immediately upon publication. If you do not agree with the amendments, you should discontinue using the app. This Policy is valid as of the first use of the app by the user.

9. Contact

This Privacy Policy represents the entire understanding between you and us regarding the collection, use and protection of your personal data. For any questions or concerns, please contact us:

E-mail: info@iandroots.com