AugmentedWorks

Privacy Policy and Personal Data Text

“IntelliClean ™”

Update Date: March 16, 2025

AugmentedWorks (“AugmentedWorks” or “Company”) processes the personal data of users in accordance with general principles of privacy and applicable data protection laws and regulations.

Your personal data, which you provided/will provide to our Company and/or obtained by our Company by any external means, may be processed by our Company as “Data Controller”:

In the context of the objective of processing your personal data and in connection with this purpose, in a limited and measured manner,
By maintaining the accuracy and up-to-date version of the personal data as reported or notified to our Company,
May be recorded, stored, preserved, reorganized and be transferred to the institutions authorized to request such personal data by law and shall be transferred, classified and shared with third parties within the country or abroad under the conditions stipulated by legislation, and they may be processed by other means listed under the legislation and be subject to other procedures set forth in the legislation.

This Privacy Policy is adopted for the continuance and improvement of the activities carried out by AugmentedWorks in line with the principles set forth in the PDP Law.

This Privacy Policy describes which data we collect, how we intend to use, store, protect and share the data we collect, how you can withdraw your consent for the processing of these data and how you can correct and revise the data.

1. Collection of Personal Data and Method

AugmentedWorks may process your personal data for the purposes specified in this Privacy Policy.

The personal data of users collected and used by AugmentedWorks in particular, are as follows: your name and surname, e-mail address, phone number (which we will receive if/when you contact AugmentedWorks), and device-specific identifiers (e.g., Identifier for Advertisers designated in your mobile device used in accessing our services (IDFA), identifier for vendors/developers designated your mobile device (IDFV), and Internet Protocol Address (IP Address)) when you use IntelliClean ™ (“Application” or “IntelliClean ™”).

We do not use or integrate any Google APIs in IntelliClean ™. Therefore, we do not collect or process any Google user data via Google API services.

2. Data Categories and Data Types

Data Category	Data Types
Identity Information	Name and surname
Contact Information	E-mail address, phone number
Process Security	Internet traffic data (network movements, IP address, visit data, time and date information), general location data (e.g., country and/or city), device name, log data, in-app purchase history, IDFA (if you provide permission), IDFV
Customer Transaction	Order information
Marketing Data	IDFA, IDFV

We may collect your above-mentioned data directly from you through electronic or physical mediums, your mobile device, third-party applications or sources where you can access our Application (such as Apple App Store, Google Play Store, Amazon App Store, etc., together referred to as “App Stores”), for the purposes of compliance with legal obligations, enhancing our services, administering your use of our services, as well as enabling you to enjoy and easily navigate our services.

We may collect log data generated while you are using our services/applications (through our products or third-party products). This Log Data may include information such as your device’s IP address, device name, operating system version, configuration of the app when utilizing our service/application, the time/date of your use, and other statistics.

3. General Principles Regarding Personal Data Processing

In accordance with this Privacy Policy, personal data are processed by AugmentedWorks as a data controller in line with the following basic principles:

Being in accordance with law and good faith
Being accurate and, where necessary, up-to-date
Being processed for specific, explicit and legitimate purposes
Being limited for the purpose for which they are processed and data minimization
Being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed

4. Purposes of Processing Personal Data and Legal Reasons

Your personal data will be processed via automatic or non-automatic means for the purposes stated below, in accordance with the applicable legislation and Articles 5 and 6 of the PDP Law where it is expressly permitted by the laws, the establishment of a contract or direct relation to the execution or performance of the contract, and for the legitimate interests of AugmentedWorks provided that your fundamental rights and freedoms are protected.

Data Category	Purposes of Processing Personal Data
Identity Information Contact Information	Execution of activities in compliance with legislation Execution of company/product/service commitment operations Execution of communication activities Execution/auditing of business activities Conducting after-sales support services for goods/services Execution of goods/services sales processes Conducting storage and archive activities Execution of agreement processes
Process Security	Execution of information security processes Conducting audit/ethical activities Execution/audit of business activities Conducting activities to ensure business continuity Providing information to authorised persons, institutions and organisations
Customer Transaction	Execution/auditing of business activities Conducting after-sales support services for goods/services Execution of goods/services sales processes Conducting activities for customer satisfaction Execution of agreement processes
Marketing Data	Conducting marketing analysis studies Execution of advertising/campaign/promotion processes

The purposes of processing personal data may be updated in line with our obligations arising from our company policies and legislation; in particular:

Creating user accounts for the service recipients/application users,
Customising our Services, understanding our users and their preferences to enhance user experience and enjoyment using our Services,
Informing about new products, services and applications and delivering you information regarding advertisements and promotions,
Carrying out digital subscription and in-app purchase processes of service recipients,
Carrying out auto-renewable subscriptions for giving users access to content, services, or premium features in our service,
Carrying out the processes of information security,
Conducting activities in accordance with legislation,
Fulfilling the demands of competent authorities,
Conducting the processes of finance and accounting transactions,
Conducting communication activities,
Conducting the processes of contracts,
Carrying out strategic planning activities,
Following up requests and complaints.

Legal Reasons

Identity Information, Contact Information, Customer Transaction: It is necessary to process your personal data, provided that we establish a contractual relationship with you, or that it is directly related to our performance obligation arising from this contract. We have to process data in order to establish a right for you, to exercise and protect this right.
Process Security: The law explicitly stipulates the process by which we process your personal data, or conditions that are necessary in order to fulfil our legal obligation.
Marketing Data: Your explicit consent (which may be acquired via your device settings or upon first launch of the app), especially for using IDFA or IDFV for promotional/marketing purposes.

5. Third Party Websites and Applications

IntelliClean ™ may contain links to other websites that are unknown to AugmentedWorks and whose content is not controlled by us. These linked websites may contain terms and conditions other than AugmentedWorks texts. AugmentedWorks cannot be held responsible for the use or disclosure of information that these websites may process. Likewise, AugmentedWorks shall not have any responsibility for any links from other sites provided to IntelliClean ™.

6. Cookies

Cookies are small text files that are stored on the browser or hard drive of your computer or mobile device when you visit a webpage or application. Cookies allow a website to run more efficiently in addition to ensuring the presentation of personalised web pages, making your visit experience faster and more suited to your specific personal needs and demands. Containing only data on your website visit history via the internet, cookies do not collect any information, including your personal data/files stored on your computer or mobile device.

We may use cookies when it is necessary for operating our services, to enhance our service performance and functionality, and to deliver content, including ads, relevant to your interests, on our sites or on third-party sites. You can delete cookies that are already present on your computer and prevent the placement of cookies on your internet browser.

Internet browsers are typically predefined to automatically accept cookies by default. As the management of cookies varies from browser to browser, you may look at the help menu of the browser or application to get detailed information on adjusting your cookie settings.

7. Push Notifications

AugmentedWorks may occasionally send you push notifications via its mobile applications regarding application upgrades or notifications about our services. You can always edit such communication preferences or stop receiving such communications through the settings on your device.

8. Data Retention

Your data will be stored for the duration specified in the applicable legislation or for a reasonable time until the purpose of processing ceases to exist, or during legal periods of limitation.

AugmentedWorks may continue to store your personal data, even after the expiry of the purpose of its use, provided that it is required by other laws or a separate consent granted by you in this regard.

In cases that you allow AugmentedWorks to store your personal data for an additional time by giving your consent, such data shall be immediately deleted, destructed, or anonymized upon the expiry of such additional time or once the purpose of processing no longer exists.

9. Technical and Administrative Measures

AugmentedWorks stores the personal data it processes in accordance with relevant legislation for periods stipulated or required for the purpose of processing. AugmentedWorks undertakes to take all necessary technical and administrative measures and to show due care to ensure the confidentiality, integrity, and security of personal data. In this context, it takes the necessary measures to prevent unlawful processing of personal data, unauthorized access to data, unlawful disclosure, modification, or destruction of data. Accordingly, AugmentedWorks takes the following technical and administrative measures regarding the personal data it processes:

User identifications. AugmentedWorks employees' authorization to AugmentedWorks systems is limited only to the extent necessary by their job descriptions; in case of any change of authority or duty, systemic authorizations are also updated.
Information security threat and event management. Events that occur on AugmentedWorks servers and firewalls are transferred to an information security threat and event management system. This system alerts the responsible staff when a security threat occurs and allows them to respond immediately to the threat.
Encryption. Sensitive data is stored with cryptographic methods and, if required, transferred through encrypted environments, with cryptographic keys stored in secure and distinct environments.
Logging. All transaction records regarding sensitive data are securely logged.
Two-factor authentication. Remote access to sensitive data is allowed only through at least two-factor authentication.
Information Security Management System (ISMS). ISMS-related topics are audited regularly at AugmentedWorks. Responsible directors review compliance with control points.
Training. In order to increase employee awareness and minimize the human factor in information violation incidents, training is provided to employees at regular intervals.
Physical data security. Personal data on paper is necessarily stored in locked cabinets and accessed only by authorized persons. Adequate security measures (for situations such as electrical leakage, fire, flooding, theft, etc.) are taken based on the nature of the environment where sensitive data is stored.
Backup. AugmentedWorks periodically backs up the data it stores using both in-house backup solutions and cloud-based infrastructure that comply with relevant legislation.
Non-disclosure agreement. Non-disclosure agreements are concluded with employees engaged in sensitive personal data processing.
Transfer of sensitive personal data. If transfer of sensitive personal data is required via email, such transfer is conducted through an encrypted corporate email or via a secure registered email system.

In the event that the personal data is damaged as a result of attacks on IntelliClean ™ or on the AugmentedWorks system, despite AugmentedWorks taking necessary information security measures, or the personal data is obtained by unauthorized third parties, AugmentedWorks will immediately notify users and, if necessary, the relevant data protection authority and take all required measures.

10. Transferring Personal Data to Third Parties

The procedures and principles to be applied for transferring of personal data are regulated in Articles 8 and 9 of the PDP Law. The personal and special categories of data of the user may be transferred to third parties within the country or abroad, since we may use servers and cloud systems located abroad.

Your personal data may be transferred for the following reasons:

Conducting storage and archive activities
Conducting business activities
Conducting after-sales support services for goods/services
Managing customer relationship management processes

Specifically, we may use third-party service providers and partners to provide data processing services on our behalf (e.g., AdMob for serving advertisements and PostHog for analytics), to manage certain features of our services, or to help us analyze how our services are used. These third parties may access and process your personal data for the purposes described in this Privacy Policy, under strict obligations of confidentiality and appropriate security measures.

11. Your Rights as the Data Subject

Pursuant to Article 11 of the PDP Law, you may request the following regarding your personal data by applying to AugmentedWorks:

Learn whether or not your personal data have been processed;
Request information as to processing if it has been processed;
Learn the purpose of the processing of personal data and whether data are used in accordance with their purpose;
Know the third parties in the country or abroad to whom your personal data have been transferred;
In case the personal data is processed incompletely or inaccurately, request notification of the transactions made under this scope to third parties to whom personal data have been transferred;
Request deletion, destruction or anonymization of personal data if the reasons for the processing have disappeared and request notification of the transactions made under this scope to third parties to whom personal data have been transferred;
Object to occurrence of any result that is to your detriment by means of the analysis of personal data exclusively through automated systems;
Request compensation for the damages in case you incur damages due to unlawful processing of your personal data.

Where the General Data Protection Regulation (“GDPR”) is applicable, data subjects have the following rights:

Right of access – Learning whether personal data is being processed and, if so, accessing your personal data and the information regarding its processing.
Right to correction – To request the correction of information that you believe is inaccurate, or the completion of information that you believe is incomplete, by AugmentedWorks.
Right to delete – To request deletion of personal data under the conditions stipulated in GDPR.
Right to restrict processing – To request the restriction of the processing of personal data under the conditions stipulated in the GDPR.
Right to object to processing – To object to the processing of personal data under the conditions stipulated in the GDPR.
Right to data portability – To request the data collected by AugmentedWorks to be transferred directly to another organisation, under certain conditions.
Objection to automatic processing – To object to the occurrence of a result against you by analyzing the processed data exclusively through automatic systems, including profiling.

In the application that includes your explanations about the right you have as the data subject and that you request to exercise; your request must be explicit and understandable. If the subject of your request is related to you or if you are acting on behalf of someone else, you must be specially authorised in this regard and your authority must be documented. The application must contain identity and address information, and documents proving your identity must be attached to the application.

Our Company will enable you to file such requests through the “Data Subject Application Form” or by contacting us at info@augmentedworks.com. In accordance with Article 13 of the PDP Law, our Company will finalise your requests, free of charge, within 30 (thirty) days at the latest depending on the nature of the request. In case the request is rejected, the reason or reasons for the rejection will be notified in writing or electronically along with its justification.

If you believe that we or someone to whom we have transferred your data is violating your rights, you can file a complaint to the data protection authority in your country and to other competent supervisory authorities.

12. Updates to This Privacy Policy

This Privacy Policy may be revised by AugmentedWorks when deemed necessary. If you continue to use IntelliClean ™ or otherwise access or use our services after a notification or update is provided regarding such revisions, it shall be deemed that you have allowed the changes in this Privacy Policy. You can always access the most up-to-date version of this Privacy Policy at www.augmentedworks.com or by contacting us at info@augmentedworks.com.