Privacy Policy

APPSYNERGY YAZILIM HİZMETLERİ A.Ş.

PRIVACY POLICY

Effective Date: 5 September 2026

1. Introduction and Scope

This Privacy Policy explains how AppSynergy Yazılım Hizmetleri A.Ş. (“AppSynergy,” “we,” “us,” or “our”) collects, uses, processes, stores, shares, and protects information when you access or use our mobile applications, websites, and related digital services (collectively, the “Services”).

This Privacy Policy applies to all Services published, operated, or provided by AppSynergy.

The information we process depends on the features you choose to use and the permissions you grant. We process information only as reasonably necessary to provide, maintain, secure, personalize, analyze, and improve the relevant Services and features.

We do not require users to provide their name or email address as part of the ordinary use of our mobile applications.

Our mobile applications may, however, create technical identifiers in the background in order to operate features such as subscriptions, usage limits, cloud functionality, service continuity, analytics, or abuse prevention. These identifiers are described below.

If you voluntarily contact us for support, privacy requests, feedback, or another inquiry, we may process the information you choose to provide in that communication.

Where consent or permission is required by applicable law or platform requirements, we request it before the relevant processing occurs.

This Privacy Policy should be read together with our Terms & Conditions, Cookie Policy, Refund Policy, and any additional notices presented in connection with specific features.

2. Information We Process and How We Obtain It

Depending on the features you use, we may process:

Information you voluntarily provide;
Game, test, challenge, score, achievement, and progress information;
Anonymous user identifiers and device identifiers;
Device, usage, technical, crash, and performance information;
Subscription and transaction-related information;
Analytics, attribution, and permitted advertising information;
Images you voluntarily capture or upload;
Questions, prompts, and conversations submitted to AI-powered features;
Health, fitness, activity, sleep, nutrition, hydration, wellness, and related information when you enable features requiring such information;
Information obtained from authorized health platforms or connected devices; and
Scores, estimates, recommendations, classifications, summaries, or other insights generated from information processed through the Services.

We obtain information:

Directly from you, when you use games, tests, questionnaires, AI tools, image-based features, health or wellness features, or contact us;
Automatically from your device, through application events, diagnostics, performance tools, analytics technologies, and permitted identifiers;
From authorized third-party platforms, such as Apple Health, after you grant permission; and
From application marketplaces, such as Apple or Google, in connection with purchases and subscriptions.

We do not collect every category described above from every user.

3. Anonymous User and Device Identifiers

Our mobile applications do not require conventional account registration using a name, email address, username, or password.

However, certain technical identifiers are used to operate the Services.

Anonymous User Identifier

We may create a Firebase Anonymous Authentication UID in the background.

This anonymous identifier may be used for purposes including:

Service functionality;
AI usage quotas;
Subscription entitlement association;
Cloud Functions;
Abuse prevention;
Service continuity; and
Related technical operations.

The anonymous Firebase UID does not require you to provide your name or email address.

First-Party Device Identifier

We may also process a first-party device identifier, such as Apple’s Identifier for Vendor (“IDFV”), or a locally generated device identifier where necessary.

This may be used for:

Usage management;
Free-tier quotas;
Service continuity;
Backup or restoration functionality;
Fraud or abuse prevention; and
Other first-party application functionality.

A first-party device identifier used for these purposes is not itself used by AppSynergy for cross-company advertising tracking.

4. Games, Tests and User-Provided Information

When you use games, cognitive exercises, tests, challenges, quizzes, assessments, or similar interactive features, we may process:

Responses;
Scores;
Test results;
Game sessions;
Performance statistics;
Completion status;
Progress;
Difficulty levels;
Achievements and rewards;
Feature interactions; and
Usage frequency.

We use this information to provide the relevant feature, calculate results, display progress, personalize content or difficulty where applicable, understand product performance, and improve the Services.

You may also voluntarily provide information such as:

Preferences;
Goals;
Lifestyle information;
Nutrition information;
Wellness information;
Age or age range where relevant;
AI prompts;
Questionnaire responses; and
Images.

Game results, cognitive scores, personality-related results, and similar assessments are intended for informational, entertainment, educational, or self-development purposes unless expressly stated otherwise.

They are not medical, psychological, psychiatric, or clinical diagnoses.

5. Device, Usage, Crash and Performance Information

When you use the Services, certain technical information may be processed automatically, including:

Device type and model;
Operating system;
Application version;
Language and region;
IP address;
Browser information when using our websites;
Installation or device identifiers where permitted;
Session information;
Features and screens used;
Application interactions;
Application initialization and performance information;
Crash reports;
Non-fatal error reports;
Error logs; and
Diagnostic information.

We currently use technologies including Firebase Analytics, Firebase Crashlytics, and Firebase Performance for analytics, crash reporting, performance measurement, debugging, and product improvement.

Crash or performance information is not used by AppSynergy for targeted advertising.

An IP address may indicate an approximate geographic area. We do not treat IP-derived general location as precise geolocation.

6. Purchases, Free Trials and Subscriptions

The Services may offer subscriptions, premium functionality, free trials, in-app purchases, or other paid features.

Payments made through our mobile applications are generally processed by the applicable marketplace, such as the Apple App Store or Google Play Store.

We may receive limited transaction-related information, including:

Product or subscription identifier;
Transaction identifier;
Purchase status;
Trial status;
Subscription status;
Renewal status; and
Expiration information.

We may use service providers such as RevenueCat to manage subscription entitlements and related subscription functionality.

Subscription information may be associated with an anonymous technical identifier so that the correct entitlement can be provided.

AppSynergy does not ordinarily receive your full payment-card information for purchases processed by Apple or Google.

7. Analytics, Advertising, Attribution and Device Tracking

We use analytics and attribution technologies to understand how the Services are used, evaluate product and marketing performance, identify technical issues, and improve functionality.

This may involve:

Application interactions;
Product interactions;
Installation information;
Device information;
Campaign or attribution information;
Advertising interaction information; and
Permitted device identifiers.

IDFA and App Tracking Transparency

Where you grant permission through Apple’s App Tracking Transparency (“ATT”) framework, Apple’s Identifier for Advertisers (“IDFA”) may become available to authorized advertising partners such as Google AdMob for personalized advertising and related advertising measurement.

Tracking that requires ATT permission does not begin before the applicable ATT authorization process.

If you do not grant ATT permission:

We do not use IDFA for personalized advertising;
IDFA is not made available for that purpose; and
Advertising is requested without IDFA-based personalized advertising.

The first-party IDFV described above is distinct from IDFA and may continue to be used for legitimate first-party functionality.

Health Data and Advertising

Regardless of your advertising choices:

Health Information obtained through Apple Health or HealthKit is not used for targeted advertising, behavioral advertising, advertising audience creation, or health-based marketing profiling.

8. Cookies and Similar Technologies

Our websites and web-based Services may use:

Cookies;
Pixels;
Tags;
SDKs;
Local storage; and
Similar technologies.

These technologies may be used for:

Essential functionality;
Security;
Preferences;
Analytics;
Performance measurement; and
Permitted advertising or marketing activities.

Where legally required, optional tracking technologies are used only after the applicable consent has been obtained.

Please review our Cookie Policy for further information.

HEALTH AND WELLNESS INFORMATION

9. Health, Fitness and Wellness Information

When you enable functionality that relies on health, fitness, activity, sleep, nutrition, hydration, wellness, lifestyle, or similar information, we process the information reasonably necessary to provide that functionality.

For purposes of this Privacy Policy, such information is referred to collectively as “Health Information.”

Health Information may include:

Information you voluntarily provide;
Information obtained from an authorized health platform or connected device;
Activity or exercise information;
Sleep information;
Nutrition or meal information;
Hydration information;
Body-related measurements;
Lifestyle or wellness information; and
Scores, estimates, trends, recommendations, classifications, or inferences generated from such information.

Health Information may qualify as sensitive, special-category, or consumer health data under applicable privacy laws.

We apply additional safeguards to this information because of its sensitive nature.

10. Apple Health and HealthKit

When you enable Apple Health integration, the Service may access authorized health and fitness information stored in Apple Health through Apple HealthKit.

Access occurs only after you grant permission through Apple’s Health authorization interface.

Depending on the functionality you enable and the categories you authorize, the Service may process information relating to:

Activity and steps;
Walking or running;
Exercise and workouts;
Energy expenditure;
Heart rate or related fitness metrics;
Sleep;
Body measurements;
Nutrition;
Hydration; and
Other health or fitness categories specifically presented through Apple’s permission interface.

The Service does not automatically receive access to all information contained in Apple Health.

You control which categories the Service may access.

You may grant, deny, or revoke permissions through Apple Health or your device settings.

Revoking permission prevents future access to the affected category but does not automatically delete information that was previously and lawfully processed outside HealthKit. You may separately request deletion where applicable.

11. How We Use and Protect Health Information

Health Information is used only for health, fitness, wellness, lifestyle, and related functionality requested by the user.

Depending on the feature, this may include:

Displaying health or wellness information;
Analyzing activity or lifestyle patterns;
Generating personalized wellness insights;
Calculating biological-age or longevity-related estimates;
Providing progress analytics;
Generating goals, habits, journeys, or missions;
Providing nutrition, sleep, hydration, activity, or fitness insights;
Personalizing health or wellness functionality;
Generating AI-assisted responses requested by you;
Maintaining and troubleshooting health-related functionality; and
Improving the relevance and quality of such functionality.

We do not use Health Information obtained through Apple Health or HealthKit:

For targeted or behavioral advertising;
For advertising audience creation;
For health-based marketing profiles;
For advertising-related data mining;
To sell information to advertisers;
To sell information to data brokers or information resellers; or
For unrelated marketing purposes.

We do not sell Health Information.

Personal Health Information obtained through HealthKit is not stored by AppSynergy in Apple iCloud.

12. Health Scores, Biological Age and Other Inferences

The Services may analyze authorized information to generate estimates or personalized outputs including:

Biological-age estimates;
Longevity indicators;
Wellness scores;
Lifestyle assessments;
Habit scores;
Nutrition insights;
Sleep insights;
Activity or fitness indicators; and
Personalized recommendations.

These outputs may themselves constitute Health Information because they can infer information about an individual’s health or wellbeing.

Such results are estimates for informational and wellness purposes.

Their accuracy may depend on the accuracy, availability, and completeness of the underlying information.

They are not medical diagnoses.

13. Reproductive and Sexual Health Information

Our Services are not designed to intentionally access reproductive or sexual health information from connected health platforms unless a feature expressly requires such processing.

We do not intentionally transmit reproductive, fertility, pregnancy, sexual health, or similar highly sensitive information to third-party AI providers where it is not necessary for functionality expressly requested by the user.

If a feature requires such processing, we will provide an appropriate disclosure and obtain any additional permission or consent required by applicable law or platform requirements.

We do not use reproductive or sexual health information for:

Advertising;
Behavioral targeting;
Data brokerage;
Sale to third parties; or
Health-based marketing profiling.

ARTIFICIAL INTELLIGENCE AND IMAGE PROCESSING

14. Artificial Intelligence Features

The Services may include artificial intelligence-powered functionality used to generate:

Responses;
Recommendations;
Explanations;
Analyses;
Summaries;
Personalized insights;
Coaching-style guidance;
Image analyses; and
Other outputs requested by you.

When you actively use an AI feature, we process the information reasonably necessary to provide the requested functionality.

This may include:

Your prompt or question;
Information contained in your message;
Relevant conversation history;
Relevant information you voluntarily provided;
Relevant preferences, scores, or results; and
Where applicable and authorized, relevant Health Information.

We apply data-minimization principles and seek to use only information reasonably necessary for the requested AI functionality.

15. OpenAI and Third-Party AI Processing

Certain AI-powered and image-analysis features use artificial intelligence technology provided by OpenAI.

When you choose to use such functionality, information reasonably necessary to generate the requested output may be transmitted to and processed by OpenAI.

Depending on the feature, this may include:

Your prompt or question;
Text you submit;
An image you submit;
Relevant application context; or
Relevant authorized Health Information where required for the functionality you request.

Where required by applicable law or platform requirements, we provide an appropriate disclosure and obtain the required permission before transmitting Personal Information or Health Information to an external AI provider.

We seek to transmit only the information reasonably necessary to perform the requested function.

We do not authorize OpenAI or other AI providers acting on our behalf to use Health Information for:

Advertising;
Targeted marketing;
Advertising audience creation;
Advertising profiling;
Data brokerage; or
Sale of Health Information.

Third-party AI processing is also subject to the applicable technical, security, and retention arrangements governing the services used by AppSynergy.

16. AI Conversations, Usage Logs and Retention

Where conversational AI functionality is provided, conversation history may be processed where necessary to:

Maintain conversational continuity;
Provide relevant context;
Allow access to prior interactions where supported;
Operate the feature;
Maintain security;
Prevent abuse; or
Troubleshoot technical problems.

When AI functionality is used, we may also maintain limited technical usage logs for purposes such as:

Usage quota enforcement;
Security;
Abuse prevention;
Cost and token monitoring;
Debugging; and
Technical quality assurance.

Such logs may include information such as:

A hashed version of an anonymous user identifier;
Hashed or limited output metadata;
Token or usage information; and
Technical timestamps.

These technical AI usage logs are generally retained for approximately 30 days, subject to legitimate security, legal, fraud-prevention, or technical requirements.

They do not contain the original food-scan image.

Information processed by an external AI provider may also be subject to the provider’s applicable technical retention and security practices.

17. Images, Camera Features and Food Analysis

When you choose to use an image-based feature, we process the image you voluntarily capture or upload in order to provide the requested functionality.

Image processing may be used to:

Identify food or meal components;
Analyze food images;
Estimate nutritional characteristics;
Generate health or wellness-related information about a meal;
Identify other objects or content; or
Provide another image-based feature requested by you.

For food or image analysis:

The image may be compressed or otherwise technically processed on your device before transmission;
Image metadata such as EXIF information is not intentionally required for the analysis;
The image may be transmitted through AppSynergy infrastructure to an authorized AI provider such as OpenAI;
AppSynergy does not store the submitted image in persistent application storage after the analysis request has been completed; and
The image itself is not included in the retained AI usage log described above.

A request may be authenticated using an anonymous user identifier or device identifier for purposes such as quota enforcement, security, or abuse prevention. This does not mean that AppSynergy maintains a persistent archive of the submitted image.

Health- or nutrition-related conclusions generated from images are not used for targeted advertising based on your health.

You should avoid submitting unrelated individuals, identification documents, financial information, private medical records, or other unnecessary sensitive information in images.

USE, SHARING AND STORAGE

18. How We Use and Share Information

We use information processed through the Services to:

Provide and maintain the Services;
Deliver requested functionality;
Calculate scores and results;
Display progress;
Personalize features;
Operate health, wellness, or AI-powered functionality;
Manage subscriptions;
Enforce usage quotas;
Perform analytics;
Detect technical issues;
Maintain security;
Prevent fraud and abuse;
Improve product functionality and usability;
Respond to support and privacy requests;
Comply with applicable law; and
Establish, exercise, or defend legal rights.

We do not sell Personal Information for monetary consideration.

We may share information with the following categories of recipients where necessary:

Service and Infrastructure Providers

Providers that support cloud infrastructure, authentication, databases, analytics, crash reporting, performance monitoring, subscription management, communications, security, AI processing, image processing, attribution, or advertising.

Our current technology stack may include providers such as:

Google Firebase, including Anonymous Authentication, Analytics, Crashlytics, Performance, and related infrastructure;
RevenueCat, for subscription entitlement management;
OpenAI, for certain AI and image-processing functionality;
Google AdMob, for advertising; and
Apple, Google, and other application marketplaces or platform providers.

At Your Direction

We may disclose information where you expressly request or authorize us to do so.

Legal and Security Purposes

We may disclose information where required by applicable law, valid legal process, or where reasonably necessary to protect users, AppSynergy, or the Services from fraud, abuse, security threats, or unlawful conduct.

Corporate Transactions

Information may be transferred in connection with a merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction, subject to applicable privacy protections.

HealthKit-derived Health Information is not provided to advertising networks, data brokers, or information resellers for advertising or marketing purposes.

We may use aggregated or properly de-identified information for analytics, research, security, and product improvement where such information can no longer reasonably identify an individual.

19. Storage, International Transfers and Retention

Depending on the functionality involved, information may be processed:

Locally on your device;
On infrastructure operated or contracted by AppSynergy; or
By authorized third-party providers required to provide the functionality you request.

AppSynergy is established in Türkiye.

Our authorized service providers may process information in Türkiye, the European Economic Area, the United States, or other jurisdictions.

As a result, Personal Information may be processed outside the jurisdiction where you reside.

Where required by law, we use appropriate contractual, organizational, technical, or other legally recognized safeguards for international transfers.

We retain Personal Information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

For example:

Game, test, and progress information may be retained as necessary to provide the relevant functionality;
Health and wellness information may be retained where necessary for historical trends and personalization;
AI conversation information may be retained where necessary to provide continuity or requested functionality;
Limited AI technical usage logs are generally retained for approximately 30 days;
Subscription and transaction information may be retained for legal, accounting, tax, fraud-prevention, or dispute-resolution purposes;
Crash and performance information may be retained for troubleshooting, analytics, security, and service improvement; and
Properly aggregated or de-identified information may be retained for longer where it no longer reasonably identifies an individual.

We periodically review retained information and delete or de-identify information that is no longer reasonably necessary.

20. Security

We use reasonable administrative, organizational, and technical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, loss, destruction, or misuse.

Depending on the type of information and feature, safeguards may include:

Encryption;
Secure transmission;
Access controls;
Authentication and authorization controls;
Data minimization;
Logging and monitoring;
Secure software-development practices;
Vendor controls; and
Incident-response procedures.

Health Information and other sensitive information receive additional protection appropriate to their nature.

No electronic system, network, or storage method can be guaranteed to be completely secure.

If a security incident affecting Personal Information occurs, we will investigate and provide notices where required by applicable law.

Security concerns may be reported to:

support@appsynergy.co

USER CONTROL AND PRIVACY RIGHTS

21. Your Choices, Data Deletion and Regional Privacy Rights

You control many permissions through your device and operating system.

Depending on the features you use, you may:

Grant or revoke Apple Health access;
Grant or revoke camera or photo access;
Grant or decline App Tracking Transparency permission;
Manage advertising permissions;
Manage notifications;
Choose whether to use AI-powered functionality;
Decline AI-related processing where consent is required;
Manage cookies through your browser; and
Stop providing optional information.

Choosing not to provide information required for an optional feature may prevent that feature from functioning.

Data Deletion

Where available, you may use an in-app deletion function.

You may also submit a privacy or deletion request to:

support@appsynergy.co

We will delete, anonymize, or otherwise address Personal Information as required by applicable law.

Certain information may be retained where necessary for:

Legal compliance;
Taxation or accounting;
Fraud prevention;
Security;
Dispute resolution; or
Establishment or defense of legal claims.

Because our mobile applications do not ordinarily require a conventional account containing your name or email address, we may request limited technical information where reasonably necessary to identify data associated with your request.

Any information obtained solely to verify a privacy request is used only for that purpose.

European Economic Area, United Kingdom and Switzerland

Where the GDPR or equivalent European privacy law applies, legal bases may include:

Performance of a contract or requested Service;
Consent;
Explicit consent for Health Information or other special-category data where required;
Legitimate interests, including security, fraud prevention, service reliability, debugging, and appropriate analytics; and
Compliance with legal obligations.

Applicable rights may include:

Access;
Rectification;
Erasure;
Restriction;
Data portability;
Objection;
Withdrawal of consent; and
The right to lodge a complaint with a competent supervisory authority.

Türkiye – KVKK

Where the Turkish Personal Data Protection Law No. 6698 (“KVKK”) applies, AppSynergy acts as the data controller.

Health Information and certain related information may constitute special-category personal data (özel nitelikli kişisel veri).

Such information is processed only where the conditions required by applicable law are satisfied and subject to appropriate technical and organizational safeguards.

Where explicit consent is required, it is requested separately.

United States

Residents of certain U.S. states may have additional rights, including:

Access;
Correction;
Deletion;
Data portability;
Opt-out rights concerning certain sales, sharing, targeted advertising, or profiling;
Appeal rights concerning certain privacy requests; and
The right to exercise privacy rights without discriminatory treatment.

Where permitted by applicable law, an authorized agent may submit a request on your behalf, subject to reasonable verification.

Where consumer-health-data laws apply, we limit collection and use to disclosed or permitted purposes, provide applicable rights and safeguards, and do not use consumer health data for targeted advertising.

AppSynergy does not sell Health Information.

Where applicable law requires a separate Consumer Health Data Privacy Notice, we may provide such a notice in addition to this Privacy Policy.

Where legally recognized universal opt-out mechanisms such as Global Privacy Control (“GPC”) apply, we process those signals in accordance with applicable legal requirements.

22. Children, Medical Disclaimer, Changes and Contact

Children and Minors

Our Services are not intended to knowingly collect Personal Information from children in violation of applicable law.

Age requirements may vary depending on the Service or feature.

Features involving sensitive Health Information, individualized health or longevity analysis, or AI-powered personalized health and wellness guidance may be restricted to users aged 18 or older.

If we learn that Personal Information has been collected from a child where legally required parental or guardian authorization was not obtained, we will take reasonable steps to delete it.

Health, Wellness and AI Disclaimer

Certain Services provide informational functionality relating to:

Health;
Fitness;
Nutrition;
Wellness;
Lifestyle;
Cognitive exercises;
Biological-age or longevity estimates;
Assessments; or
AI-generated information.

Unless expressly stated otherwise, AppSynergy Services are consumer applications intended for informational, educational, entertainment, fitness, lifestyle, or wellness purposes.

They are not medical services and do not provide:

Medical diagnosis;
Medical treatment;
Medical prescriptions;
Professional medical advice;
Emergency medical services; or
A substitute for qualified healthcare professionals.

AI-generated responses, biological-age estimates, longevity indicators, wellness scores, nutrition analyses, cognitive results, and recommendations may be inaccurate, incomplete, inconsistent, outdated, or unsuitable for a particular individual.

You should not rely on such information as the sole basis for medical or health-related decisions.

Always consult an appropriately qualified healthcare professional regarding symptoms, medical conditions, diagnosis, treatment, medication, or significant changes to your health, diet, exercise, or wellness routine.

If you believe you are experiencing a medical emergency, contact your local emergency services immediately.

Unless expressly stated otherwise in connection with a specific healthcare relationship, AppSynergy operates its Services as consumer applications and is not acting as a healthcare provider, health plan, healthcare clearinghouse, or business associate under the U.S. Health Insurance Portability and Accountability Act (“HIPAA”).

Communications With AppSynergy

We do not require your name or email address as part of ordinary mobile application use.

If you voluntarily contact us through email, a website form, customer support, or another communication channel, we may receive your email address and other information you choose to provide.

We use this information only as reasonably necessary to respond, provide support, investigate an issue, process a privacy request, prevent abuse, or maintain appropriate business records.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in:

Our Services;
Features;
Technology;
Service providers;
Data-processing practices;
Platform requirements; or
Applicable law.

The effective date displayed at the beginning of this Privacy Policy identifies the current version.

Where a material change affects the processing of sensitive Personal Information or Health Information, we will provide additional notice or obtain renewed consent where required.

Data Controller and Contact

Data Controller
AppSynergy Yazılım Hizmetleri A.Ş.

Registered Address
19 Mayıs Mah. Halaskargazi Cad. No:226
Çiftkurt Apt. Kat:7 İç Kapı No:24
Şişli – İstanbul, Türkiye

Trade Registry No.
1072598

Privacy and Support Contact
support@appsynergy.co

You may contact us regarding privacy questions, access or deletion requests, Health Information, AI-related privacy matters, security concerns, or any other matter relating to this Privacy Policy.

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