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Privacy Policy Effective Date: October 7, 2024 Welcome to Bablworld. This Privacy Policy governs the privacy practices of Bablworld services ("Platform"), including Bablworld applications, websites, software, and related services accessible through any platform or device that links to this Privacy Policy. The Platform is provided and controlled by Bablworld Yazılım A.Ş., located in Izmir. Protecting your privacy is fundamental to us. This Privacy Policy explains how personal information about users and other individuals is collected, used, shared, and processed in connection with our Platform. Your use of the Platform constitutes your acceptance of this Privacy Policy. If you do not agree to any part of this policy, please do not use the Platform. Information We Collect Information You Provide We may collect the following types of information from you: Profile Information: Details you provide when registering on the Platform, such as your username, password, date of birth (if applicable), email address, phone number, and other additional information specified in your user profile, photo, or profile video. User Content: Content created on the Platform, including photos, videos, comments, “babls,” and associated metadata such as creation timestamps, locations, and creator identities. Even if you are not a registered user, User Content created or published by others on the Platform may contain information about you. Messages: Messages sent or received through the Platform’s messaging functions, timestamps, message content, and participant information. Please note that messages sent to other users are accessible by those users and that we are not responsible for how they use or share those messages. Purchase Information: Payment card information, billing and shipping addresses, contact details, and products purchased when making purchases or payments on the Platform. Contact Information: If you choose to synchronize your phone or social network contact information with the Platform, information such as names, phone numbers, email addresses, and social media profiles may be collected and matched with existing users on the Platform. Proof of Identity or Age: At times, we may request proof of identity or age to access certain features, for features such as verified or Business Accounts, or to meet legal requirements. Information Collected Automatically Usage Information: Information about how you interact with the Platform, including content views, interactions with ads, videos watched, browsing and search history, liked content, saved favorites, and interactions with other users. Inferred Information: We may infer certain characteristics, such as your interests, gender, and approximate age range, to provide you with a personalized experience. Technical Information: Details about the device you use to access the Platform, such as IP address, user agent, mobile carrier, time zone settings, advertising identifiers, device model, operating system, network type, device IDs, screen resolution, application and file names, typing patterns, battery status, audio settings, and connected audio devices. We may also link your profile information to your activities across devices. Location Information: We collect approximate location information based on your IP address or SIM card, and with your permission, precise GPS-based location data. Image and Audio Information: Information about the videos, images, and audio in your User Content. We collect this data for content moderation, demographic analysis, personalized content and ad recommendations, and other non-personally identifiable purposes. Cookies: We and our partners use cookies and similar technologies (e.g., web beacons, flash cookies) to automatically collect information about Platform usage, analyze usage patterns, enhance user experience, improve Platform functionality, provide targeted advertising, and measure advertising effectiveness. Cookies also enable certain features and functionality on the Platform. Information from Other Sources We may receive information from the following sources: Third Party Social Networks: If you register or log in to the Platform using your third party social network accounts (e.g., Facebook, Twitter), you may provide us with information such as your username, public profile, and other account-related details. We may share certain information with these social networks, such as your application ID and access token. Advertisers and Partners: Information shared with advertisers, measurement partners, and other third parties about your activities off the Platform, such as websites visited, applications used, and products purchased online or in-store. This information helps us match your activities off the Platform to your Bablworld account. Affiliates: Information from affiliates within our corporate group about your activities on their Platforms. Publicly Available Sources: Information from publicly accessible sources or in User Content, direct messages, complaints, objections, requests, or feedback sent to us. How We Use Your Information We use the information we collect for a variety of purposes, including: ● To provide, operate, and maintain the Platform. ● To fulfill your requests for products, services, or information, and to provide customer support. ● To personalize content and recommendations based on your preferences, interactions, and location. ● To send you promotional materials, offers, and notifications about products/services on the Platform or our affiliates and trusted third parties. ● To improve, develop, and optimize the Platform, conduct research, and analyze user trends. ● Measure and understand the effectiveness of ads and other content offered on the Platform. ● Support social functions such as connecting with other users, messaging, recommending accounts, and enabling content interactions. ● Enable interactive features of the Platform, such as allowing other users to use your User Content in their videos. ● Use User Content in our advertising and marketing campaigns, promoting the Platform, and highlighting popular topics and campaigns. ● Understand how you use the Platform across devices. ● Extract additional information, such as additional demographic details and interests. ● Detect, prevent, and address abuse, harmful activity, fraud, spam, and illegal activity. ● Ensure that content is presented effectively for you and your device. ● Promote the safety and security of the Platform by scanning, analyzing, and reviewing User Content and messages for violations of our Terms of Service, Community Guidelines, or other policies. ● Facilitate investigations by independent researchers who meet certain criteria. ● Verify your identity or age when necessary. ● Communicate with you, including to notify you about changes to our Services or to announce contest/promotion winners. ● To enforce our Terms of Service, Community Guidelines, and other policies. How We Share Your Information We may share your information with the following parties: Partners: If you sign up using third-party social network accounts or integrate with third-party services, we may share certain information with them. Service Providers: Organizations that support our business operations, such as cloud service providers, content moderation services, and marketing service providers. Payment Processors and Transaction Completion Providers: Information necessary to process payments and transactions, such as transaction IDs for Coin purchases. Analytics Providers: Third-party providers that help with analysis and optimization of the Platform. Advertisers, Ad Networks, and Measurement Partners: Data sharing to measure ad performance and display targeted ads. Independent Researchers: Data sharing for research purposes that meet certain criteria. Corporate Group: Information sharing with our other members, affiliates, or subsidiaries for platform improvement and operational support. Legal Reasons: Sharing information with law enforcement, public authorities or other entities to comply with legal requirements or enforce our Terms of Service, investigate violations, detect fraud or technical issues, or protect our rights, our users or the public. Private Babls Unless your Babl is set to private, your content is publicly visible on the Platform and can be accessed or shared by your friends, followers, and third parties such as search engines, content aggregators, and news sites. Each time you create a Babl, you can adjust the visibility settings or select the default private setting via "Edit" and set a custom price to make it private. Embedded Video Content Our mobile app includes embedded video content from YouTube, Vimeo, and other third-party platforms. These embedded videos allow you to watch content directly in our app, but are served from external platforms. Information Collection ● When you interact with embedded video content in our App, third-party platforms may collect the following information: ● Your IP address ● Pages you visited before and after watching the video ● Your interactions with the video (e.g. play, pause, or watch time) ● Device and browser information ● Cookies and similar tracking technologies to collect data about your browsing behavior Use of Information The information collected by these third-party platforms is subject to their own privacy policies. We do not control how these platforms use your data. We include embedded videos to enhance your user experience and provide relevant content. Sale, Merger, or Other Transaction We may disclose your information to third parties in connection with a sale, purchase, merger, partnership, or other business transaction involving Bablworld or its assets. Where We Store Your Information Your information may be stored on servers outside your country of residence, including in Frankfurt. We maintain a global infrastructure of servers to provide our Services worldwide. Your Rights and Options You have rights under applicable law, including the right to access, delete, update or correct your data, to be informed about data processing activities, to complain to authorities and potentially other rights. To exercise your rights, you can submit your requests to support@bablworld.com. You can follow the instructions provided in our communication to appeal decisions made regarding your request. You can access and edit your profile information by logging into Bablworld. You can delete content you have uploaded. Security of Your Information We take steps to ensure that your information is processed securely and in accordance with this policy. Unfortunately, the transmission of information over the Internet is not completely secure. We will take reasonable measures to protect your personal data, for example encryption, but we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk. We have appropriate technical and organizational measures in place to provide a level of security appropriate to the varying likelihood and severity of risks. We review and update these technical and organizational measures from time to time with the aim of improving the overall security of our systems. We may, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Check these policies before submitting any information to these websites. How Long Do We Keep Your Information We keep information for as long as necessary to provide the Platform and for other purposes set out in this Privacy Policy. We also keep information to fulfill contractual and legal obligations, when we have legitimate business interests (e.g., to improve and develop the Platform and to enhance its security, reliability and stability), and for the exercise or defense of legal claims. Retention periods vary depending on the type of information and the purpose for which we use it. For example, when we process your profile information to provide the Platform, we keep that information for as long as you have an account. If you violate our Terms of Service, Community Guidelines or other terms or policies, we may immediately remove your profile and User Content from public view, but we may retain other information about you to process the violation. Information Regarding Children and Youth Bablworld is not directed to children under the age of 13. Depending on local regulatory requirements, this age may be higher; refer to local supplemental terms for more information. If you believe that you are a user under this minimum age, please contact us at support@bablworld.com. Updating Privacy Policy We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the "Last Updated" date at the top of this policy and posting the new Privacy Policy or providing such other notice as may be required by applicable law. Your continued access or use of the Platform after the updated policy is posted will constitute your acceptance of the updated policy. If you do not accept the updated policy, you should discontinue accessing or using the Platform. Contact If you have any questions, comments, complaints or requests regarding this Privacy Policy, please contact us at support@bablworld.com Please also refer to the supplemental terms below to see if there is a local representative or contact for your country. Information Text Dear User, As Bablworld, we attach great importance to the protection of your personal data. Therefore, we would like to inform you within the scope of the Personal Data Protection Law No. 6698 (KVKK). Processed Personal Data: Profile Information We collect your identity and profile information, including your username, password, first and last name, date of birth, nickname, profile photo and other biographical information you choose to provide. We may also collect your Turkish Republic ID number in certain cases where identity verification or proof of age is required. Information in this category is generally collected directly from you (e.g. when you register for the Platform). If you register for or use the Platform using third-party social network account information (e.g. Facebook, Twitter, Instagram, Google) or a login service, you will be required to provide us with your username, public profile information and other information associated with this account or to permit the provision of this information. Likewise, we will share some information with your social network, including your app ID, access token, and referral URL. If you connect your Bablworld account to another service, we may also collect information about your use of that service. We may also use automated processes to determine your qualifications (including age range and gender) and interests using your information. We may use your information to infer information to keep the platform secure, conduct content moderation, and, where permitted, provide you with personalized advertising based on your interests. Contact Information When you register for the Platform, you provide us with your email address and/or phone number. We may also collect this information and your postal address through correspondence you send us or when you make purchases through the Platform. Purchase Information When you make a purchase or payment on or through the Platform, when you receive Babl Coin, you may provide us with information about the purchase or payment transaction, including payment card information and the products you purchase. User Content When you use the Platform, you may create User Content, including photos, audio recordings and videos you upload or create, comments, tags, feedback, reviews and live broadcasts you make, and associated metadata such as when, where and by whom the content was created. Even if you are not a user, your information may appear in User Content created or published by users on the Platform. Messages We collect the information you provide when you create, send or receive messages through the Platform’s messaging functions. This information includes the content of the message and information about the message, such as when the message was sent, received or read, and the participants in the message. We would like to point out that messages you choose to send to other users of the Platform may be accessed by these users, and we are not responsible for how these users use or share messages. Social Connections If you synchronize the contacts stored on your phone, we will access and collect information about the registered contacts, including name, phone number, and email address, and match this information with existing users of this Platform. If you choose to share contacts in your social network, we will collect the names and profile information of the people in your social network, as well as your public profile information. Account and Technical Information We automatically collect certain information about the device you use to access the Platform, such as your IP address, user agent, internet service providers, mobile carrier, time zone settings, advertising identifiers, device model, device system, network type, device IDs, screen resolution and operating system, application and file names and types, keystroke patterns or rhythms, battery status, audio settings, and connected audio devices. Location Information We collect information about your approximate location, including location information based on your SIM card and/or IP address. Marketing Information We and our service providers and partners use cookies and other similar technologies (e.g. web beacons, flash cookies, etc.) (“Cookies”) to automatically collect, measure and analyze how you use the Platform, including which pages you view most often and how you interact with content, enhance your experience using the Platform, improve the Platform, serve you advertising, and measure the effectiveness of advertising and other content. We and our partners also use Cookies to promote the Platform on other platforms and websites. Cookies enable the Platform to provide certain features and functionality. Web beacons (web beacons) Cookies are very small images or small pieces of data embedded in images, also known as “pixel tags” or “perceptible GIFs”, that recognize the time and date a page was viewed, a description of the page where the pixel tag was placed, and similar information from your computer or device. Advertisers, measurement and other partners share information with us about you and your online or in-person actions outside of the Platform, such as your activities on other websites and apps or in stores, including products or services you purchase. These partners also share information with us, such as mobile identifiers for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to help match you and your actions outside of the Platform to your Bablworld account. Purposes of Processing Personal Data: - To provide and improve our services - To manage customer relations - To fulfill our legal obligations - To improve user experience - To engage in marketing activities (with your consent) Transfer of Personal Data: Your personal data may be shared with our business partners, suppliers, legally authorized public institutions and organizations for the purposes specified above. Methods of Collection of Personal Data and Legal Reasons: Your personal data is collected electronically through our application by automatic or non-automatic methods. The legal reasons for processing your personal data are; your explicit consent, being foreseen by the laws, establishment and performance of the contract, fulfillment of our legal obligations and our legitimate interests. Necessity of Contract We use your information when it is necessary for the establishment or performance of any contract you have with us when you register, access or use the Platform. In this context, we use your information for the following purposes: To provide our products and services and fulfill support requests. We use your information to provide our products and services, to ensure the functionality of the platform and to fulfil your requests for support and information. We may also process your information for troubleshooting and user support, if necessary. To enable you to use interactive features. This processing purpose includes ensuring that your content is featured in other users’ videos. To ensure device compatibility. We may use your information to ensure that content is presented in the most effective way for you and your device. To communicate with you. (Including to inform you about changes to our Services) Cookies. We use strictly necessary tracking technologies to provide you with the features you have requested, such as allowing you to access our website and secure areas of our website. Exercising Legal Rights We use your information where it is necessary to establish, exercise or protect our rights. This means that we use your information to enforce our Terms and other terms and policies. This may include removing content (including through automated content removal processes) or suspending or closing your account if we find that you have violated our Terms and any of our other terms and policies. Data Publication We may process your information that you have made public. We use such public data for the following purposes: To recommend accounts to you and others and to enable you and others to share, download and otherwise interact with User Content published through the Platform. To use User Content as part of our advertising and marketing campaigns to promote the Platform. We use your information where it is necessary to achieve the legitimate interests we pursue, provided that it does not infringe on your fundamental rights and freedoms. We use the information we collect for the following purposes: Legitimate Interest To support the social functions of the Platform. ● To enable you and other users to connect (for example, through our Find Friends function) and to share with your friends whether you are active on the Platform (and other information you choose to share), to provide our messaging service (with your consent). ● Legitimate Interest: To provide users with tools to inspire creativity, collaboration and entertainment, and to create opportunities for users to reach new audiences. To recommend your account to other users. ● We may offer your account to other users, including if a user chooses to sync their contacts with the Platform. ● Legitimate Interest: To enable users to quickly and efficiently find and connect with other users. To provide you with a personalized user experience. ● To personalize the content you see while using the Platform. For example, depending on your selected country settings, we may provide you with services or show you content similar to content you have liked or engaged with. ● Legitimate Interest: To enable users to quickly and efficiently find and connect with other users. To provide personalized and non-personalized advertising to all users. ● We show you non-personalized and personalized advertising based on your activities on the Platform. We also show you personalized advertising based on your activities off the Platform, unless you decline through your Platform settings. Personalized advertising is not displayed on the Bablworld website version. ● Legitimate Interest: To show you personalized and non-personalized advertising to keep the Platform free. To perform measurement and analytics. ● We help creators and advertisers measure the effectiveness and delivery of ads and other content we serve to you and others, and to serve ads (including targeted ads) on the Platform. We may use information about you, including your age range, gender, and interests, for this purpose. ● Legitimate Interest: To enable creators and advertisers to see and understand the performance of their ads or content, and the audiences viewing or engaging with their ads or content. This allows Bablworld, creators, and advertisers to make more informed decisions (such as what types of ad campaigns they may want to run, the type of audience they want to reach, and the types of content users enjoy the most). This ensures that users are presented with ads and content that are relevant and entertaining to their interests, and that the Platform remains free for all users. To ensure the safety and well-being of our community. ● We support the safety and security of our Platform and the well-being of our community. We may use your information to help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Platform. We review, analyze, and review User Content (and, where permitted under applicable law, Messages and related metadata) for violations of our Terms, Policies, or other terms and policies. ● We may also ask you to provide additional information to infer your age range and, under certain circumstances, to verify your age. ● Legitimate Interest: Keeping our community safe, reviewing compliance with our Policies, and detecting abuse of the Platform. Ensuring the security and order of the Platform ● We use your information to maintain the order and order of the Platform, including identifying and combating technical or security issues (such as technical errors, spam accounts, and detecting abuse, fraud, and illegal activities). ● Legitimate Interest: Ensuring the stability and security of the Platform and ensuring the continued availability and functionality of the Platform. Review, improve, promote and develop the Platform ● We use your information to develop and improve the Platform, including to understand how people use the Platform and to train, develop and improve our technology, such as our machine learning models and algorithms. We also use this information to better understand and promote the Platform, popular topics, hashtags, campaigns and emerging trends. To achieve this goal, we may conduct data analysis, testing, research, and surveys and solicit your feedback. ● Legitimate Interest: To knowingly improve, promote and develop the Platform. Sharing your information with third parties We share your information with third parties whose platforms or services integrate with the Platform. We may also share your information to facilitate research conducted by independent researchers who meet certain criteria. Legitimate Interest: To provide you with a seamless user experience, to allow your content to be shared on other platforms, to enable third parties to verify the identity of users, to optimize the user experience and to conduct research that meets certain criteria. Sending instant / in-app marketing messages ● We may send you marketing and promotional materials that we think will be of interest to you about the Platform, its features, popular topics, hashtags and campaigns, and the services of our affiliates and trusted third parties via instant / in-app messaging. ● We may also send you information about promotions, contests or marketing campaigns or events via instant / in-app messaging. In cases where you participate in our contests, promotions or other promotional activities and win, we may declare you a winner and use your information to send you a prize, if the rules of the relevant event or activity permit. ● Legitimate Interest: To promote the Platform, our events, activities and the products and services of Bablworld, its affiliates and trusted third parties. Cookies ● We process your personal data through "functionality" and "first-party analytics and performance" cookies. ● We use cookies and other tracking technologies to enable certain features and to store information or access information stored on your device to distinguish you from other visitors. ● Legitimate Interest: To enable users to navigate between pages efficiently, to ensure internet security, to understand how our website is used, to remember user preferences and to generally improve the user experience. Explicit Consent We rely on your explicit consent to process your information for certain processing purposes: Sending commercial electronic messages. ● We may send you direct marketing and promotional materials, including SMS and email, about the Platform, its features, popular topics, hashtags and campaigns, and the services of our affiliates and trusted third parties that we think may be of interest to you. ● We may also send you information about promotions, contests or marketing campaigns or events. If you participate in our contests, promotions or other promotional activities and win, we may declare you a winner and use your information to send you a prize, if the rules of the relevant event or activity permit. ● We do this to promote the Platform, our events, activities and the products and services of Bablworld, its affiliates and trusted third parties. If we rely on your consent to process your information, you can always withdraw your consent through your device permissions or in-app settings. We only rely on this legal basis when we need your explicit consent for processing. If another legal basis exists, your explicit consent will not be requested. Cookies We rely on your explicit consent for our personal data processing activities through "third party performance and analytics" and "advertising and marketing" cookies. Parties and conditions for sharing information Partners If you choose to register to use the Platform using your social network account information (e.g. Facebook, Twitter, Instagram, Google), you will provide us with your phone number, email address, username, and public profile, or allow your social network to provide them to us. Similarly, we will share certain information with the relevant social network, such as your application ID, access token, and referring URL. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you provide, the third party may receive your account information and other information you choose to provide. Where you choose to share content on social media platforms, the video, username, and accompanying text will be shared on that platform, or, in the case of sharing via instant messaging platforms such as WhatsApp, a link to the content will be shared. Service Providers We provide information and content to service providers that support our business, such as service providers who help us promote the Platform, content management service providers that make the Platform a safe and enjoyable place, and cloud service providers. Payment processors and transaction processing providers: If you choose to purchase tokens or make other payment-related transactions, we will share data with the relevant payment provider to facilitate that transaction. For token transactions, we share a transaction ID to enable us to identify you after you make a payment and to fund your account with the correct value in tokens. Analytics providers: We use analytics providers to help us optimize and improve the Platform. Our third-party analytics providers also help us deliver targeted advertising. Advertisers, Ad Networks and Measurement Partners We share information with advertisers and third-party measurement companies to show us how many times an advertisement on the Platform has been viewed or clicked by which users of the Platform. Independent Researchers We share your information with independent researchers to facilitate research that meets certain criteria. Our Corporate Group We may also share your information with other members of our corporate group, affiliates or subsidiaries, including to provide, improve and optimize the Platform, prevent unlawful use and support users. For Legal Reasons We share your information with law enforcement, public authorities or other organizations if legally required or reasonably necessary to: ● comply with a legal obligation, process or request; ● enforce our Terms of Service and other agreements, policies and standards, including investigation of potential violations thereof; ● detect, prevent or otherwise address security, fraud or technical issues; or ● protect the rights, property or safety of us, our users, a third party or the public, as required or permitted by law (including exchanging information with other companies and organizations for fraud prevention and credit risk reduction purposes). Sale, Merger or Other Business Transactions We may also disclose your information to third parties: ● in the event that we sell or buy any business or assets (whether by liquidation, bankruptcy or otherwise), in which case we will disclose your information to the prospective seller or buyer of such business or assets; or ● if we sell, buy, merge, be acquired by or form a partnership with other companies or businesses, or if we sell some or all of our assets. In such transactions, user information may be among the transferred assets. Merchants, Payment and Processing Providers, and Other Service Providers When you purchase our shopping features, we share information about the transaction with merchants, payment and processing providers, and other service providers. For example, we will share order items, contact information, and shipping information so that your order can be processed. These organizations may use the information shared by their privacy policies. Your Rights as a Data Owner: According to Article 11 of the KVKK, you have the following rights regarding your personal data: - To learn whether your personal data has been processed, - To request information about it if it has been processed, - To learn the purpose of processing and whether it is used in accordance with its purpose, - To know the third parties to whom personal data is transferred domestically or abroad, - To request correction of any incomplete or incorrect processing, - Request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the KVKK, - Request that the correction, deletion or destruction processes be notified to third parties to whom the personal data is transferred, - Object to the emergence of a result against you by analyzing the processed data exclusively through automatic systems, - Request compensation for the damages in case you suffer damages due to the unlawful processing of your personal data. You can send your requests and complaints by sending an e-mail to support@bablworld.com Personal Data Protection and Processing Policy Purpose and Scope: This policy has been prepared by Bablworld in accordance with the Personal Data Protection Law No. 6698 (KVKK) in order to determine the procedures and principles regarding the protection and processing of personal data. Principles of Processing of Personal Data: - Processing by the law and rules of honesty - Being accurate and up-to-date when necessary - Processing for specific, clear and legitimate purposes - Being connected, limited and proportionate to the purpose for which they are processed - Being stored for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed Security of Personal Data: - Preventing unlawful processing of personal data - Preventing unlawful access to personal data - Taking all necessary technical and administrative measures to ensure the storage of personal data Purposes of Processing of Personal Data: - Providing services - Customer relations management - Fulfillment of legal obligations - Marketing and analysis activities Transfer of Personal Data: Your personal data may be transferred to third parties at home or abroad in line with legal obligations or requirements of business processes. Rights of Data Owners: Data owners may exercise their rights specified above by Article 11 of the KVKK. Application and Complaint: You can send any questions, requests or complaints regarding your personal data to support@bablworld.com