Privacy Policy

Introduction

We respect your privacy and are committed to protecting your personal data while helping you organize and clean up your photo library. This Privacy Policy (“Policy”) explains how Technograde Yazılım Teknoloji ve Ticaret Ltd. Şti. (“Company”, “we”, “our”, “us”) collects, uses, processes, and shares your information when you use the Cleanio mobile application (“Cleanio”, “Application”, “App”, “Services”).

By downloading, installing, accessing, or using Cleanio, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our Terms and Conditions, please do not use the App.

This Policy should be read together with our Terms and Conditions, which govern your use of Cleanio.

1. Information We Collect

We collect the following categories of information when you use Cleanio:

Apple ID and Account Information

Apple processes your Apple ID and App Store account information independently when you download or purchase through the App Store. We do not receive your Apple ID, Apple account email, password, or payment credentials. We may assign an internal anonymous user identifier to manage subscription status, app preferences, permissions, and app functionality.

Photo Library Access (On-Device Only)

Cleanio requires access to your device's photo library to perform its core function: helping you identify duplicates, similar photos, screenshots, large videos, and, where available, people-based photo groups. All photo analysis is performed entirely on your device. We do not upload, store, transmit, or have access to your photos or videos on our servers at any time.

Face Detection Data (On-Device Only)

The “People” feature uses Google ML Kit's on-device face detection technology to help you group photos by the people who appear in them. This processing happens entirely on your device. No facial data, biometric information, or images are transmitted to Google, to us, or to any third party. We do not create or store facial recognition templates.

Technical and Device Data

We may collect technical information such as your IP address, device model, device identifiers (including the Identifier for Vendors / IDFV), operating system version, app version, language, time zone, region, crash reports, and usage analytics (e.g., features accessed, session duration). This information is collected through services such as Firebase (provided by Google LLC) and is used to ensure the App functions properly, diagnose technical issues, prevent abuse, and improve our Services.

Subscription and Purchase Information

When you subscribe to Cleanio Premium or make an in-app purchase, we process information about your subscription type, billing period, purchase date, transaction identifier, and subscription status through our subscription management provider (Adapty). We do not collect or store your credit card number or payment method details. All payments are processed directly by Apple.

Advertising and Marketing Data

If you provide consent through Apple's App Tracking Transparency (ATT) prompt, we may collect:

• Identifier for Advertisers (IDFA)
• Advertising interaction data (impressions, clicks)
• Attribution data (which marketing campaign led you to install the App)

This data is used for advertising measurement, campaign attribution, fraud prevention, and to show you more relevant advertisements.

Even without ATT consent, limited aggregated attribution data (such as campaign-level install metrics) may be collected through Apple's SKAdNetwork framework via AppsFlyer. This data does not include personal identifiers and cannot be used to identify you individually.

Contact Information

If you contact us by email for support, feedback, or to exercise your rights, we will process your email address and any information you choose to include in your message.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To provide, operate, and maintain the App and its features
• To manage your subscription and process in-app purchases
• To detect and remove duplicate, similar, or unwanted photos and videos from your device
• To enable face detection and people-based photo organization (on-device)
• To display advertisements to non-subscribed users
• To measure advertising performance and attribute installs
• To communicate with you about your account, subscription, or support requests
• To analyze app usage and improve features and performance
• To detect, prevent, and address technical issues, fraud, or abuse
• To comply with legal obligations and enforce our Terms and Conditions

2.1 Legal Basis for Processing (GDPR)

If you are located in the European Economic Area, United Kingdom, or Switzerland, we process your personal data on the following legal bases:

• Performance of a contract: Processing necessary to provide the App and manage your subscription (e.g., subscription status, in-app purchases).
• Legitimate interests: Processing for analytics, crash reporting, fraud prevention, and app improvement, where our interests are not overridden by your data protection rights.
• Consent: Processing of advertising identifiers (IDFA) and cross-app tracking data, collected only where you have provided explicit consent via Apple's App Tracking Transparency (ATT) prompt. You may withdraw your consent at any time via your device settings (Settings > Privacy & Security > Tracking).
• Legal obligation: Processing necessary to comply with applicable laws and regulations.

3. Third-Party Services

Cleanio integrates the following third-party services. Each service may collect and process certain data subject to its own privacy practices:

We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

4. Advertising and App Tracking Transparency

Cleanio displays advertisements to users who have not subscribed to Cleanio Premium. We use Google AdMob to serve these ads, which include:

• Interstitial ads — full-screen ads shown at natural breakpoints
• App Open ads — full-screen ads shown when you open the App
• Rewarded ads — optional ads you can watch to unlock specific features

In accordance with Apple's App Tracking Transparency (ATT) framework, we will request your permission before tracking your activity across other companies' apps and websites for advertising purposes. You can change your tracking preference at any time in your device settings (Settings > Privacy & Security > Tracking).

If you do not consent to tracking, you may still see advertisements, but they will not be personalized based on your activity across other apps.

5. Sharing of Information

We do not sell your personal data. We may share your information in the following limited circumstances:

• Service Providers: We share data with the third-party providers listed above (AdMob, Firebase, AppsFlyer, Adapty, Google ML Kit) solely to enable the functionality of the App.
• Legal Authorities: We may disclose information to comply with applicable law, regulation, legal process, or governmental request, or to protect our rights, property, or safety.
• Business Transfers: If we are involved in a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. Any successor entity will be bound by this Policy.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Analytics, crash, and attribution data are retained only for as long as needed for diagnostics, fraud prevention, analytics, and product improvement, unless a longer retention period is required by law. Support emails are retained only as long as necessary to respond to your request and maintain appropriate business records. When data is no longer needed, we will securely delete or anonymize it.

Photos, videos, and other content on your device are never stored on our servers. They remain solely on your device and are processed locally.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit, access controls, secure development practices, and regular security reviews.

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

8. Children's Privacy

Cleanio is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal information, please contact us and we will take steps to delete the information.

If you are between 13 and 18 years of age, you must have permission from a parent or legal guardian to use the App.

9. Your Rights

For Users in the European Economic Area, United Kingdom, and Switzerland (GDPR)

Under the General Data Protection Regulation (GDPR), you have the following rights:

• Right of access — to obtain confirmation of whether we process your data and request a copy
• Right to rectification — to correct inaccurate or incomplete data
• Right to erasure (“right to be forgotten”) — to request deletion of your data
• Right to restriction of processing — to limit how we process your data
• Right to data portability — to receive your data in a machine-readable format
• Right to object — to object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent — where processing is based on consent
• Right to lodge a complaint — with your local data protection authority

To exercise these rights, contact us at the email address below.

For California Residents (CCPA)

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

• Know what personal information we collect, use, and disclose
• Request deletion of their personal information
• Correct inaccurate personal information
• Opt out of the sale or sharing of personal information
• Non-discrimination for exercising privacy rights

We do not sell your personal information for monetary compensation. However, the use of certain advertising and analytics tools may be considered “sharing” under California law. You may opt out by denying ATT permission, disabling tracking in iOS Settings (Settings > Privacy & Security > Tracking), or contacting us at info@cleanio.app with the subject “Do Not Sell or Share My Personal Information.”

For Users in Turkey (KVKK)

For the purposes of KVKK, Technograde Yazılım Teknoloji ve Ticaret Ltd. Şti. acts as the data controller.

Under the Turkish Personal Data Protection Law No. 6698 (“KVKK”), you have the rights set out in Article 11, including the right to learn whether your personal data is being processed, to request information about the processing, to know the purposes of processing, to know third parties to whom your data is transferred, to request correction or deletion of your data, and to object to processing carried out solely by automated means.

To exercise any of these rights, please contact us using the contact information below. We will respond to your request within the time period required by applicable law.

10. International Data Transfers

Your personal data may be transferred to and processed in countries outside your country of residence, including countries that may have different data protection laws. When we transfer data internationally, we implement appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission or the Turkish Data Protection Authority, where applicable.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the “Last Updated” date at the top of this Policy. For material changes, we will provide prominent notice through the App or by other reasonable means.

Your continued use of the App after the effective date of the revised Privacy Policy means that you acknowledge the updated Policy.

12. Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Technograde Yazılım Teknoloji ve Ticaret Ltd. Şti.
Email: info@cleanio.app
Address: Şişli/İstanbul, Türkiye