PRIVACY POLICY

Last updated: February 17, 2025

Mangai is operated by APPSTERRA YAZILIM TICARET LIMITED SIRKETI ("Company," "we," "our," or "us"), a company registered in Turkey. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Mangai mobile application (the "App"). Please read this policy carefully. By using the App, you agree to the collection and use of information in accordance with this policy.

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly

• Account Data: When you first launch the App, we automatically create an anonymous account using a unique device identifier. We do not require you to provide your name, email address, or phone number to use the App.
• User-Generated Content: Characters you create (including photos you upload for character creation), story descriptions, prompts, and preferences you provide to generate comic stories.
• Photos and Images: If you choose to upload photos for character creation, we process these images solely to generate your AI characters. Uploaded photos are sent to our secure servers for processing and are not stored permanently after character generation is complete.
• Support Communications: If you contact us for support, we may collect your email address and the content of your communications.

1.2 Information Collected Automatically

• Device Information: Device model, operating system version, unique device identifiers (IDFV), language, and timezone.
• Identifier for Advertisers (IDFA): On iOS 14.5 and later, we request your permission via the App Tracking Transparency (ATT) framework before collecting your IDFA. This identifier is used for advertising attribution and campaign measurement. You may deny this request, and the App will continue to function normally.
• Usage Data: App interaction data including features used, pages viewed, session duration, crash logs, and performance metrics.
• Purchase Data: Information about your in-app purchases, subscription status, and credit balance, processed through Apple's App Store and our subscription management service.
• Push Notification Token: If you grant notification permission, we collect your device token to send you relevant push notifications about your story generation progress and other updates.

1.3 Information from Third-Party Services

• Attribution Data: When you install the App via an advertisement or promotional link, we receive campaign attribution data (such as the campaign name, ad group, creative, and source) through our attribution partners. This helps us measure the effectiveness of our marketing campaigns.
• Deep Link Data: If you open the App through a shared link, we receive metadata about the link to direct you to the appropriate content within the App.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

• Provide and Maintain the App: To create your account, generate AI comic stories, manage your characters, process your credits and subscriptions, and deliver the core functionality of the App.
• AI Content Generation: Your prompts, character data, and story preferences are processed by AI systems to generate personalized manga/comic content. This processing is essential to the App's core service.
• Process Purchases: To verify and fulfill in-app purchases, manage your subscription status, and maintain your credit balance.
• Send Notifications: To notify you when your comic story is ready, send reminders, and provide other relevant updates (only if you have granted notification permission).
• Advertising Attribution: To measure the effectiveness of our advertising campaigns, understand which channels drive installs, and optimize our marketing spend. We do NOT display third-party advertisements within the App.
• Analytics and Improvement: To understand how users interact with the App, identify bugs and performance issues, and improve our features and user experience.
• Fraud Prevention: To detect and prevent fraudulent transactions, abuse, and other harmful activities.
• Legal Compliance: To comply with applicable laws, regulations, and legal processes.

3. THIRD-PARTY SERVICES

We use the following third-party services to operate the App. Each service has its own privacy policy governing the use of your information:

4. ADVERTISING AND TRACKING

4.1 App Tracking Transparency

On iOS 14.5 and later, we request your permission before tracking your activity across other companies' apps and websites. This permission is requested through Apple's App Tracking Transparency (ATT) framework. You can change your preference at any time in your device Settings > Privacy & Security > Tracking.

4.2 Advertising Attribution

We use advertising attribution services to measure the performance of our marketing campaigns. This involves:

• IDFA Collection: If you grant ATT permission, your Identifier for Advertisers may be shared with our attribution partners to match your install with the advertisement that led you to download the App.
• SKAdNetwork: We participate in Apple's SKAdNetwork, a privacy-preserving advertising attribution framework that provides aggregated campaign performance data without exposing individual user data. We have registered SKAdNetwork identifiers for Google Ads, Meta (Facebook/Instagram), TikTok, Apple Search Ads, and various mediation partners.
• AdServices: We use Apple's AdServices framework to receive attribution tokens for Apple Search Ads campaigns. These tokens are privacy-preserving and do not require ATT consent.

4.3 No In-App Advertising

We do NOT display third-party advertisements within the App. The tracking and attribution described above are used solely to measure the effectiveness of our own marketing campaigns to acquire new users.

5. DATA RETENTION

• Account Data: Retained for as long as your account is active or as needed to provide you with the App's services.
• User-Generated Content: Characters and stories are retained in your account until you delete them or your account is terminated.
• Uploaded Photos: Photos uploaded for character creation are processed and not permanently stored on our servers after the character has been generated.
• Purchase Records: Retained for as long as required by applicable tax and financial regulations (typically 7 years).
• Analytics Data: Aggregated analytics data may be retained indefinitely. Individual usage logs are retained for up to 24 months.
• Attribution Data: Campaign attribution data is retained for up to 24 months for marketing analysis purposes.

6. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit using TLS/SSL (HTTPS).
• Secure server infrastructure with access controls and monitoring.
• Regular security assessments of our systems and third-party services.
• Minimal data collection principles - we only collect data necessary for the App's functionality.

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

7. YOUR RIGHTS AND CHOICES

7.1 Access and Deletion

You have the right to:

• Access the personal data we hold about you.
• Request deletion of your personal data and account.
• Request correction of inaccurate personal data.
• Receive a copy of your data in a portable format.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

7.2 Opt-Out Options

• Push Notifications: You can disable push notifications at any time through your device Settings > Notifications > Mangai.
• Tracking (IDFA): You can deny or revoke tracking permission through Settings > Privacy & Security > Tracking on your iOS device.
• Account Deletion: You may request complete deletion of your account and all associated data by contacting us at [email protected].

8. CHILDREN'S PRIVACY

The App is not directed to children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at [email protected].

9. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that are different from the laws of your country. By using the App, you consent to the transfer of your information to these countries. We ensure that appropriate safeguards are in place to protect your information in accordance with this Privacy Policy.

10. CALIFORNIA PRIVACY RIGHTS (CCPA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

• The right to know what personal information we collect, use, and disclose.
• The right to request deletion of your personal information.
• The right to opt-out of the "sale" of your personal information. We do not sell your personal information.
• The right to non-discrimination for exercising your privacy rights.

To exercise these rights, contact us at [email protected].

11. EUROPEAN PRIVACY RIGHTS (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

• Legal Basis: We process your data based on: (a) your consent, (b) the necessity to perform our contract with you (providing the App's services), (c) our legitimate interests (analytics, fraud prevention, marketing measurement), and (d) legal obligations.
• Right to Object: You have the right to object to processing based on legitimate interests.
• Right to Restrict Processing: You may request restriction of processing in certain circumstances.
• Right to Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority.
• Withdrawal of Consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy within the App or on our website. Your continued use of the App after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

13. CONTACT US

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

• Company: APPSTERRA YAZILIM TICARET LIMITED SIRKETI
• Email: [email protected]
• Website: https://getmangai.com/support