Privacy Policy and Personal Data Processing Disclosure

PERSONAL DATA PROCESSING DISCLOSURE (Privacy Policy included) Last Update: 10.07.2024

1. Data Controller Identity This disclosure is prepared by Nail Akdağ ("Developer") as the data controller under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK"). Address: Pendik, Istanbul, Turkey Contact: info@babywallie.com

2. Categories of Personal Data Processed • Identity data: first name, last name • Contact data: email address • Financial data: payment transaction ID (provided by Apple/Google) • Baby/pregnancy data: photos, videos, voice recordings, height-weight measurements, vaccination records, sleep and feeding logs • Daily notes, forum posts, and messages • Technical data: device ID, IP address, app usage data

3. Purposes of Processing Personal Data • Account creation and membership management • Cloud storage, media display, and data synchronization • Subscription management and billing (via App Store / Google Play) • AI features (chat, photo editing, development suggestions) • Forum community management and moderation • App performance improvement and error tracking • Fulfillment of legal obligations • Explicit user consent is obtained before AI features are used or enabled. • User data is not used for advertising and is not sold to third parties.

4. Transfer of Personal Data Your data may be transferred to the following parties for the stated purposes: • AWS (EU-Frankfurt region): Secure storage of media files and app data • OpenAI LLC (USA): Anonymous/limited data processing for AI chat and suggestion services • Google Firebase: Analytics, notification services, and authentication • RevenueCat: Subscription management • Authorized public authorities (Turkey): When legally required

5. Method and Legal Basis of Data Collection Your data is collected through automated and semi-automated methods via the app, based on KVKK Art. 5/2(c) performance of the contract, Art. 5/2(ç) legal obligation, and Art. 5/1 your explicit consent.

6. Retention and Destruction Periods • Membership data: Deleted within 6 months of account deletion request (subject to legal retention obligations) • Baby photos/videos: Until deleted by user or account closure • Forum posts: Until deleted by user or account closure • Financial records: 10 years per tax legislation • Server logs: 2 years

7. Data Subject Rights (KVKK Art. 11) Under KVKK Art. 11, you have the following rights: • To learn whether your personal data is processed • To request information about processing • To learn the purpose of processing and whether data is used accordingly • To know third parties to whom data is transferred domestically or abroad • To request correction if data is incomplete or inaccurate • To request deletion or destruction under KVKK Art. 7 conditions • To request notification of correction, deletion, or destruction to third parties • To object to results arising from automated analysis • To claim compensation for damages arising from unlawful processing Submit your requests to info@babywallie.com. Requests are free and answered within 30 days.

8. Security Measures Technical: HTTPS/TLS encryption, database encryption, access logs, multi-factor authentication (MFA), regular backups Administrative: Confidentiality agreements, role-based access authorization, regular security assessments

9. Cookie and SDK Policy Baby Wallie is a mobile application and does not use web cookies. Only mandatory SDKs (authentication, session management) and analytics SDKs (Firebase Analytics) are used within the app. No advertising SDKs or tracking tools are used.

10. International Data Transfer Some of our service providers (AWS, OpenAI, Google) may process data in the EU or USA. These transfers are carried out under KVKK Art. 9, to countries providing adequate protection or based on your explicit consent.

11. Apple and Google Privacy Requirements Baby Wallie complies with Apple App Store and Google Play Store privacy requirements. The types of data collected and purposes of use are declared in the privacy labels/data safety sections of both platforms. The app does not engage in third-party ad tracking or data selling.

12. Children's Privacy Baby Wallie is designed for use by parents. Parental or guardian consent is required for individuals under 18. We do not knowingly collect personal data directly from children under 13.

13. Policy Changes This policy is effective as of 10.07.2024. The current version is always published at https://www.babywallie.com/en/privacy. Significant changes will be announced via in-app notification.