Privacy Policy - TuranliApp

Last Updated: September 7, 2026

At TuranliApp, we are committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your information when you use any mobile application published by us (each, an "App"). It applies to all our Apps, whether currently available or released in the future, including AI-powered image and video generation apps, AI-powered keyboard apps, AI-powered health, fitness, and nutrition tracking apps, and other AI-based productivity and entertainment tools. This Privacy Policy is part of our Terms of Use.

Not all sections apply to every App: sections describing a specific feature type (such as photo processing, keyboard functionality, or health and fitness tracking) apply only to Apps that include that feature. Each App's features are described on its App Store product page.

By downloading, installing, or using an App, you acknowledge that you have read, understood, and agree to this Privacy Policy.

APP-SPECIFIC PRIVACY POLICIES

The following applications have a dedicated policy describing their exact features and data flows. If an app-specific policy differs from this general policy, the app-specific policy governs that App.

• Florecho: Plant Identifier — Privacy Policy
• Koza — Privacy Policy

1. INFORMATION WE COLLECT

1.1 Information You Provide

• Account Information: When you create an account or use the App, we may collect your email address and other registration details.
• Input Content: Text prompts, photos, videos, or other inputs you submit to generate AI-powered results. For Apps with keyboard functionality, Input Content means only the text you explicitly submit to an AI action (see Section 2A).
• Health, Fitness, and Nutrition Data: In Apps with calorie, macro, weight, BMI, water, fasting, step, or walk-tracking features (such as CalorieOwl), we collect the information you enter to use those features, such as your height, weight, age, sex, activity level, and goals; your food log entries (including food photos, barcode scans, and search results) and the calories/macros associated with them; your water intake; your fasting schedule and history; your weight history; and, where you use step counting or GPS walk tracking, your step counts and walk routes, distance, and duration. See Section 2B for details.
• User Content: All content generated through the App, including AI-generated images, videos, and text.
• Communication Data: When you contact us for support, we collect your email and message content.

1.2 Automatically Collected Information

• Device Information: Device type, operating system, unique device identifiers, and mobile network information.
• Usage Data: Features you use, time spent on the App, interaction patterns, performance data, and generation count (number of images/videos generated or AI requests made).
• App Activity: Crash reports, error logs, and diagnostic information.

App Tracking Transparency: Where an App requests permission through Apple's App Tracking Transparency framework, tracking occurs only if you grant permission. You can deny or withdraw this permission at any time in iOS Settings › Privacy & Security › Tracking, and the App remains fully functional without it.

1.3 Usage and Generation Limits

To ensure fair usage and maintain service quality for all users, we track the number of AI generations and AI requests you make. AI features are subject to fair-use limits (which may include hourly, daily, weekly, or monthly caps). The limits applicable to each App, and whether they differ between free and premium plans, are displayed in the App, on its purchase screen, or on its App Store page. Where a periodic limit applies, it resets at the start of the applicable period (for example, monthly limits reset on the first day of each calendar month).

1.4 Payment and Subscription Information

• Payment processing is handled securely by Apple App Store. We do not store your credit card or payment information.
• We receive transaction confirmations and subscription status from the App Store.
• We receive refund, cancellation, and billing-issue notifications from the App Store.

2. PHOTO AND VIDEO DATA & AI PROCESSING

This section applies to Apps that allow you to upload photos or videos for AI transformation, generation, or editing (for food photos in food-logging Apps such as CalorieOwl, see Section 2B instead).

2.1 How We Process Your Photos and Videos

When you upload photos or videos to the App for AI transformation:

• They are securely transmitted to our processing servers via encrypted connections.
• They are processed by AI models operated by our third-party AI service providers (see Section 4.1) to generate the transformations you request.
• Automatic Deletion: All uploaded photos and videos are automatically and permanently deleted from our servers within 24 hours of upload.
• Generated content (Output Content) remains accessible to you until you delete it or terminate your account.
• Usage Limits: Generations are subject to the fair-use limits described in Section 1.3.

2.2 Face Data & Image Processing

IMPORTANT: We do not collect, analyze, or store facial data or biometric identifiers.

All photos, including those that may contain faces, are processed solely to apply visual effects and AI-generated transformations (e.g., anime, cartoon, portrait, avatar, or fantasy styles).

• No Facial Recognition: The App does not perform facial recognition, face mapping, or identity analysis.
• No Biometric Data Collection: We do not create, infer, or retain any data that can identify or authenticate an individual based on facial features.
• Artistic Rendering Only: The App's AI models process images exclusively for artistic rendering purposes and do not perform biometric analysis of any kind.
• Temporary Processing: Photos are processed temporarily on secure servers and automatically deleted within 24 hours.
• No Database Storage: We do not maintain any database of facial features, face templates, or biometric identifiers.
• Third-Party Processing: Photos are processed by our third-party AI service providers (see Section 4.1), which operate under strict data processing agreements and do not retain your images after processing.

What We Do:

• Apply artistic filters and style transfers to your photos
• Generate creative transformations (anime, cartoon, fantasy, portraits, avatars, etc.)
• Enhance images using AI algorithms
• Process images to deliver the visual effects you request

What We DO NOT Do:

• Identify individuals from facial features
• Authenticate users based on face data
• Create biometric profiles or templates
• Match faces across different photos
• Analyze demographic characteristics from faces
• Store or retain any facial recognition data
• Share face data with third parties for identification purposes

Purpose of Processing: The App uses uploaded photos containing faces strictly for generating the AI results you request. No facial recognition, face mapping, or identity analysis is performed.

2.3 Data Security During Processing

• All photos and videos are transmitted using industry-standard encryption (TLS/SSL).
• They are stored temporarily in secure, access-controlled storage during processing.
• We implement strict access controls to prevent unauthorized access to uploaded content.
• No Sharing: We do not sell, rent, trade, or share your uploaded photos or videos with third parties for marketing or advertising purposes.
• No Model Training: Uploaded photos and videos are never used to train AI models or for any purpose beyond generating your requested output.

2A. KEYBOARD DATA & AI TEXT PROCESSING

This section applies to Apps that include a custom keyboard extension.

2A.1 No Keystroke Logging

IMPORTANT: Our keyboards do not log, record, collect, store, or transmit your keystrokes.

• Regular typing — keys, word suggestions, emoji, haptics — happens entirely on your device and requires no network connection.
• We do not maintain any record of what you type during normal typing, and nothing you type is sent anywhere automatically.

2A.2 When Text Is Transmitted

Text leaves your device only when you explicitly invoke an AI action (such as grammar correction, tone rewriting, translation, or Ask AI). At that moment:

• The relevant text from the active text field is transmitted over an encrypted connection (TLS/SSL) to our third-party AI service provider (see Section 4.1), through a secure proxy layer.
• The text is processed transiently, solely to generate the result you requested, and the result is returned to your keyboard.
• We do not store the submitted text on our servers.
• Under our providers' API data usage terms, content submitted via their APIs is not used to train their models.
• Your text is never used for advertising, profiling, or marketing purposes, and is never sold or shared with third parties beyond the processing described here.

2A.3 Full Access Permission

Apple requires custom keyboards to obtain the "Allow Full Access" permission before they can use the network. Our keyboards use Full Access solely to:

• Send the text you explicitly submit to AI actions to our AI service provider and return the result;
• Enable device features iOS restricts for keyboards without Full Access (such as haptic feedback);
• Share your settings and subscription status between the main App and the keyboard, locally on your device.

Without Full Access, the keyboard continues to work for regular typing; only AI features and certain device features are unavailable.

2A.4 History (Stored on Your Device Only)

• If the App offers a history feature and you enable it, AI results are stored locally on your device only, in the App's shared on-device storage.
• History is never uploaded to our servers and is not accessible to us.
• You can turn history off or clear it at any time from the keyboard or App settings, and it is removed when you delete the App.

2A.5 Secure Fields

iOS automatically disables custom keyboards in secure text fields (such as password fields). Our keyboards therefore cannot see or access anything you enter into such fields.

2B. HEALTH, FITNESS, AND NUTRITION DATA

This section applies to Apps that offer calorie, macro, weight, BMI, water, fasting, step, or GPS walk tracking, or AI-powered food recognition (such as CalorieOwl).

2B.1 Food Photos and AI Recognition

• When you use the AI photo food scanner, the photo is transmitted over an encrypted connection to our AI service provider (currently OpenAI, see Section 4.1) solely to identify the food and estimate its calories, protein, carbohydrates, and fat.
• Our provider processes the photo transiently to generate this result and does not use it to train their models or retain it beyond what is needed to provide the service.
• The photo itself is stored locally on your device (in the App's on-device database) as part of your food log, so you can review your log history. It is not uploaded to or stored on our own servers.
• You can delete an individual food log entry (including its photo) or your entire log at any time in the App. Deleting the App removes this locally stored data from your device.

2B.2 Barcode Scanning and Food Search

The barcode scanner uses your camera to read a product barcode and looks up nutrition information from a food database. Food search queries the same or a similar database. We do not retain the images captured by the barcode scanner beyond what is needed to read the barcode.

2B.3 Health and Body Profile Data

Information such as your height, weight, age, sex, activity level, goal, weight history, and calculated BMI is used solely to calculate your calorie and macro targets and to show your progress over time within the App. This data is stored on your device and, where the App provides account sync, in our secure backend under your account.

2B.4 Step Counting and Walk Tracking

• Step counting uses your device's built-in motion/pedometer sensors, not Apple HealthKit. Step data is processed and stored on your device to show your daily activity.
• GPS walk tracking uses your device's location services only while you have an active walk session running, to record your route, distance, and duration. You can deny or revoke location permission at any time in iOS Settings, in which case walk-route tracking will be unavailable but the rest of the App continues to work.

2B.5 No Use of Health Data for Advertising

We do not use, sell, or share your health, fitness, nutrition, weight, or location data for advertising or ad-targeting purposes, and we do not disclose it to data brokers. Any advertising attribution tools we use (see Section 4.6) measure ad-campaign effectiveness only and do not receive this data.

2B.6 Data Export

Where offered, you can export your log (including food, weight, water, fasting, and step history) as a PDF or data file directly from the App, for your own records or to share with a healthcare professional such as a dietitian or doctor.

3. HOW WE USE YOUR INFORMATION

We use the collected information for the following purposes:

3.1 Service Provision

• To provide and deliver the App's AI-powered generation and tracking services (images, videos, text, and food/nutrition recognition).
• To process your Input Content and generate Output Content according to your requests.
• To calculate calorie, macro, and BMI targets and show your health and fitness progress, where applicable.
• To manage your account, subscriptions, and in-app purchases.
• To provide customer support and respond to your inquiries.

3.2 Service Improvement

• To analyze usage patterns and improve the App's features and functionality.
• To monitor and analyze App performance, identify technical issues, and fix bugs.
• To develop new features and services.
• To conduct research and analytics (using aggregated, anonymized data only).

3.3 Communication

• To send you important updates about the App, including changes to our Terms or Privacy Policy.
• To provide subscription renewal reminders and payment confirmations.
• To send promotional communications (only with your consent, where required by law).

3.4 Legal and Security

• To detect, prevent, and address fraud, security issues, or technical problems.
• To enforce our Terms of Use and protect our rights and property.
• To comply with legal obligations and respond to lawful requests from authorities.
• To respond to refund requests you submit to the App Store and to detect and prevent refund abuse.

4. THIRD-PARTY SERVICES AND DATA SHARING

We use trusted third-party services to operate and improve our Apps. These services may have access to your information only to perform tasks on our behalf and are obligated to protect your data. The services used depend on the App. The providers named below are those currently used; we may replace or add providers from time to time, in which case any new provider will be subject to substantially similar data protection commitments and this Privacy Policy will be updated.

4.1 AI Processing

• Image and video generation: Photos and videos you upload in Apps with image/video generation features are currently processed through Replicate's API (including the Gemini AI model) and, for certain features, open-source models from Stability AI. Replicate processes content according to strict data processing agreements and does not retain uploaded content after processing is complete. Learn more at https://replicate.com/privacy
• AI text features: Text you explicitly submit to AI actions in Apps with AI writing or keyboard features is currently processed by OpenAI's API, accessed through a secure proxy layer. Content submitted via OpenAI's API is not used to train OpenAI's models. Learn more at https://openai.com/policies/api-data-usage-policies
• Food recognition and AI coach: In Apps with AI food-photo scanning or an AI coach feature (such as CalorieOwl), food photos and your questions to the AI coach are currently processed via OpenAI's API. Content is transmitted over an encrypted connection solely to generate your requested output (food identification, nutrition estimate, or coach response) and is not used by OpenAI to train their models. Learn more at https://openai.com/policies/api-data-usage-policies

4.2 Payment Processing

• Apple App Store: All payment processing, subscription management, and transaction handling is performed by Apple. We do not have access to your payment card information. Apple's privacy practices are governed by their Privacy Policy.

Refund Requests. When you request a refund for an in-app purchase through Apple, Apple may ask us for information to help evaluate that request. In response, we (through RevenueCat) may share limited account and usage information with Apple, such as whether the purchased content was delivered, the extent to which you have used the App, the age and status of your account, your purchase and refund history, and our recommendation as to whether the refund should be granted. Apple makes the final decision on all refunds. We share this information only in response to a refund request you have initiated, and only with Apple. Where you are located in the EEA, United Kingdom, or Switzerland, we rely on the performance of our contract with you and on our legitimate interest in preventing fraudulent or abusive refund claims.

4.3 Subscription Management

• RevenueCat: We use RevenueCat to manage in-app subscriptions, track subscription status, and handle subscription-related features. RevenueCat processes subscription data according to their Privacy Policy available at https://www.revenuecat.com/privacy RevenueCat also transmits the refund-related information described in Section 4.2 to Apple on our behalf when you submit a refund request.

4.4 Analytics and Performance

• Firebase Analytics: We use Google Firebase to collect app usage statistics, crash reports, and performance data. This helps us improve the App's stability and user experience. Firebase collects anonymized usage data. Learn more at https://firebase.google.com/support/privacy
• Firebase Crashlytics: We use Crashlytics to monitor app crashes and technical errors, helping us identify and fix issues quickly.

Analytics run in the main App. In Apps that include a keyboard, the keyboard extension itself does not run analytics on your typing; as stated in Section 2A, keystrokes are never collected.

4.5 Other Third-Party Services

• Cloud Storage: We use secure cloud infrastructure providers to host the App's backend services and temporarily store data during processing.

4.6 Advertising and Attribution

Where enabled, we use advertising attribution tools (such as Google Ads' on-device conversion measurement) solely to measure which ad campaigns led to an App install or subscription, subject to your App Tracking Transparency permission. These tools receive install and conversion events only — they do not receive your food, weight, health, fitness, or location data.

4.7 Data Sharing Limitations

We do not sell your personal information. We only share your information:

• With the third-party service providers listed above, solely for the purposes described.
• When required by law, legal process, or government request.
• To protect our rights, property, or safety, or that of our users or the public.
• In connection with a merger, acquisition, or sale of assets (users will be notified).

5. DATA RETENTION

5.1 Uploaded Photos and Videos (Input Content)

• Automatic Deletion: All uploaded photos and videos in AI image/video generation Apps are automatically and permanently deleted from our servers within 24 hours of upload.
• No Long-Term Storage: We do not retain these uploaded photos or videos beyond the 24-hour processing window under any circumstances.
• Food photos in Apps such as CalorieOwl are handled differently — see Section 5.6.

5.2 Text Submitted to AI Actions

• Text submitted to AI actions is processed transiently to generate your result and is not stored on our servers.
• In Apps with a history feature, AI results saved to history remain only on your device, under your control (see Section 2A.4).

5.3 Generated Content (Output Content)

• AI-generated images and videos remain accessible in your account until you manually delete them or terminate your account.
• You can delete your generated content at any time through the App.

5.4 Account Data

• Your account information and usage data are retained for as long as your account is active.
• Upon account deletion, we will delete or anonymize your personal information within 90 days, except where retention is required by law.

5.5 Legal Retention

• Some information may be retained longer if required by law, for dispute resolution, or to enforce our agreements.
• Anonymized and aggregated data may be retained indefinitely for analytics and research purposes.

5.6 Health, Fitness, and Nutrition Data

Food log entries (including photos), weight history, water logs, fasting history, step counts, and walk routes are stored locally on your device for as long as you keep them in the App, and, where the App provides account sync, on our secure servers under your account. You can delete individual entries or your entire history at any time in the App. Deleting the App removes the locally stored copies from your device; if you use account sync, contact us at ismailturanli91@gmail.com to request deletion of any server-side copies.

6. YOUR RIGHTS AND CHOICES

6.1 Access and Control

• Access: You can access your personal information through your account settings.
• Correction: You can update or correct your account information at any time.
• Deletion: You can delete your generated content, uploaded content, health/fitness log entries, or entire account through the App or by contacting us. In Apps with a history feature, you can clear your on-device history at any time.
• Data Portability: You can request a copy of your data in a portable format, and, where the App offers a built-in export feature, download it directly from the App as a PDF or data file.

6.2 Communication Preferences

• You can opt out of promotional emails by following the unsubscribe link in any marketing email.
• You cannot opt out of service-related communications (e.g., subscription confirmations, security alerts).

6.3 Subscription Management

• Manage or cancel your subscription through your Apple App Store account settings.
• Subscriptions auto-renew unless canceled at least 24 hours before the renewal date.
• Uninstalling the App does not cancel your subscription.

6.4 Your Legal Rights (GDPR/CCPA)

Depending on your location, you may have additional rights:

• Right to Know: Request information about what personal data we collect and how we use it.
• Right to Delete: Request deletion of your personal information (subject to legal exceptions).
• Right to Object: Object to certain processing of your personal data.
• Right to Restrict: Request that we limit how we use your data.
• Right to Data Portability: Receive your data in a structured, machine-readable format.
• Right to Withdraw Consent: Withdraw consent for data processing where consent was the legal basis.

To exercise these rights, please contact us at ismailturanli91@gmail.com. We will respond to your request within 30 days.

7. CHILDREN'S PRIVACY

The App is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately, and we will delete such information.

Users between 13 and 17 years of age must have parental or guardian consent to use the App.

Feature-Specific Restriction: Certain features (including, where available, avatar creation or other features involving the processing of photos of real people) require users to be of legal age (18+). Any minor found using such a feature will have their access terminated.

Health and Fitness Apps: Calorie, weight, and body-tracking features are intended for adult, general wellness use and are not designed for children. If we become aware that a user under 13 has provided health or body-measurement data, we will delete it.

8. DATA SECURITY

We take the security of your information seriously and implement appropriate technical and organizational measures to protect your data:

• Encryption: All data transmitted between your device and our servers is encrypted using industry-standard TLS/SSL protocols.
• Access Controls: We implement strict access controls and authentication mechanisms to prevent unauthorized access.
• Secure Storage: Data is stored on secure servers with encryption at rest.
• Regular Security Audits: We conduct regular security assessments and updates to address potential vulnerabilities.
• Employee Training: Our team members are trained on data privacy and security best practices.

However, please note: No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You use the App at your own risk.

9. INTERNATIONAL DATA TRANSFERS

The App's services and servers may be located in various countries around the world. By using the App, you consent to the transfer of your information to countries outside your country of residence, which may have different data protection laws.

We ensure that any international data transfers comply with applicable data protection laws and that appropriate safeguards are in place to protect your information.

10. CALIFORNIA PRIVACY RIGHTS (CCPA)

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

• Right to Know: You can request details about the personal information we have collected about you in the past 12 months.
• Right to Delete: You can request that we delete your personal information.
• Right to Opt-Out: We do not sell your personal information. If our practices change, we will update this policy and provide an opt-out mechanism.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise your CCPA rights, contact us at ismailturanli91@gmail.com.

11. EUROPEAN PRIVACY RIGHTS (GDPR)

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

• Legal Basis for Processing: We process your data based on: (a) your consent, (b) performance of a contract, (c) compliance with legal obligations, or (d) our legitimate interests.
• Data Controller: TuranliApp (contact: ismailturanli91@gmail.com) is the data controller for your personal information.
• Your Rights: Access, rectification, erasure, restriction of processing, data portability, objection, and withdrawal of consent.
• Complaints: You have the right to lodge a complaint with your local data protection authority.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, service providers, legal requirements, or for other operational reasons.

When we make changes:

• We will update the "Last Updated" date at the top of this Privacy Policy.
• For material changes, we will notify you through the App or via email (if you have provided your email address).
• Your continued use of the App after any changes indicates your acceptance of the updated Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. CONTACT US

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

Data Controller: TuranliApp
Email: ismailturanli91@gmail.com

We will respond to your inquiry within a reasonable timeframe, typically within 30 days.

By using TuranliApp applications, you acknowledge that you have read, understood, and agree to this Privacy Policy.