Update Date: 12 March 2023

RossAI Privacy Policy

1. Introduction and Data Controller

As UNİVERLİST TEKNOLOJİ SANAYİ VE ANONİM ŞİRKETİ located at Erzene Mah. Ankara Cad. , Ebiltem Blok No: 172/14 Bornova, İzmir/TÜRKİYE, (hereinafter referred to as “Company” or “we” or “our” or “us”), we want our users or customers (hereinafter referred to as “you” or “your”) to be confident that their personal data is safe and secure with us. For this reason, the mobile app named RossAI (hereinafter collectively referred to as the App), which is established, designed and operated by Company, shall collect, process and store your personal information as a result of visiting or using the App.

This Privacy Policy is adopted for the continuance and improvement of the activities carried out by Univerlist in line with the principles outlined in the PDP Law. This Privacy Policy explains which data we collect, how we intend to use, store, protect and share the data we collect, how you can withdraw your consent for the processing of these data, and how you can correct and edit the data. Capitalized terms in this Policy shall have the meanings specified in the Terms and Conditions unless defined separately in this Policy.

2.Collection of Personal Data and Methodology

The company may process your personal data for the purposes specified in this Privacy Policy.

The personal data of users collected and used by Univerlist in particular are as follows: your name and surname, e-mail address and phone number which we will receive once you contact Univerlist, your order information if you purchase in-app purchase, the photo which you have uploaded to RossAI application (RossAI) and an identifier for advertisers designated in your mobile device used in accessing our services (The Identifier for Advertisers-IDFA), an identifier for vendors/developers designated your mobile device (The Identifier for Vendors-IDVF) and Internet Protocol Address-IP Address. We collect your username, password, and e-mail address information only when you sign up to RossAI and become a member through Registration.

Identity Information	Name and surname
Contact Information	Phone number, e-mail address
Process Security	Internet traffic data (network movements, IP address, visit data, time and date information), device name, In-app purchase history, Token ID (when you allow notifications through your device), identifier for advertisers designated in your mobile device used in accessing our services(if you give a permission, the Identifier for Advertisers-IDFA), identifier for vendors/developers designated your mobile device (The Identifier for Vendors-IDVF)
Visual and Audio Records	The photos you have uploaded to RossAI
Customer Transaction	Order Information
Marketing Data	IDFA, IDVF

We may collect your aforementioned data directly from you through electronic or physical mediums, your mobile device, third-party applications, or third-party sources which you can access our application via these mediums such as Apple App Store, Google Play App Store (similar platforms together with “App Stores”), for compliance with legal obligations, enhancing our services, administering your use of our services, as well as enabling you to enjoy and easily guide our services.

We may collect your log data generated while you are using our services/applications (through our products or third party products). This log data may include information such as your device’s Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our service/application, the time/date of your use of the service/application, and other statistics.

3.General Bases Concerning Personal Data Processing

In accordance with this Privacy Policy, personal data are processed by Univerlist as a data controller in line with the basic principles listed here:

being in accordance with law and good faith,
being proper and, where necessary, up-to-date,
being processed for specific, direct and legitimate purposes,
being limited for the objective for which they are processed and data minimization; and
being stored for the period prescribed in the relevant legislation or required for the purpose for which they are processed.

a) Purposes of Processing Personal Data

Identity Information Contact Information	execution of activities in compliance with legislation execution of company / product / service commitment operations execution of communication activities execution/auditing of business activities execution of goods/services sales processes execution of agreement processes conducting storage and archive activities
Process Security	execution of information security processes delivering information to authorized individuals, establishments, and organizations execution/audit of business actions
Visual and Audio Records	conducting storage and archive activities execution of agreement processes execution/auditing of business activities
Customer Transaction	execution/auditing of business activities execution of agreement processes
Marketing Data	conducting marketing analysis studies execution of advertising / campaign / promotion processes

Moreover, the purposes of processing personal data may be updated in line with obligation and legislation.

b) Legal Grounds of Collection

Identity Information Contact Information Customer transaction	execution of performance of the contract legitimate interest explicit consent legal obligation
Visual and Audio Record	legitimate interest explicit consent execution of performance of the contract
Process Security	execution of performance of the contract legitimate interest
Marketing Data	explicit consent

Third Party Websites and Applications

RossAI may include links to other websites that are unknown to Univerlist and whose content is not controlled. These linked websites may contain terms and conditions other than Univerlist texts. Univerlist cannot be kept responsible for the use or disclosure of information that these websites may process. Likewise, Univerlist shall not have any responsibility for any links from other sites provided to RossAI.

Push Notifications

RossAI may once in a while send you to push notifications via its mobile applications regarding application upgrades or notifications about our services. You can always edit notification preferences through the settings on your device and stop receiving such notifications.

Your data will be stored for the period specified in the applicable legislation or for a reasonable time until the purpose of the processing ceases to exist, or during legal periods of limitation.

Univerlist may continue to store your personal data, even after the expiry of the intention of its use delivered that it is required by other laws or a separate grant by you in this regard.

In circumstances where you allow Univerlist to store your personal data for extra time by giving your permission, such data shall be immediately deleted, destructed, or anonymized upon the expiry of such additional time or once the objective of processing no longer exists.

4.Domestic and Cross-Border Transfers of Personal Data

Cloud server services are provided by Amazon Web Services; therefore, the location of the servers is in Frankfurt, Germany. In this context, your personal data collected while visiting, enrolling, or using our Platform regardless of your status as a member, visitor, or user are transferred to Frankfurt.

In addition, your name, Contents, IP address, and Session IDs may be shared with public institutions and organizations authorized to request personal data to fulfill our legal obligations under the applicable laws.

Your payment information and name will be shared with the payment service providers via our Platform. Your internet or other electronic network activity information, device information, IP address, and session IDs will be shared with analytics providers for our Platform.

5.Your Rights

Privacy laws provide certain rights for data subjects. In this context, you have a right to:

Learn whether or not your personal data have been processed;
Request information as to processing if your data have been processed;
Learn the purpose of processing personal data and whether data are used following their purpose;
Know the third parties in the country or abroad to whom personal data have been transferred;
Request rectification in case personal data is processed incompletely or inaccurately;
Request deletion or destruction of personal data;
Request notification of the operations to third parties to whom personal data have been transferred in case of any rectification or deletion or destruction;
Object to the occurrence of any result that is to your detriment utilizing analysis of personal data exclusively through automated systems;
Request compensation for the damages in case you incur damages due to the unlawful processing of personal data.

You can claim your rights by sending an email to [email protected] along with your name, surname, ID number or passport number, your nationality, address, phone number and the subject of your claim.

This Privacy Policy may be revised by our Company when deemed necessary. If you continue to access RossAI and use, you shall be deemed to have allowed the changes in this Privacy Policy.