To exercise these rights, you can contact us by submitting a data subject access request, by email at [email protected], or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
If we decline to take action regarding your request and you wish to appeal our decision, please email us at [email protected]. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
If we decline to take action regarding your request and you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Utah Residents
This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Exercise your rights provided under the Virginia VCDPA
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
10. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:
- offer you the products or services that you want
- respond to or help with your requests
- manage your account with us
- confirm your identity and protect your account
Republic of South Africa
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
11. MORE ON OUR FACE DATA POLICY
Introduction
Our application, Young Face, is committed to advancing the personal well-being and skincare routines of our users through the power of artificial intelligence (AI) and deep learning algorithm. To fulfill this mission, we responsibly collect, use, and manage facial data.
Collection and Purpose of Face Data
At Young Face, we collect facial data by requesting users to upload a photograph of their face. This collection serves a dual purpose:
- To Analyze Skin Conditions: Your facial data allows our AI algorithms to assess various skin conditions accurately. This analysis is the cornerstone of generating a personalized face yoga program tailored to meet your unique skincare needs.
- To Enhance AI Accuracy: By analyzing diverse skin conditions across our user base, we continuously refine our AI algorithms. This iterative improvement process ensures our services become more effective and personalized over time.
- Progress Tracking: The storage of facial data is pivotal for the monitoring of user progress throughout the engagement with the personalized face yoga program. By evaluating initial facial data against subsequent data points, our deep learning algorithms are equipped to measure the efficacy of the skincare regimen, make necessary adjustments, and furnish users with objective assessments of their skin's progression. This mechanism is vital for the tailored adjustment and optimization of our services, aligning with the dynamic skincare objectives of our users.
Use and Transfer of Collected Data
- The collected facial data undergoes a secure transfer process from DGT YAZILIM SAĞLIK ve DANIŞMANLIK HİZMETLERİ A.Ş.'s AWS Servers to our second shareholder, TRUEYOGI WELLNESS TEKNOLOJİ A.Ş.'s Google Cloud Servers. This transfer is pivotal for:
Conducting in-depth skin analyses.
- Facilitating the ongoing enhancement of our AI's analytical capabilities. As co-shareholders, both entities access the data exclusively for these stated purposes, ensuring the integrity and confidentiality of your facial data.
Data Sharing, Storage, and Security
- We uphold the highest standards of data privacy and security. Accordingly, we guarantee that:
- No Third-Party Sharing: Your facial data is not shared with or sold to any third-party entities. Access is strictly limited to DGT YAZILIM SAĞLIK ve DANIŞMANLIK HİZMETLERİ A.Ş. and TRUEYOGI WELLNESS A.Ş.
- Secure Storage: All facial data is securely stored on AWS and Google Cloud servers, managed by DGT YAZILIM SAĞLIK ve DANIŞMANLIK HİZMETLERİ A.Ş. and TRUEYOGI WELLNESS A.Ş., respectively. These platforms are renowned for their robust security measures, ensuring your data's safety.
Retention and Anonymity
- To balance the benefits of AI enhancement with the paramount importance of privacy and security, we:
- Retain facial data anonymously for a period of 6 months. This duration supports our AI's learning process while safeguarding your privacy.
- Post-retention, all facial data is permanently erased, underscoring our commitment to data security and user privacy.
Our Commitment
At Young Face, we are deeply committed to protecting your privacy and ensuring the secure handling of your facial data. This policy outlines our practices, reflecting our dedication to transparency, security, and the responsible use of AI technology to serve your skincare needs.
12. HOSTING AND BACKEND INFRASTRUCTURE
This Application utilizes hosting and backend infrastructure services for the purpose of hosting data and files, enabling its operation and distribution, and providing an infrastructure for running certain functionalities. Among these services, Amazon Web Services (AWS), provided by Amazon Web Services, Inc., is employed. AWS may operate through geographically distributed servers, complicating the determination of the precise locations where Personal Data is stored. The types of Personal Data collected and processed by AWS are detailed in its privacy policy.
13. MORE ON RETENTION TIME
Personal Data will be processed and stored for as long as necessary for the purposes for which they were collected. Specifically, Personal Data required for performing a contract between the Owner and the User will be retained until the contract is fully executed. Data collected for the Owner’s legitimate interests will be kept as long as necessary to achieve these purposes, with details on these interests available in this document or upon request. If the User consents to data processing, such data can be retained until consent is revoked. Moreover, compliance with legal obligations or authorities’ orders may necessitate longer retention periods. Once the retention period concludes, Personal Data will be deleted, rendering the rights to access, erasure, rectification, and data portability unenforceable post-retention period.
14. MORE ON INFRASTRUCTURE MONITORING
This Application employs certain services to monitor usage and behavior of its components to enhance performance, operations, maintenance, and troubleshooting. The specific Personal Data processed by these services varies based on their characteristics and implementation, which are designed to filter the activity within the Application. Sentry, offered by Functional Software, Inc., is one such service, collecting various data types as outlined in its privacy policy, with data processing occurring in the United States. Another is Crashlytics, provided by Google LLC or Google Ireland Limited, depending on the Application's access location, which gathers data such as crash information, device specifics, and UUID, processing this data in the United States or Ireland, with the latter being a Privacy Shield participant.
15. MANAGING CONTACTS AND SENDING MESSAGES
Services that manage contact databases for email, phone, or other contact information enable this Application to communicate with the User. They may track when messages are viewed or interacted with, including link clicks. OneSignal, by Lilomi, Inc., is a messaging service allowing message and notification delivery to users on various platforms like Android, iOS, and web. Messages may be targeted to individual devices, device groups, or user segments. Collected data may include precise location, WiFi details, installed apps, and device identifiers used for interest-based advertising, analytics, and market research. Users can usually opt-out of push notifications and interest-based advertising through their device settings. Personal Data collected includes cookies, email addresses, geographic positions, languages, device identifiers, usage data, and more as outlined in OneSignal’s privacy policy, with processing in the United States and options to opt out available.
16. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:
DGT YAZILIM SAGLIK ve DANISMANLIK HIZMETLERI AS
Beşyol Mah. 1. İnönü Caddesi No.38/1 Küçükçekmece İstanbul Küçükçekmece VD
İstanbul 34000
Turkey
18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.