Privacy Policy of Bubi

«Bubi» is an interactive training service provided by Prisma Yazılım Limited Şirketi ("Company"). Our services ("Services") include a wide range of language content and courses from elementary to advanced level. This content is available in applications ("Apps") for various operating systems that can be downloaded to a mobile phone and/or a tablet.

This Privacy Policy explains which personal data (defined below) we collect through the Services, how we use and transmit this data, and your options in relation to our data processing practices.

This Privacy Policy is part of our Terms of Use, which are available at https://enbubi.com/terms.html.

By providing us with your personal data when using the Services, you agree to the processing of your personal data as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Services.

1. The Personal Data We Collect

When you interact with our Apps, we collect data that can be used separately or in combination with other information to identify you ("Personal Data").

Personal data that you provide us. When you register or use the Services, you voluntarily provide us with certain Personal Data, including your name (surname), e-mail address, and photo. If you register your account via your social network account (such as Facebook, etc.), the information we receive from these accounts depends on your settings and the Privacy Policies of these social networking platforms. Please consult their policies to understand how to maintain confidentiality on these platforms.

We may also collect information not related to Personal Data, such as your time zone or language.

Automatically collected data. When you use the Services, our systems automatically create and record the following information:

• Event log data: Information ("event log data") that Apps send automatically when you use them. Event log data includes your Internet protocol ("IP") address, browser type and settings, date and time of your request, and information on your interaction with the Services.
• Device Information: Includes device type and settings, operating system, unique device identifiers, network information, and other device-related data. The information we collect may depend on the type of device you are using and its settings.
• Activity Information: We collect information about how you use our Services, such as the types of content you view or engage with, the functions you use, the actions you take, the other users you interact with, and the frequency and duration of your activity.
• Advertising Data: Our Apps display advertisements through cas.ai and other third-party advertising networks (e.g., Google AdMob, Facebook Audience Network, AppLovin, UnityAds). These networks may automatically collect certain data to deliver personalized ads and analyze ad performance. This data may include device identifiers (e.g., IDFA or GAID), IP address, device type, operating system, ad interaction data (clicks, views, etc.), and, if enabled, approximate location data. The data collected is subject to the privacy policies of the advertising networks listed in our app-ads.txt file. You can view the full list of our advertising partners at https://enbubi.com/app-ads.txt.

When you make in-app purchases, our Apps collect specific information to enhance your experience and manage your purchases effectively. If you request a refund for a purchase, Apple may ask us for additional details regarding your use of that purchase. This data helps Apple make informed decisions about refund eligibility and provides us insights to improve our Services.

2. How We Use the Data

We use the collected data to:

• Authenticate users, provide Services, process transactions, and respond to your requests. For users within the EU, this usage is necessary to fulfill the terms of the contract with them.

When necessary, for legitimate business interests, which include the following actions:

• Adapt the training experience and degree of complexity to the level and needs of our users;
• Understand how visitors interact with our Apps and ensure that the Services are provided in the best possible way;
• Send e-mail messages that we believe will interest you;
• Conduct research or promote research and publish scientific papers. We may transfer collected information in an anonymous and impersonal form to researchers who help us improve the learning tools of the Services. We may also use this information to publish works on language studies;
• Analyze information to support our marketing strategy and ensure the improvement and personalization of our messages and the opportunities we offer to our users.

We may anonymize, de-identify, and/or aggregate the information we collect and use such anonymous, de-identified, and/or aggregated data for commercial, statistical, and market research purposes, including transferring this data to affiliated persons and business partners.

Mobile Analytics

We use mobile analytics software to better understand the functionality of our mobile software on your device. This software may record information such as how often you use the Apps, events that occur within the Apps, aggregated usage, performance data, and where the App was downloaded. We may combine the information stored in the analytics software with any personal information you provide in the mobile app.

We use third-party trackers to inform us when users visit our Apps by clicking on our ads or content hosted on third-party platforms.

The Apps use Google Analytics, Facebook Analytics, Firebase, AppsFlyer, AppMetrika, and Crashlytics to collect statistical information. Analytics information helps us estimate the exact number of App visitors and utilization capacity. For more information about how these analytics providers process this information, please visit their respective websites.

Marketing and Personalized Advertising

We cooperate with third parties, such as Facebook, to manage our advertising of Apps on other websites or platforms. Our third-party partners may use cookies or similar technologies to collect information about your activity within the Apps to provide you with advertising, such as retargeting ads.

cas.ai and other third-party advertising networks may use device identifiers (e.g., IDFA or GAID), IP addresses, and ad interaction data to deliver personalized advertisements tailored to your interests. These ads help support the free availability of our Services. You can manage your advertising preferences as follows:

• iOS Users: Go to Settings > Privacy > Advertising and enable "Limit Ad Tracking."
• Android Users: Go to Settings > Google > Ads and select "Opt out of Ads Personalization."
• You can also visit the opt-out pages of major advertising networks, such as Google Ad Settings, Facebook Ad Preferences, or other networks listed in our app-ads.txt file, to manage your ad preferences.

We will send you updates and information about our new products and services, upcoming events, or other advertising campaigns or news via email or pop-up notifications. In cases required by law, we will send you marketing information only with your consent, provided when you share your Personal Data. You can opt out of receiving such emails by following the instructions in each promotional email we send, updating your user settings, or contacting us at info@enbubi.com. We will continue to contact you by email regarding the provision of our Services and to respond to your requests.

3. Data Transfer and Disclosure

We may transfer your Personal Data and other information to certain third parties in the following cases:

• Developers and service providers. To help us meet the needs of business operations and perform certain services and functions, your Personal Data may be transferred to third-party providers of hosting services, email delivery, customer support services, analytics, marketing services, and advertising (including Amazon and Google web services in the USA, which have certificates of the Program for Protection of Confidential Information).
• Advertising Networks. We may share device identifiers, IP addresses, ad interaction data, and other relevant data with cas.ai and other third-party advertising networks to deliver personalized ads and analyze ad performance. These networks process data in accordance with their own privacy policies. You can view the full list of our advertising partners at https://enbubi.com/app-ads.txt. The privacy policies of major advertising networks can be accessed at:
  • Google Privacy Policy
  • Facebook Privacy Policy
  • AppLovin Privacy Policy
• Transfer of control over the Company. If we participate in a merger, acquisition, financing, reorganization, bankruptcy, compulsory liquidation, sale of all or part of our assets, or transfer of the Service to another provider, your Personal Data and other information may be transferred to the assignee or an affiliate during this operation.
• Legal requirements. If required by law, applicable regulatory document, or in a good-faith belief that such actions are necessary to (1) comply with a legal obligation, (2) protect the rights or property of the Company, (3) act in urgent circumstances to protect the personal safety of our users or the public, or (4) protect the Company from legal responsibility.
• Apple Refund Verification. If Apple requests it for refund verification purposes, we may share the following information related to your in-app purchase usage:
  • Account Tenure: The duration of your account with us.
  • Consumption Status: Details on how and if the purchased item was used.
  • Customer Consent: Your agreement to share this information.
  • Delivery Status: Information about any delivery of digital goods or services.
  • Lifetime Purchases and Refunds: Total dollar value of purchases and refunds on your account.
  • Platform Information: The device and operating system used for the purchase.
  • Play Time: The amount of time the in-app purchase was utilized.
  • User Status: Information about your activity status within the app (e.g., active, inactive).
  This information will only be shared if Apple requests it for the purpose of refund review and in accordance with Apple’s policies.

4. Storage of Information

We will store your Personal Data as long as reasonably necessary to achieve the objectives described in this Privacy Policy, when we have a legitimate business need, or in accordance with legal requirements (e.g., for tax, legal, accounting, or other purposes), depending on which period is longer.

Advertising data collected by cas.ai and other third-party advertising networks is stored in accordance with their respective privacy policies. For more information, please refer to the privacy policies of the networks listed in our app-ads.txt file.

5. Updating Personal Data

If you need to change or correct your Personal Data, or you want to remove it from our systems, please contact us at info@enbubi.com. We will consider your request in accordance with applicable law. You can also update your Personal Data directly in your user settings.

6. Rights According to EU Regulations

Scope of application. This section provides information on your rights under EU law (for this purpose, the reference to the EU also includes the countries of the European Economic Area: Iceland, Liechtenstein, and Norway).

Operator of Personal Data. Prisma Yazılım Limited Şirketi is the operator of your Personal Data. Our registered office is located at Esenler mah. Horasan sok. No:4/32 Selçuklu/Konya, Turkey.

Your rights. In accordance with EU regulations, you have the following rights with respect to your Personal Data:

• Right of access. Upon your request, we will confirm whether we process your Personal Data, and if so, we will provide you with a copy of this Personal Data along with additional details. If you need additional copies, you may need to pay a reasonable fee.
• Right to make corrections. If your Personal Data is inaccurate or incomplete, you have the right to ask us to correct or update it. If we have transferred your Personal Data to third parties, we will notify them of the correction, if possible. Upon your request, and if it is possible and legal, we will also inform you about the third parties to whom we have transferred your Personal Data so that you can contact them directly.
• Right to delete information. You can ask us to delete your Personal Data in certain cases, for example, if we no longer need it or if you withdraw your consent (if applicable). If we have transferred your Personal Data to third parties, we will inform them about the need to delete the data, if possible. Upon your request, and if it is possible and legal, we will also inform you about the third parties to whom we have transferred your Personal Data so that you can contact them directly.
• Right to limit the processing of Personal Data. You can ask us to restrict or "block" the processing of your Personal Data in certain circumstances, for example, when you dispute the accuracy of the data or object to their processing. We will notify you before we remove any data processing restrictions. If we have transferred your Personal Data to third parties, we will notify them of the restriction, if possible. Upon your request, and if it is possible and legal, we will also inform you about the third parties to whom we have transferred your Personal Data so that you can contact them directly.
• Right to transfer data. You have the right to receive your Personal Data that you consented to provide or that was provided as necessary under the contract with the Company. We will provide your Personal Data in a structured, commonly used, and machine-readable format. You can reuse it elsewhere.
• Right to object. You can request us to stop processing your Personal Data at any time if we rely on legitimate interests (described in the section "How We Use the Data") for processing, unless we provide compelling legal grounds for processing, or if we process your Personal Data for direct marketing.
• Rights in relation to automated decision-making and profiling. You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless this is necessary for the contract with the Company or you have given your consent.
• Right to withdraw consent. If we rely on your consent to process your Personal Data, you have the right to withdraw this consent at any time, but this will not affect the processing already completed.
• Advertising Data Rights. If you have consented to the collection and processing of data for personalized advertising, you can withdraw this consent at any time. Withdrawing consent will not affect prior data processing. You can also limit ad tracking through your device settings or visit the opt-out pages of advertising networks listed in our app-ads.txt file.
• Right to file a complaint with the Data Protection Authority. If you are concerned about our methods of protecting confidential information, including how we process your Personal Data, you can report it to the Data Protection Authority authorized to handle such matters.

Please contact us at info@enbubi.com to exercise your rights.

Legitimate interest. "Legitimate interests" are our interests in running our business, managing, and providing you with better Services. This Privacy Policy describes when we process your Personal Data to satisfy our legitimate interests, what these interests are, and your rights. We will not use your Personal Data in ways that outweigh your interests unless we have your consent or when such actions are required or permitted by law.

7. California Consumer Privacy Act (CCPA) Rights

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

• Right to Know. You have the right to know what personal information we collect, use, and share.
• Right to Delete. You have the right to request the deletion of your personal information, subject to certain exceptions.
• Right to Opt-Out of Sale. You have the right to opt out of the "sale" of your personal information (as defined under CCPA). cas.ai and other advertising networks may share data for personalized advertising, which may be considered a "sale" under CCPA. You can opt out by limiting ad tracking in your device settings or contacting us at info@enbubi.com.
• Right to Non-Discrimination. You will not be discriminated against for exercising your CCPA rights.

To exercise these rights, please contact us at info@enbubi.com. We may need to verify your identity before processing your request. For more information about data shared with advertising networks, please review our app-ads.txt file.

8. Public Information

This Privacy Policy does not apply to any information you post in public areas of the Services, such as comments in blogs or public forums. Such information may be viewed and used by third parties in accordance with their rules and privacy policies.

9. Children

Prisma Yazılım Limited Şirketi does not intentionally collect Personal Data from children under 13. If our Apps are directed to children under 13, we comply with the Children’s Online Privacy Protection Act (COPPA) by displaying only contextual advertisements and limiting personal data collection. cas.ai and other advertising networks operate in accordance with their own privacy policies for child-directed content. You can view the full list of our advertising partners at https://enbubi.com/app-ads.txt. If you believe a child under 13 has provided Personal Data through our Services, please contact us at info@enbubi.com, and we will endeavor to remove this information from our databases.

10. Links to Other Applications

Our Apps may contain links to other websites or applications not managed or controlled by us ("Third-Party Sites"), including social networking services. The information you share with Third-Party Sites is governed by their privacy policies and terms of use, not this Privacy Policy. By providing these links, we do not imply approval or endorsement of these sites. Please contact these sites directly for information on their data protection and privacy policies.

11. Data Protection

We take reasonable administrative and technical measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, modification, or destruction. However, no method of data transmission over the Internet is 100% secure. While we strive to protect your data, we cannot guarantee its absolute security.

Data collected by cas.ai and other third-party advertising networks is secured in accordance with their respective privacy policies. For more information, please refer to the privacy policies of the networks listed in our app-ads.txt file.

12. Changes to the Privacy Policy

We may update this Privacy Policy at any time. When we do, we will publish an updated version on this page and notify you through the Apps or other means as required by law. By continuing to use the Apps or providing information after the updated Privacy Policy is published, you agree to the revised Privacy Policy and its practices.

Additionally, our advertising partners are listed in our app-ads.txt file, which may be updated periodically. We encourage you to review this file regularly for updates.

13. Contact Us

If you have any questions about this Privacy Policy or our data processing practices, please contact us at info@enbubi.com.