Privacy Policy

1. Who we are

This Privacy Policy explains how TECHNOGRADE YAZILIM TEKNOLOJİ VE TİCARET LİMİTED ŞİRKETİ, a company registered in Türkiye, with its registered office at Merkez Mah., Feriköy Fırın Sok. No: 69/2, Şişli, İstanbul, Türkiye ("Company", "we", "us"), collects and processes personal data when you use the Pionare iOS application (the "App").

For the purposes of the Turkish Personal Data Protection Law No. 6698 (KVKK) and the EU General Data Protection Regulation (GDPR), the Company is the data controller for the personal data described below.

Contact for privacy matters: info@pionare.app

2. Summary

The short version:

• You do not need an account. We do not ask for your name, email address, or a password, and there is nothing to sign in to.
• You can create images in three ways: apply one of our styles to a photo, write your own description, or build a personal profile from photos of yourself and then create images of yourself.
• To create an image, your photo and your description are sent to a third-party AI provider, processed, and returned.
• Your personal profile is stored on your device, not in an account on our servers. You can delete it at any time.
• We use analytics, crash reporting, subscription, and advertising-measurement tools that collect device identifiers and usage data.
• We use your device's advertising identifier only if you allow it when iOS asks. The App works fully either way.
• Payments are handled by Apple. We never see your card details.

3. Data we collect

a) Photos you provide. To create an image, the App processes the photo you select. This photo may show identifiable people. Only use photos you have the right to use, and do not upload photos of other people without their permission.

b) Photos used to build a personal profile. If you choose to create a profile, you provide several photos of yourself. These are used to build a model of your appearance. Section 5 covers this separately, because it is the most sensitive processing in the App.

c) Descriptions you write. The text you type to describe an image, and any expanded or rewritten version of it produced by the App's writing assistant.

d) The style you select. An identifier for the preset style or category you chose.

e) Generated images. The images the App creates.

f) Purchase and subscription data. When you buy a subscription or a credit pack, Apple processes the payment. We, through our subscription provider, receive confirmation of the transaction and your entitlement status — for example active, expired, or in trial — together with your remaining credit balance. We do not receive your payment card number.

g) Identifiers. A device identifier, an installation identifier, and identifiers assigned by the tools listed in Section 8 (for example a subscription profile ID or an attribution ID). If you allow tracking when iOS asks, this also includes your device's advertising identifier (IDFA).

h) Usage and advertising data. Which features you use, how you move through the App, which screens and paywalls you see, how many credits you use, and which of our advertisements led you to install the App.

i) Technical and diagnostic data. Device model, operating system version, app version, language and region, crash logs, and performance data.

j) Support data. If you email us, we receive your email address and whatever you write.

Children. The App is not directed at children, and we do not knowingly collect personal data from anyone under the age of 13, or under the higher age of digital consent that applies where you live. If you believe a child has provided us with personal data, contact info@pionare.app and we will delete it.

4. Creating a single image

When you create an image:

• Your selected photo, the style you chose and any description you wrote are transmitted from your device to a third-party AI infrastructure provider (see Section 7).
• The provider runs the model and returns the generated image.
• The generated image is delivered back to your device.

Photos submitted this way are not retained by us after the image is produced. Generated images are stored on your device. If you delete the App, they are removed with it — export anything you want to keep.

5. Personal profiles

This is the most sensitive processing in the App, so we set it out separately and in full.

What a profile is. If you choose to create one, you provide several photos of yourself. They are used to build a model of your appearance — your "profile" — so that later images look like you without you having to supply photos each time.

This is data about your face. Depending on your jurisdiction, photographs of your face and a model derived from them may be treated as special category data under the GDPR, or özel nitelikli kişisel veri under the KVKK, and may be covered by specific biometric privacy laws in some countries and US states.

We rely on your explicit consent. We ask for your consent separately, before you create a profile — not as part of accepting these documents. You can withdraw it at any time by deleting your profile. Withdrawal does not affect processing already carried out.

Only your own likeness. You may only build a profile from photos of yourself. Creating a profile of another person is prohibited by our Terms of Use.

Where it is stored. Your photos are transmitted to a third-party AI provider to build the profile. The resulting profile is stored on your device, not in an account on our servers. The photos used to build it are not retained by us after the profile has been created.

How to delete it. You can delete your profile in the App at any time. Because the profile lives on your device, deleting it in the App or deleting the App removes it. If you have any question about data relating to you, write to info@pionare.app.

What we do not do. We do not use your profile or the photos behind it to train our own models. We do not use them to identify you, to match you against other images, or for any purpose other than generating images at your request. We never share a profile with other users, and we never share it with advertising networks.

Because there is no account, your profile is tied to your installation of the App. If you delete the App or change device, your profile is not recoverable and you will need to create it again.

6. Descriptions and the writing assistant

Text you type is sent to third-party AI providers in order to produce an image. If you use the writing assistant, your text is also sent to a language model that expands or rewrites it before generation.

Text is screened before generation, and generated images are screened before they are shown to you, in order to block content that is unlawful or that breaches our Terms of Use. Our AI providers apply their own safety rules as well, and may refuse to produce certain content.

7. AI processing providers

To generate images, to build profiles and to expand descriptions, the App transmits your photos and text to third-party AI infrastructure providers, who process them on our behalf as data processors.

Current providers:

• fal.ai (Features and Labels, Inc.)
• Replicate (Replicate, Inc.)
• OpenAI (OpenAI, L.L.C.)

Which provider is used depends on the style, model or feature you select. Each processes your data under its own terms and data-use policies. OpenAI, for example, states that it does not use data submitted through its API to train its models by default, and applies its own content restrictions which prevent certain material from being generated.

Future providers. We may add, replace, or use additional AI providers, including providers located outside Türkiye and the EU. When we do, we require them to protect your data under appropriate agreements and safeguards, and we update this policy to reflect material changes.

This processing involves transferring your data to servers located in other countries — see Section 13.

8. Third-party tools in the App

These providers act as processors or, in the case of advertising measurement, may act as independent or joint controllers under their own terms. None of them receives your photos, your profile, your descriptions, or the images you create.

Style catalogue. The App retrieves the list of available styles and categories from our servers, so that we can offer new styles without an app update. This request carries technical data such as your app version and device type; it does not carry your photos.

9. Advertising and tracking

We advertise Pionare on third-party platforms, and we need to connect an install or a subscription back to the advertisement you saw.

• During onboarding, iOS asks whether you allow Pionare to track you across apps and websites owned by other companies (Apple's App Tracking Transparency prompt).
• If you allow it, we and the providers in Section 8 may use your device's advertising identifier (IDFA) to measure and optimize our advertising, and may combine data from the App with data from other companies for that purpose. Under Apple's definitions, this is tracking.
• If you decline, we do not access your advertising identifier for this purpose. The App works fully either way — no feature, credit grant, or price depends on your answer.
• You can change your decision at any time in iOS Settings → Privacy & Security → Tracking.
• We do not sell your personal data, and we never share your photos, profile, descriptions or generated images with advertising networks.

10. How we use your data and our legal bases

Where we rely on consent, you may withdraw it at any time. Where we rely on legitimate interests, you may object.

11. How we share data

We do not sell your personal data. We share it only with:

• Apple — for app distribution and payment processing.
• AI providers — as described in Section 7.
• The providers listed in Section 8 — for analytics, crash reporting, subscription management, and advertising measurement. These do not receive your photos, profile, descriptions or generated images.
• Infrastructure and hosting providers — who help us run the service.
• Professional advisers and authorities — where required by law, to comply with legal process, or to protect our rights, our users, or the public.
• In a business transfer — if the Company is involved in a merger, acquisition, or sale of assets, subject to this policy.

12. Data retention

• Photos submitted to create an image, or to build a profile — transmitted to an AI provider for processing, and not retained by us afterwards. Our AI providers may retain inputs only for the limited period allowed under their own terms.
• Your personal profile — stored on your device, under your control, until you delete it or delete the App.
• Descriptions you write — retained only as long as needed to produce the image and to run safety screening.
• Generated images — stored on your device, under your control.
• Purchase and entitlement records — retained for 10 years, as required by Turkish tax and commercial law.
• Analytics, advertising, and diagnostic data — retained for a limited period in line with each provider's retention settings, and then deleted or aggregated.

Because there is no account, most of what identifies you is tied to your device and its identifiers. Resetting your advertising identifier or deleting the App breaks that link going forward.

13. International data transfers

We and our providers may operate outside Türkiye and the European Economic Area. Your personal data may therefore be transferred to and processed in other countries whose data-protection laws differ from those where you live. Where such transfers occur, we take steps to ensure an appropriate level of protection, for example through your explicit consent where the KVKK requires it, and through contractual safeguards such as the EU Standard Contractual Clauses where the GDPR applies.

14. Your rights

Depending on where you live, you have rights over your personal data, which may include the right to:

• learn whether we process your data and request access to it;
• request correction of inaccurate or incomplete data;
• request deletion of your data;
• object to or request restriction of certain processing;
• request portability of data you provided to us;
• withdraw consent at any time, without affecting processing already carried out; and
• lodge a complaint with a supervisory authority.

Under the KVKK you may exercise the rights set out in Article 11 and, if unsatisfied, apply to the Turkish Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu). If the GDPR applies to you, you may complain to your local data-protection authority.

Because the App has no account, we may need additional information — such as a device or subscription identifier — to locate data relating to you. To exercise your rights, contact info@pionare.app.

You can also act directly, without contacting us: delete your profile in the App, delete generated images, withdraw tracking consent in iOS Settings, or delete the App.

15. Security

We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, and misuse, including encryption in transit and access controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

16. Apple App Privacy

Apple requires us to disclose our data practices on the App Store product page (the "privacy nutrition label"). Those disclosures summarize the data described in this policy. If you spot an inconsistency, tell us at info@pionare.app so we can correct it.

17. Changes to this policy

We may update this Privacy Policy from time to time. We will update the "Last updated" date and, for material changes, provide additional notice such as an in-app message. Your continued use of the App after changes take effect indicates acceptance of the updated policy.

18. Contact

TECHNOGRADE YAZILIM TEKNOLOJİ VE TİCARET LİMİTED ŞİRKETİ Merkez Mah., Feriköy Fırın Sok. No: 69/2, Şişli, İstanbul, Türkiye Email: info@pionare.app