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Privacy Policy

Introduction

We respect your privacy and are committed to protecting your personal data. This Privacy Policy (“Policy”) explains how HubX Yazılım Hizmetleri A.Ş. (“HubX”) collects, uses and protects your personal data, as well as your rights.

This Policy applies to QRCode’s app, website, and social media platforms (collectively, “QRCode” or the “Services”). Your use of the Services is also subject to our Terms of Use (“Terms”), which should be read together with this Policy.

By using QRCode, you acknowledge that you have read and understood this Policy and how your personal data is processed. If you do not agree with this Policy or the Terms, please do not use the Services.

Collection of Information and Processing Purposes

We may collect the following information and personal data when you access QRCode, or otherwise utilize (“use”) the Website, and/or the Services:

1. Personal Information and Contact Information

  • Google Account or Apple ID (whichever you preferred to log in), User ID, E-mail Address

This information is used to create a profile, create and save QR codes, and communicate with you through or about QRCode, updates or your requests.

2. Technical Data

  • IP address, logs, device type and name, operating system, type and date of subscription.

These data are processed for the purpose of ensuring the functionality of the app, crash and error detection, conducting technical analysis, carrying out the activity in accordance with the legislation and technical data security.

3. Customer Transaction

  • Subscription plan, billing cycle, receipt.

This data is processed for the purpose of determining the customer's subscription plan, providing and improving the services and membership plans, to follow and provide coin purchases. No credit card information is collected by us.

4. Images, Documents and Links

To create QR codes, users may voluntarily upload or provide content such as documents, images, social media links, or website links (“User Content”). We process this content only as necessary to provide the requested QR code functionality.

Users are responsible for the User Content you provide and should only create QR codes for content that you own or are authorized to use and share. Please do not upload or link to content that infringes the rights of others or that you are not authorized to use.

5. Marketing and Analytics Data

Analytics data, user preferences, interaction with marketing emails or ads (if any).

These data are processed for personalized advertising, direct marketing, performance tracking of campaigns upon your explicit consent. Please note that you may withdraw your consent any time.

6. The Information Disclosed by Users

Within the scope of the data minimization principle adopted in accordance with the GDPR, QRCode takes care not to process any data other than the above and is unnecessary for the application. Data that is not included in the app but shared through contact or other means is deemed to be disclosed by users. These are also protected within the scope of relevant legislation and adequate data protection measures.

Age Restriction: QRCode has an age restriction as it is not intended for Users under the age of 13. If you are under 13 years of age, please do not use or access the App and Website at any time or in any manner. By using the App and Website, you affirm that you are over the age of 13.

Parent/Guardian Use: Parents and guardians are strongly encouraged to notify QRCode if their children under the age of 13 are using the app. Please note that QRCode does not collect information from children under the age of 13 in accordance with the Children's Online Privacy Protection Act ("COPPA") as indicated in this Privacy Policy and the Terms.

Sharing of Information

Your personal data will not be sold, traded, or otherwise transferred to third parties for commercial purposes. Your data may be transferred for the reasons explained below:

  • (a) Service Providers: We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, customer service, and cloud services. This includes cloud providers (Google, CloudFlare), data analytics providers (Facebook, Google, Appsflyer, Firebase).
  • (b) Business and Communication Partners: We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we

jointly offer products or services. This includes service providers (Intercom, Firebase).

  • (c) Advertising Partners: We may share your personal information with third-party advertising partners. These third-party advertising partners may set technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g. page visited, location, time of day) upon your consent. These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as personalized advertising. This includes measurement partners (Firebase, Clarity).
  • (d) Analytics Partners: We may share anonymized usage logs and interaction data with analytics partners. This includes information like feature usage frequency, interaction patterns, and performance metrics. This data does not include your personal images, videos, or other user-generated content. The data is used exclusively for analytics to understand user engagement, identify areas for improvement, and enhance the functionality and performance of our application. This includes analytics partners (Google, Firebase).
  • (e) Law Enforcement and Public Authorities: We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Anonymized Data: We may use anonymized data for analytical purposes. Anonymized data is processed in such a way that it can no longer be attributed to a specific individual, ensuring your privacy is maintained. Please review the Data Destruction and Anonymization heading for the process.

Storage of Information

We are committed to ensuring that your personal data is stored securely and in compliance with applicable laws and regulations.

Retention of Personal Information

We may store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Data Destruction and Anonymization : When personal data is no longer necessary or the retention period has expired, we will either securely delete or destroy the data to prevent unauthorized access or retrieval, or we will anonymize the data. Anonymization involves

processing the data in such a way that it can no longer be attributed to you, ensuring that it can be used for analytical or research purposes without compromising your privacy. Once data is anonymized, it is irreversibly altered and cannot be traced back to any individual.

Security Measures

We take the security of your personal data very seriously and implement measures to ensure protection as of the General Data Protection Regulation (GDPR). Our key principles include:

  • Safety Measures: Personal data is processed within the company only by authorized personnel, in a way that is not publicly accessible, and verification or additional confidentiality declarations required in processing special data categories if available.
  • Access Controls: Access to personal data is restricted to authorized personnel only, ensuring that only those who need to access your information can do so.
  • Regular Security Audits : We conduct regular audits and assessments of our security practices to identify and address potential vulnerabilities.
  • Data Minimization : We only collect and retain personal data that is necessary for the purposes specified.
  • Incident Response Plan : We have established an incident response plan to quickly address any potential data breaches or security incidents.

While we strive to maintain a secure digital environment, yet no digital environment can be fully secure, we encourage users to take their own precautions when accessing and using the app, including utilizing relevant antivirus software, implementing a secure firewall, accessing the website over a safe Wi-Fi connection, and ensuring that the device used to access the app is secure and up to date.

QR Code and Link Safety: QR codes may direct you to third-party websites, social media pages, files, or other external content. Before opening a link through a QR code, you should check the destination and assess whether the link and its source are trustworthy and secure. Avoid opening suspicious or unfamiliar links or providing personal or sensitive information through websites you do not trust.

If you become aware of a potential security issue involving our app, please contact us so that we can investigate and, where appropriate, take necessary measures to address the issue.

Corporate Affiliates and Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of QRCode or any of its Corporate Affiliates. Please note that Corporate Affiliate means any person or entity which directly or indirectly controls, is controlled by or is under common control with QRCode, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate

Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Delete Account Policy

Users can request for deletion of their data at any time by sending mail to [email protected] with their User ID. To find your User ID, please open the app > navigate to the settings > you will see your User ID on the screen. After we receive your e-mail, we will review your request and process it as of GDPR. Once confirmed, the account and all associated personal data will be permanently deleted and cannot be recovered. Anonymized data that does not personally identify the user may be retained for analytical purposes. Account deletion results in the immediate loss of access to all services and subscriptions, which will be terminated without refunds. This action is irreversible. In cases where legal obligations or unresolved transactions exist, deletion may be delayed until those matters are resolved. For assistance or questions, please contact our support team.

Rights Under GDPR

The General Data Protection Regulation No. 2016/679 (GDPR) establishes a comprehensive framework for the protection of personal data within the European Union and the European Economic Area. Under GDPR, users have the following rights regarding their personal data as data subjects:

  • Right to Access: Obtain confirmation and access to personal data being processed.
  • Right to Rectification: Request correction of inaccurate or incomplete data.
  • Right to Erasure: Request deletion of personal data under certain conditions.
  • Right to Restrict Processing: Request limitation of data processing in specific situations.
  • Right to Data Portability: Receive personal data in a machine-readable format and transfer it to another controller.
  • Right to Object: Object to the processing of personal data, especially for direct marketing.
  • Rights Related to Automated Decision-Making: Not to be subject to decisions based solely on automated processing, unless certain conditions apply.

To exercise these rights, users must send an email or petition clearly stating the right they wish to enforce, along with their name and accurate contact details. A response will be provided within the legal time period.

California Residents

The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above.

We are also required to communicate information about rights California residents have under California law. You may exercise the following rights:

  • Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
  • Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
  • Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
  • Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us. Please note that we do not sell the personal information of our users. For more information about these rights, please contact us.

Updates to Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, legal requirements, or Services. The latest revision date will be indicated in the Policy, and updates will become effective when posted. We encourage you to review this Policy periodically. If you do not agree with any changes, please discontinue using the Services.

Contact

This privacy policy constitutes the entire understanding between you and us regarding the collection, use, and protection of your personal data. If you have any questions or concerns regarding this policy or our data practices, please contact us via [email protected]

HubX Yazılım Hizmetleri Anonim Şirketi Çınarlı Mah. Ankara Asfaltı Cad. No:15-411 Konak/İzmir

Last Update: August 2026