Cliq

Privacy Notice on the Processing of Personal Data

This notice is provided to inform you under Article 10 of the Turkish Personal Data Protection Law No. 6698 (KVKK). We record that you have read this notice; this is not an approval or explicit consent. For processing based on explicit consent, your consent is requested separately, with its own text, when you first use the relevant feature.

1. Data controller#

Piksel Bayt Teknoloji Limited Şirketi · MERSİS: 0729131336500001 · Address: Ünalan Mah. Ünalan Cad. Kapı No: 1 Daire No: 02, Üsküdar/İstanbul · KEP (registered electronic mail): [email protected] · Email: [email protected]

Data Examples Purpose Legal ground
Identity and contact Name and surname, email, Apple or Google account ID Opening an account, signing in, account security notifications, support Establishment and performance of a contract (Art. 5(2)(c))
Sign-in and session security Encrypted digest of the sign-in code, sign-in times, device and installation ID Verifying sign-in, keeping the account open on only one device at a time, preventing abuse Performance of a contract; legitimate interest in the security of the account (Art. 5(2)(f))
Skin, hair and style profile Skin and hair type, appearance goals, age range, gender, ingredients you prefer to avoid (such as fragrance, alcohol) Personal recommendations, product compatibility result, ritual and routine Performance of a contract
Health data Pregnancy, breastfeeding or pregnancy planning; menopause; medicines you use; dermatological procedures in the last 4 weeks; diagnoses made by your doctor and your health conditions (such as rosacea, eczema, psoriasis, vitiligo, keloid, PCOS, thyroid, seizures, favism); hair loss pattern; your allergies and the allergens you avoid Filtering out ingredients that do not suit you, compatibility result, routine, safe personalization of assistant responses Explicit consent (Art. 6)
Health information in the cycle tracker and diary Period and cycle records you enter in My cycle; symptoms, period and notes in your Skin check-in Cycle tracking, showing changes in your skin in reports Explicit consent (Art. 6)
Health information in chat Information such as symptoms, medicines, diagnoses or pregnancy that you write or say to the assistant Generating responses, referring you to a doctor where needed Explicit consent (Art. 6); without consent, these details are masked before they reach the AI (§4)
Face and hair photos Skin and hair analysis photos; the appearance of dryness, oiliness, redness, texture, spots and pores measured from the photo; the appearance of your hair Skin and hair analysis, tracking change Explicit consent (Art. 6)
Try-on photos Try-on photos you save in Studio and the products tried Showing them in Your try-ons Explicit consent (Art. 6)
Diary photos Photos you add to your Skin check-in or a child's diary Keeping the record with photos, doctor summary Explicit consent (Art. 6)
Color measurement and face structure Color measurement photo, skin tone, eye and hair color measurements, facial proportions Color signature, shade matching, makeup recommendations Explicit consent (Art. 6); for a signature created from questions without a photo, performance of a contract
Belief preference Preference for halal-certified or vegan products Product recommendations and filters Explicit consent (Art. 6)
Dress and attire preference Headscarf or bonnet, modest clothing Hair care and outfit recommendations Explicit consent (Art. 6)
Voice assistant Your speech (processed in real time; no audio recording is kept) and its transcript Generating spoken responses Explicit consent (Art. 6), because health information may come up in conversation
Assistant chats Messages you write and the assistant's responses Generating responses, showing chat history Performance of a contract
Products and usage Your shelf, products you scan, lists, notes, ritual and routine records Features of the app Performance of a contract
Label photo Photo of the product label and the ingredients read from it Reading the ingredients and assessing the product Performance of a contract
Location Province and district (coordinates are not stored) Weather, UV and tap water information Performance of a contract; you can turn off location permission at any time
Preferences inferred from use The time you open the app, makeup occasion, routine length, budget tendency, the channel you prefer Suggesting a reminder time and ordering; visible in Profile › Assistant › "What I've noticed" Legitimate interest (Art. 5(2)(f)); a preference you mark as "Not right" is deleted and never inferred again. Health, belief and dress are never inferred; no inferences are made for users aged 18 and under
Usage records Screens opened and features used, session and installation ID, account ID while signed in; free text you type is not included Improving the product, fixing errors, support Legitimate interest (Art. 5(2)(f)); you can turn this off in Profile › Privacy & data
Device and error records Device model, app version, language, crash reports (without account ID) Security and fixing errors Legitimate interest (Art. 5(2)(f))
Traffic information Account ID, source IP address, connection time, type of service Hosting provider obligation under Law No. 5651 Expressly provided for by law and legal obligation (Art. 5(2)(a), (ç))
Missing product and error reports Product information you report (non-personal information such as name, brand, ingredients) Correcting the catalog Legitimate interest (Art. 5(2)(f))
Support requests Correspondence and your attachments Providing support Performance of a contract
Child profile (age 0–15) The profile, diary, photos and health information a parent enters for their child Care, ritual and diary suitable for the child For special categories of data, the parent's explicit consent; for the rest, performance of the contract concluded with the parent
Co-parent Invitation to a child profile, the parents' roles, who wrote each record Management of the child profile by two parents Performance of a contract; for sharing the child's special category data with the second parent, the explicit consent of the inviting parent
Consent to commercial electronic messages Email, name and surname, date and channel (email or notification) of consent or refusal Campaign and news messages Consent under Article 6 of Law No. 6563; legal obligation for notification to the İYS (Message Management System)
Personalized advertising Skin type, appearance goals, age range Advertising selected for you Explicit consent; not offered to users aged 18 and under. Health, belief, dress and attire, photos and color measurements are never used in advertising
Consent and acknowledgement records Which version of which text you approved or read, and when Proving compliance with obligations Legal obligation; establishment, exercise or protection of a right (Art. 5(2)(ç), (e))

Health data, belief and dress and attire come only from your own statement; they are not inferred from your behavior, the products you scan or your photos. When you turn off pregnancy, breastfeeding or pregnancy planning mode, this statement is deleted within 30 days.

3. Method of collection#

Your data is collected electronically through the app and partly by automated means: the questions you answer, the photos you take, what you write and the records created while you use the app. When you sign in with Apple or Google, identity information is obtained from these services. Support and application correspondence is received by email or KEP.

4. Artificial intelligence and automated assessment#

5. Transfers#

Your data is transferred to the recipient groups and countries below, only for the stated purpose. The names of the service providers are disclosed on request; how to apply is set out in §7.

6. Retention periods#

Data Period
Analysis, try-on, diary and color measurement photos Until you delete them, withdraw the relevant consent or your account is deleted. Deleting a photo does not delete the analysis results
Health answers, cycle, child diary Until you delete them, withdraw your health data consent or the profile is deleted. When pregnancy, breastfeeding or pregnancy planning mode is turned off, the statement within 30 days
Chats Until you delete them. In voice chat no audio recording is kept; the transcript for the same period as the chat
Label photo 90 days
Audit copy of AI responses 30 days; immediately when the related analysis, chat or account is deleted
Usage records and analytics 13 months; when the account is deleted, the link to the account is removed
Application logs (IP address only in hashed form) 14 days
Traffic information (5651) 1 year, in a separate encrypted record
Sign-in records (email only in hashed form) 1 year
Backups 35 days; the data of a deleted account in backups cannot be read because the encryption key is destroyed
Consent and acknowledgement records 10 years in pseudonymized form after the account is deleted
Commercial message consent and refusal records 3 years from the end of the consent
Support requests 2 years from closure; deleted together with the account when it is deleted, or kept until resolved if there is an open legal dispute
Data copy file 7 days

7. Your rights (KVKK Art. 11)#

By applying to Cliq, you have the right to:

In the app: Profile › Privacy & data (manage permissions, delete my data, copy of my data, consent history, delete account, object to usage records); "Object to this result" on a product result.

How to apply: [email protected] · KEP: [email protected] · in writing to Ünalan Mah. Ünalan Cad. Kapı No: 1 Daire No: 02, Üsküdar/İstanbul. Your identity is verified with a code sent to your account's email or with the Apple or Google account linked to your account. Your application is concluded free of charge within 30 days at the latest.

8. Website and cookies#

hellocliqai.com uses no strictly necessary cookies. Google Analytics cookies (_ga, _ga_*) are used to understand how the site is used only if you accept them; if you don't, no request is sent to Google.