PRIVACY POLICY

BraindPower Alpaco Yazılım Teknolojileri A.Ş. This Privacy Policy explains how Alpaco Yazılım Teknolojileri A.Ş. (“Alpaco”) collects, uses, shares, stores, and protects personal data of users of the BraindPower social media analytics platform.

1. Data Controller

In accordance with applicable data protection laws, including KVKK and GDPR where applicable: Company: Alpaco Yazılım Teknolojileri A.Ş. Address: Ayazağa Mahallesi, Kemerburgaz Caddesi, 7C Blok No: 7D/15, Sarıyer / Istanbul, Turkey Email: info@alpacotech.com Website: https://www.alpacotech.com/

2. Definitions

Personal Data: Any information relating to an identified or identifiable natural person. Data Subject: The individual whose personal data is processed. Processing: Any operation performed on personal data such as collection, storage, use, transfer, or deletion. Consent: Freely given, specific, informed, and unambiguous indication of the data subject’s wishes. Anonymization: Irreversibly preventing identification of a person.

3. Legal Basis for Processing

We process personal data based on: ● Performance of a contract ● Legal obligations ● Legitimate interests ● Explicit consent ● Data made public by the user

4. Types of Data Collected

4.1 Account Information

● Name and surname ● Username ● Email address

4.2 Social Media Integration Data

● Connected platform account information (Twitter, Instagram, YouTube, LinkedIn, etc.) ● Public profile data ● Followers, engagement, and performance metrics

4.3 Analytics and Usage Data

● Platform interaction data ● Behavioral insights ● Generated reports and analytics outputs

4.4 Device and Technical Data

● IP address ● Browser type ● Device model and operating system

4.5 Location Data

● Approximate location based on IP

4.6 Cookies and Tracking Data

● Session data ● Preferences ● Analytical tracking data

5. Purposes of Processing

We process personal data to: ● Analyze connected social media accounts ● Provide insights and reporting services ● Improve platform performance ● Enhance user experience ● Develop new features and services ● Ensure security and prevent fraud ● Fulfill legal obligations

6. Cookies and Similar Technologies

BraindPower uses cookies and similar technologies for: ● Session management ● Analytics ● Remembering user preferences Users may manage cookie settings via their browser.

7. Data Sharing

7.1 Service Providers

We may share data with third-party providers for hosting, analytics, and infrastructure services.

7.2 Social Media Platforms

Data exchange occurs with platforms that users connect to BraindPower.

7.3 Business Partners

Limited data sharing may occur for analytics and reporting purposes.

7.4 Legal Obligations

Data may be disclosed to authorities when required by law.

7.5 Corporate Transactions

Data may be transferred in case of merger, acquisition, or asset sale.

8. International Data Transfers

Personal data may be transferred to servers located outside the user’s country. Appropriate safeguards are implemented in accordance with applicable laws.

9. Data Security

We implement appropriate technical and organizational measures including: ● SSL/TLS encryption ● Access control systems ● Multi-factor authentication ● Logging and monitoring ● Regular security testing ● Data backup systems

10. Data Retention

● Account data: retained while the account is active ● Log data: up to 1 year ● Cookies: up to 13 months ● Analytics data: up to 12 months Data is deleted, anonymized, or destroyed after retention periods expire.

11. User Rights

Users have the right to: ● Access their personal data ● Request correction ● Request deletion ● Request restriction of processing ● Object to automated processing ● Request information about data transfers ● Claim compensation for damages Requests can be submitted via info@alpacotech.com.

12. Withdrawal of Consent

Users may withdraw consent at any time. Withdrawal does not affect the lawfulness of prior processing.

13. Policy Updates

This Privacy Policy may be updated periodically. Users will be informed of significant changes.

14. Contact

Company: Alpaco Yazılım Teknolojileri A.Ş. Email: info@alpacotech.com Address: Ayazağa Mahallesi, Kemerburgaz Caddesi, 7C Blok No: 7D/15, Sarıyer / Istanbul, Turkey Website: https://www.alpacotech.com/