Privacy Policy – Chainz

Effective Date: 23.09.2026

This Privacy Policy has been prepared by JAI UYGULAMA VE YAPAY ZEKA TEKNOLOJİLERİ A.S ("the Company"), acting as the data controller, in accordance with Article 10 (Disclosure Obligation of the Data Controller) and Article 11 (Rights of the Data Subject) of the Turkish Personal Data Protection Law No. 6698 ("PDPL").

1. Principles of Personal Data Processing

Your personal data is processed:

In accordance with the law and good faith principles
Accurately and kept up to date
For specific, explicit, and legitimate purposes
In a manner limited and proportionate to the purpose
For the period required by relevant legislation or processing purpose

2. Collection of Personal Data

Your personal data may be collected:

Directly from you through the App (for example, when you create an account, set up your profile, write prompts, or create Chains and episodes)
Through your interactions with other users in the App (for example, invitations, continuing a Chain, sharing, reporting, or blocking)
Through customer support communications
Automatically via technical systems during app usage

Data is stored securely in the Company's systems and authorized third-party service providers.

3. Processed Personal Data and Purposes

The Company may process the following data:

User Information: username, email address, phone number, and profile details you choose to provide (such as display name, profile picture, or bio)
User Content: text prompts, selected story styles, the Chains and video episodes you create or continue, and content you share
Social and Interaction Data: Chains you start or join, invitations you send or accept, likes, comments, and other interactions, followers or connections (where available), and reports and blocks you make or that are made about you
Technical Data: device model, operating system, app version, performance data
Log Data: IP address (for security, fraud prevention, and legal obligations)
Purchase Status Data: information on whether a subscription or credit purchase has been completed, and your credit balance (payment card details are never received by the Company)

Purposes of processing include:

Creating and managing user accounts
Generating AI video episodes and providing Chain continuity, collaboration, feed, discovery, profile, and sharing features
Managing subscriptions, credits, and in-app purchases
Providing customer support services
Reviewing reports, moderating content, and enforcing our Terms of Service and community rules, including keeping the App suitable for all ages
Improving app performance and user experience
Preventing fraud and ensuring security
Complying with legal obligations

4. Information Regarding Mobile Applications

Downloading, using, or making in-app purchases in the App does not result in the direct transfer of personal data to the Company beyond what is technically required. All in-app purchases are processed via Apple App Store or Google Play Store. Even if you consent to personalized advertising, advertising-related interactions are processed anonymously. For users we know to be children, we do not enable personalized advertising, to the extent required by applicable law.

Third-party services used may include:

Adapty
Amplitude
AppLovin MAX
AppsFlyer
Facebook
Firebase
Unity

Each provider processes data under its own privacy policy.

AI Processing & Third-Party AI Provider (fal.ai)

When you use AI generation features, we transmit the following data to our third-party AI provider fal.ai to generate the requested episode:

the text prompt you write, including the prompt for the next episode of a Chain,
generation parameters you select (e.g., story style, model, or quality option),
context from earlier episodes of the Chain that is needed to keep characters, scenes, and story continuous,
any image you choose to upload as a reference, including any edits or crops you apply,
technical information required for delivery and security (e.g., app version, device type, request ID).

We request your explicit consent in the App before sending any image you upload to fal.ai. If you do not consent, the AI generation feature that requires the image will not run. For children, this consent must be given by a parent or legal guardian (see Section 12).

fal.ai processes this data only to provide the AI output, and is required to provide protection that is equal to or greater than the safeguards described in this Privacy Policy.

5. Visibility of Your Content and Collaborative Chains

Chainz is a social and collaborative application. Please be aware that:

Episodes in a Chain are visible to the participants of that Chain, and may be visible to other users through the feed, discovery, and creator profiles depending on the visibility of the Chain;
When you invite friends or continue a Chain started by another user, your username, profile information, and the episodes you create are visible to the other participants;
Content you share outside the App can be seen, copied, or further shared by others, and we cannot control how it is used once it leaves the App;
You should not include sensitive personal data (for example, health data, government ID numbers, or financial information) in your prompts, profile, or content;
Children should not share personal information such as their full name, address, school, or phone number in their profile, prompts, or content. Parents and guardians are encouraged to supervise their child's use of the social features, including invitations, sharing, and Chain participation.

Reports and blocks are used to protect the community and to enforce our rules. Information about who filed a report is not shared with the reported user.

6. Notifications

Push notifications (for example, Chain invitations, new episodes in your Chains, or account and purchase updates) are sent only with your explicit consent (for children, the consent of a parent or legal guardian). You can manage notification permissions via your device settings at any time.

7. Legal Grounds for Processing

Personal data is processed based on:

Explicit legal obligations (PDPL Art. 5/2-a)
Necessity for contract performance (Art. 5/2-c)
Fulfillment of legal responsibilities (Art. 5/2-ç)
Establishment, use, or protection of legal rights (Art. 5/2-e)
Legitimate interests of the data controller, provided that they do not harm your fundamental rights and freedoms (Art. 5/2-f), such as security, fraud prevention, content moderation, and service improvement

Processing under these grounds does not require explicit consent.

8. Processing Based on Explicit Consent

Certain optional data (such as profile details) may be processed only if you voluntarily provide consent. Sending images you upload to our third-party AI provider, as described in Section 4, is based on your explicit consent. Marketing communications (e-mails, notifications) are sent only if explicit consent is given and can be withdrawn at any time. Withdrawal of consent does not affect prior lawful processing.

Where the user is a child or otherwise a minor, any explicit consent required under this Privacy Policy is valid only if given by, or with the approval of, the child's parent or legal guardian. We do not send marketing communications to children.

9. Transfer of Personal Data

Personal data may be transferred without consent when required:

To authorized service providers, including our AI generation, analytics, attribution, and advertising partners listed in Section 4
To banks, legal advisors, auditors
To judicial and administrative authorities

Transfers are limited, proportionate, and compliant with PDPL Article 8.

10. Access to Data from Abroad

Personal data is stored on servers located in Turkey. Limited access from abroad may occur for technical support purposes and is based on explicit consent under PDPL Article 9.

11. Data Security, Retention, and Destruction

The Company implements appropriate technical and administrative security measures.

User account data: retained for 10 years after last activity
Purchase-related data: retained for 10 years
Marketing data: retained for 2 years after last activity
User Content (prompts, episodes, Chains): retained until you delete it or your account, unless retention is required for legal reasons or for the purposes of safety and moderation

When you delete your account, your personal data is deleted, destroyed, or anonymized in accordance with the periods above. Episodes that other participants have already built upon may remain as part of a Chain in a form that no longer identifies you, so that the story stays continuous for the other participants.

You can delete your account through the App or by contacting us at the e-mail address below.

After retention periods, data is deleted, destroyed, or anonymized.

12. Children

Chainz is rated Age 4+ and is designed to be suitable for all ages, so children may use the App. Because of this, we handle children's data with additional care:

Children may use the App only under the supervision of a parent or legal guardian. Children under the age of majority in their country may use the App only with the consent of a parent or legal guardian, and children under 13 (or below the minimum age required to consent to the processing of personal data in their country, if higher) must have a parent or legal guardian accept the Terms of Service and this Privacy Policy on their behalf.
We collect only the data that is necessary to provide the App, and we do not require children to provide more personal data than is needed for the App to work.
Any explicit consent requested in the App (such as sending an uploaded image to our AI provider, or push notifications) must be given by the parent or legal guardian for a child.
We do not knowingly use children's personal data for marketing communications or personalized advertising, and we do not sell children's personal data.
Content in the App is moderated to keep it suitable for all ages, and parents and guardians can use the reporting and blocking features described in Section 5.
In-app purchases must be made by, or with the permission of, a parent or legal guardian. Parents can also use their device's parental controls (such as Apple Screen Time or Google Family Link) to manage downloads, purchases, and content access.

A parent or legal guardian may contact us at any time to review, correct, or delete their child's personal data, to withdraw consent, or to have their child's account deleted, and may exercise the rights in Section 13 on behalf of their child. If you believe a child has provided us with personal data without the required parental consent, please contact us and we will delete it.

13. Your Rights as a Data Subject

Under PDPL Article 11, you have the right to:

Learn whether your data is processed
Request information regarding processing
Learn the purpose of processing and whether it is used in accordance with that purpose
Learn the third parties to whom your data is transferred
Request correction or deletion
Request that corrections and deletions be notified to third parties to whom your data was transferred
Object to automated decision-making
Request compensation for unlawful processing

For children, these rights may be exercised by their parent or legal guardian.

Requests can be sent to: E-mail: non-gaming@jaitech.ai

14. Complaint Right

If your request is not resolved, you may apply to:

Personal Data Protection Board (KVKK) Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4 06520 Balgat / Ankara – Turkey Phone: +90 312 216 5000 Web: http://www.kvkk.gov.tr/