PRIVACY POLICY

This Privacy Policy was posted on May 4, 2025 and is effective for new and existing users of the app "Low Buy - Spending Tracker" (Application).

General statement

Your privacy is critically important to us. Your data is your own. We make no claims to it and will only use it according to the policies outlined below.

This policy was written in English. To the extent a translated version exists and that version conflicts with the English version, the English version controls.

We reserve the right to modify this Privacy Policy at any time as our Application changes. If we make changes to this Privacy Policy, the updated Privacy Policy will be posted in the Application in a timely manner. This policy will always be posted within the Mobile App.

This page informs you of our policies regarding the collection, use, and disclosure of data when you use our Application and the choices you have associated with that data.

The Application allows you to track your daily spending. It is not transmitted outside of the App. No Personally-Identifying Information is transmitted to external locations when using the Application.

The Application transmits non-personally identifiable information such as device type and operating system version. This is used in aggregate to help facilitate development decisions.

We use your data to provide and improve the Application. By using the Application, you agree to the collection and use of information in accordance with this policy.

Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of use.

DEFINITIONS

• Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage Data: Usage Data is data collected automatically either generated by the use of the Application or from the Application infrastructure itself (for example, the duration of an App visit).
• Data Subject: Data Subject is any living individual who is the subject of Personal Data.
• User: The User is the individual using our Application. The User corresponds to the Data Subject, who is the subject of Personal Data.

1. INTRODUCTION AND REMARKS

1.1. About Us

Provider of this Application and responsible person is Nurettin Resul TANYILDIZI, FENERBAHÇE MAH. İĞRİP SK. NO: 13 İÇ KAPI NO: 1 KADIKÖY/ İSTANBUL, Türkiye (referred to as the "Provider" as well as "we", "us" etc.).

"Low Buy - Spending Tracker" (Application) strongly believes that you have the right to control the use of your data, and that your privacy must be respected. We strictly limit the collection and processing of your data, and to the best of our abilities we will work only with other organizations who do the same. We will not use data that you provide to us in a manner inconsistent with the purposes for which you provided it to us, as set out below. We do not sell, rent or lease data. We will vigorously challenge any attempts by government agencies or private sector organizations to gain access to any information that you give us.

1.2. Our Core Principles

With this Privacy Policy we would like to inform you how we process data while providing you with the Low Buy - Spending Tracker - application software designed for smartphones and /or tablet computers (the "Application"), - which allows Users to track their spending.

The protection of your privacy is of the utmost importance to us, which is why it goes without saying that we comply with the statutory provisions on data protection.

PLEASE READ THIS PRIVACY POLICY CAREFULLY, AS YOUR ACCESS TO AND USE OF THE APPLICATION SIGNIFIES THAT YOU HAVE READ AND UNDERSTOOD THE TERMS WITHIN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, PLEASE DO NOT ACCESS OR CONTINUE TO USE THE APPLICATION, OR OTHERWISE SUBMIT YOUR DATA.

THIS POLICY MAY BE AMENDED OR UPDATED FROM TIME TO TIME, SO PLEASE CHECK IT REGULARLY FOR UPDATES.

You can find the definitions of terms that are not specified in this Privacy Policy, in our Terms of Use.

1.3. What information does the Application obtain

The Application does not provide an option to create an account therefore, we do not store nor have access to your entries and data. Your data are stored locally only on your device and personal iCloud.

We use your data to provide and improve the Application. We obtain your email address when you request support via email. We use your email only to contact you to provide support, feedback or important information.

1.4. What Data is Being Logged by Default

By continuing to use this Application, you've agreed to data collection. The Application collects some data that is essential for us to deliver our services, to understand your needs and to improve our services.

The Application automatically collects certain information that does not personally identify our end users who access or use Application. This information includes:

• Usage data (product interaction: such as Application launches, taps, clicks, scrolling information, or other information about how users interact with the Application; advertising data: such as information about the advertisements user have viewed; other usage data: any other data about user activity in the Application).
• Diagnostics (crash data: such as crash logs; performance data: such as launch time, hang rate, or energy use; other diagnostic data: any other data collected for the purposes of measuring technical diagnostics related to the Application).

The Application does NOT collect any personal data that directly identifies you such as your name, surname, or anything you type within the Application. The Application also does NOT collect any data about your health and fitness and it will NOT be used to track users.

Generally, we do not collect or keep a record of sensitive personal data and only do so in very limited circumstances, primarily when an individual has chosen to provide us with this data. On occasion we may also process sensitive personal data of others engaging with Application, for example where an individual provides us with information relating to accessibility needs for the purpose of obtaining and/or exchanging data or where an individual contacts Application and their communication includes sensitive personal data. We do not use this data for any other purpose other than that for which it is provided.

When using our Application, you are not required, as a statutory requirement or as a necessity to enter into a contract, to provide us with any personal data for processing as described in this Policy.

In the mobile app environment, data related to your device and its usage is treated with care and respect for your privacy. This includes device identifiers and app usage logs, which we collect to improve our services and ensure the app functions correctly.

When accessing sensitive (special categories of) data, stricter requirements apply under data protection laws. Please note that Low Buy - Spending Tracker does not collect any data that falls under these special categories.

Our Application does not directly collect, transmit, or use precise location data. However, third-party services we utilize, such as Sentry, may derive non-precise location information (e.g., country or city) from your IP address for the purpose of providing aggregated analytics. This information is used to evaluate user behavior, understand the effectiveness of existing product features, plan new features, or measure audience size or characteristics.

1.5. Third-Party Analytics

To help us understand how users interact with Low Buy - Spending Tracker, and to improve the app's performance and stability, we use the following third-party services:

• Sentry: This service is used for crash reporting, allowing us to identify and fix issues that might cause the app to crash. It helps us monitor app stability and improve the overall user experience.

1.6. Data Use

We process your data for the following purposes:

• Analytics (using data to evaluate user behavior, including to understand the effectiveness of existing product features, plan new features, or measure audience size or characteristics).
• Product personalization (customizing what users see, such as a list of recommended products, posts, or suggestions).
• To administer our Application functionality (such as to authenticate users in the Application, enable features, prevent fraud, implement security measures, ensure server uptime, minimize Application crashes, improve scalability and performance, or perform customer support).
• For corresponding with the user (to respond to any communications, queries or requests for information or services from you, however received).
• To comply with our legal or regulatory obligations.
• To establish, exercise or defend legal claims.

The Application may contain links to other websites or applications for whose content, function and compliance we are not responsible. Please inform yourself about the data protection regulations of the respective web pages with the respective operators.

The Application will only process personal data when we have a legal basis for doing so. The legal basis that we will rely on will depend on the circumstances in which we collect and use your personal data.

In almost all cases, the relevant legal basis to process personal data is that the processing will be one of the following:

• Based on your consent to use your data in a certain way (for example, to communicate with you through our mailing list). Your consent may subsequently be withdrawn at any time by editing your preferences or contacting us as specified in this Policy without affecting the lawfulness of processing based on consent before its withdrawal.
• Necessary in order to take steps prior to entering into a contract or for the performance of a contract (for example, for human resources management and to manage those carrying out work on behalf of PI);
• Necessary to comply with legal requirements (for example, to comply with applicable regulatory obligations and employment law);
• Necessary for our legitimate interests (for example, to administer our apps, to carry out research and investigations consistent with our mission). We will only rely on this legal basis where we've identified the purpose (the legitimate interest), assessed that the processing is necessary for that purpose and conducted a balancing test to ensure that this interest is not overridden by the interests, rights and freedoms of the individual.
• Children's Privacy: Our Application does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

1.7. Security

We implement appropriate technical and organizational measures to protect against unauthorized or unlawful processing of data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to data.

Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of data. You acknowledge that clearing Application data or uninstalling this application from your device or losing your device or device problem could result in loss of all data. You are responsible for backing up your data.

1.8. Purchases

Your purchases in the App Store and in-app-purchases are handled by Apple. We do not get access to your funds and banking data.

2. USER RIGHTS

2.1. Storage Period of the Collected Data

We retain the automatically collected usage and diagnostic data (as described in Section 1.4) for as long as it serves the purpose of analyzing and improving our Application. This data is generally retained in an aggregated and anonymized form. When you delete the Application from your device, the collection of new usage and diagnostic data ceases. Data stored in your personal iCloud is subject to your own data management practices within your iCloud account.

2.2. Data Sources

All the data we receive are received from you and/or your device only.

2.3. Legitimate Interests

When processing your data, we pursue the following legitimate interests:

• The improvement of our offer,
• The production of statistics,
• Informing about the Application's news and updates.
• The storage of our correspondence with you.
• To comply with a legal obligation
• To protect and defend the rights or property of Provider
• To prevent or investigate possible wrongdoing in connection with the Application
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

2.4. Making contact

We may provide emails or forms to which users of the Application can send us questions or comments, or which users can use to request customer support. In the process of receiving and responding to such requests, we may collect personal information about you, such as your email address or any other personal data contained in the body of your email message. By allowing you to send us these requests, we are not attempting to solicit personal information from you. We only use the information for the purpose of responding to your questions and/or comments or to provide customer support. Copies of your requests may be kept on file for our records, for quality control purposes, or to provide ongoing support services you have requested.

3. CHANGES TO THIS PRIVACY POLICY

We may change from time to time without prior notice to you. For this reason, we reserve the right to amend or update this Privacy Policy from time to time. When we update this Privacy Policy, we will also update the date at the top of this Privacy Policy. We encourage you to review the latest version of this Privacy Policy. The new Privacy Policy will become effective immediately upon publication. If you do not agree to the revised notice, you should alter your preferences or consider stopping using our Application. By continuing to access or make use of our Application after those changes become effective, you acknowledge that you have been informed and agree to the Privacy Policy as amended.

4. SUPPORT SERVICE

If you have any questions for a quick solution, you can use the e-mail: info@appday.co

The Support Service will take all possible efforts to quickly respond to the problem, it usually takes up to one business day.

If you want to receive any ordinary mail clarifications, then make an appropriate request to: info@appday.co

As part of providing the Application we may send you service announcements, technical notices, updates, security alerts and support-related messages through the Application or by email. We may also communicate with you in response to your support requests, questions or feedback.