Milena: AI Photo Video Maker ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by Milena: AI Photo Video Maker.

This Privacy Policy applies to our website and its associated subdomains (collectively, our "Service") alongside our application, Milena: AI Photo Video Maker. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

Definitions and Key Terms

To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, they are strictly defined as:

• Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics, and remember information about you such as your language preference or login information.
• Company: when this policy mentions "Company," "we," "us," or "our," it refers to Denali Digital Bilişim Limited Şirketi, which is responsible for your information under this Privacy Policy.
• Country: where Milena or the owners/founders of Milena are based, in this case, Turkey.
• Customer: refers to the company, organization, or person that signs up to use the Milena: AI Photo Video Maker Service to manage and enhance their media content.
• Device: any internet-connected device such as a phone, tablet, or computer that can be used to visit Milena and use its services.
• IP Address: Every device connected to the Internet is assigned a number known as an Internet Protocol (IP) address. These numbers are usually assigned in geographic blocks and can often be used to identify the location from which a device is connecting to the Internet.
• Personnel: refers to those individuals who are employed by Milena or are under contract to perform a service on behalf of one of the parties.
• Personal Data: any information that directly, indirectly, or in connection with other information—including a personal identification number—allows for the identification or identifiability of a natural person.
• Service: refers to the AI-powered photo and video creation services provided by Milena: AI Photo Video Maker as described in the relative terms and on this platform.
• Third-Party Service: refers to advertisers, content partners, marketing partners, and other providers whose products or services we believe may interest you.
• Website: Milena's official website, which can be accessed at [MilenaApp.com].
• You: a person or entity that is registered with Milena: AI Photo Video Maker to use the services.

Information Automatically Collected

There is some information like your Internet Protocol (IP) address and/or browser and device characteristics—is collected automatically when you visit our platform. This information may be used to connect your computer to the Internet. Other information collected automatically could be:

• Login, email address, and password (if applicable).
• Device and connection details, including browser plug-ins, time zone settings, and platform information.
• Purchase history, which may be aggregated with similar information from other users.
• User interaction data, including session durations, visited pages, and in-app behavior.
• Security information, including fraud prevention measures.
• Technical logs and error reports to help diagnose performance issues.

We may also use cookies and similar tracking technologies to enhance the user experience, prevent fraud, and collect marketing analytics.

Collection of Personal Data and Method

Milena may process your personal data for the purposes specified in this Privacy Policy.

Personal Data Collected by Milena

We collect and use the following personal data of users:

We may collect this information directly from you, your device, third-party applications, or third-party platforms (such as Apple App Store, Google Play Store).

Additionally, log data generated while you use our application may include:

• IP address, device details, app version, and operating system.
• Time and date of app usage.
• Technical statistics, error logs, and in-app events.

How We Use Your Information

We use your information for various purposes, including:

Providing Our Services

We process your information to:

• Enable AI-powered photo and video editing features.
• Enhance and improve AI-generated content recommendations.
• Allow users to store and modify their AI-enhanced media.
• Enable face-tracking and animation effects in videos.
• Process user requests for customer support.
• Handle in-app purchases and subscriptions.

Administrative Purposes

We may use your information to:

• Perform research and development (including AI model improvements).
• Ensure fraud detection and security.
• Monitor engagement levels and app functionality.
• Customize user experience based on preferences.
• Improve app stability, bug fixes, and feature enhancements.
• Comply with legal obligations.

Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include email campaigns, custom audiences advertising, and "interest-based" or "personalized advertising," including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in Section 15 below.

Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

(a) Share Content with Friends or Colleagues

Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends or colleagues through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

General Principles Regarding Personal Data Processing

In accordance with this Privacy Policy, personal data are processed by Denali Digital Bilişim Limited Şirketi as a data controller in line with the basic principles named here:

• (i) being in accordance with law and good faith,
• (ii) being accurate and, where necessary, up-to-date,
• (iii) being processed for specific, explicit, and legitimate purposes,
• (iv) being limited for the purpose for which they are processed and data minimization,
• (v) being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

Purposes of Processing Personal Data and Legal Reasons

Your personal data will be processed via automatic or non-automatic means for the purposes stated below, in accordance with the applicable legislation and articles 5 and 6 of the PDP Law where it is expressly permitted by the laws, the establishment of a contract or direct relation to the execution or performance of the contract and for the legitimate interests of Denali Digital Bilişim Limited Şirketi, provided that your fundamental rights and freedoms are protected.

Purposes of Processing Personal Data

Identity Information

• Execution of activities in compliance with legislation
• Execution of company/product/service commitment operations

Contact Information

• Execution of communication activities
• Execution/auditing of business activities
• Conducting after-sales support services for goods/services
• Execution of goods/services sales processes
• Conducting storage and archive activities
• Execution of agreement processes
• Execution of information security processes
• Conducting audit/ethical activities
• Execution/audit of business activities

Process Security

• Conducting activities to ensure business continuity
• Providing information to authorized persons, institutions and organizations
• Execution/auditing of business activities
• Conducting after-sales support services for goods/services

Customer Transaction

• Execution of goods/services sales processes
• Conducting activities for customer satisfaction
• Execution of agreement processes
• Execution of activities in compliance with legislation

Visual and Audio Records

• Execution of agreement processes
• Conducting storage and archive activities
• Conducting marketing analysis studies

Marketing Data

• Execution of advertising/campaign/promotion processes

Legal Reasons

Additional Purposes

Besides, the purposes of processing personal data may be updated in line with our obligations arising from our company policies and legislation; in particular:

• Creating user accounts for the service recipients/application users
• Customizing our Services, understanding our users and their preferences to enhance user experience and enjoyment using our Services and improve our users' experience
• Informing about new products, services, and applications and delivering you information regarding advertisements and promotions
• Carrying out a digital subscription and in-app purchase processes of service recipients
• Carrying out the auto-renewable subscriptions for giving users access to content, services, or premium features in our service
• Carrying out the processes of information security
• Conducting activities in accordance with legislation
• Fulfilling the demands of competent authorities
• Conducting the processes of finance and accounting transactions
• Conducting communication activities
• Conducting the processes of contracts
• Carrying out strategic planning activities
• Following up requests and complaints

Third Party Websites and Applications

Denali Digital Bilişim Limited Şirketi applications, including Milena: AI Photo Video Maker, may contain links to third-party websites that are not affiliated with Denali Digital Bilişim Limited Şirketi and whose content is not controlled by us. These linked websites may have different terms and conditions from Milena: AI Photo Video Maker. Denali Digital Bilişim Limited Şirketi is not responsible for how these websites use or disclose any personal information.

Similarly, Denali Digital Bilişim Limited Şirketi does not take responsibility for links from third-party websites that lead to Milena: AI Photo Video Maker.

Collection and Use of Information

Milena: AI Photo Video Maker collects personal information lawfully and fairly, with users' knowledge and consent. Users are informed about why data is collected and how it will be used. Users have the right to refuse the collection of certain information, but some services may not function properly without the necessary data.

Push Notifications

Denali Digital Bilişim Limited Şirketi may occasionally send push notifications to users of Milena: AI Photo Video Maker regarding application updates, feature releases, or service-related notifications. Users can manage or disable such notifications through device settings at any time.

Personal data will be stored for the period required by applicable regulations or until the purpose for processing no longer exists. Denali Digital Bilişim Limited Şirketi may continue storing personal data even after the initial purpose has been fulfilled, if required by law or with the user's explicit consent.

If a user grants consent for Denali Digital Bilişim Limited Şirketi to retain personal data for an additional period, such data will be immediately deleted, destroyed, or anonymized once the extended retention period ends or when processing is no longer necessary.

Technical and Administrative Measures

Denali Digital Bilişim Limited Şirketi ensures the confidentiality, integrity, and security of personal data through technical and administrative measures, in compliance with applicable laws and regulations. The following measures are in place to protect personal data from unauthorized access, misuse, or unlawful modification.

Technical Measures

Administrative Measures

Transferring Personal Data to Third Parties

The procedures and principles for transferring personal data are regulated under applicable data protection laws, and personal data may be transferred to third parties within the country or abroad, as Milena: AI Photo Video Maker may use servers and cloud-based storage systems located in different regions.

Your personal data may be transferred internationally for the following purposes:

• Conducting storage and archiving activities
• Managing customer relationship processes
• Conducting business operations
• Providing after-sales support services for products/services

Denali Digital Bilişim Limited Şirketi may also transfer your personal data to its service providers and third-party partners, including but not limited to:

• Facebook SDK
• Adjust
• Firebase Analytics

These third-party services are integrated into Milena: AI Photo Video Maker for purposes such as:

• Sharing identity, contact, and transaction security information with authorized institutions to ensure compliance with legal regulations.
• Sharing identity and contact details for customer support and business operations.
• Allowing users to integrate and share identity and contact information with third-party applications that are linked to Milena: AI Photo Video Maker, only with explicit user consent.

Affiliates

We may disclose personal information to our corporate affiliates. For the purpose of this Privacy Policy, a Corporate Affiliate is any entity that directly or indirectly controls, is controlled by, or is under common control with Denali Digital Bilişim Limited Şirketi. Any data shared with these affiliates will be treated according to this Privacy Policy.

Governing Law

This Privacy Policy is governed by the laws of Turkey, without regard to its conflict of laws provisions. By using Milena: AI Photo Video Maker, you agree that any disputes arising in relation to this Privacy Policy shall be subject to the exclusive jurisdiction of Turkish courts.

Your use of Milena: AI Photo Video Maker may also be subject to other local, national, or international laws depending on your location.

By continuing to use Milena: AI Photo Video Maker, you acknowledge and agree to this Privacy Policy. If you do not agree, you should discontinue use of the app.

Advertising

This app may display third-party advertisements and contain links to external sites. Denali Digital Bilişim Limited Şirketi does not guarantee the accuracy or reliability of the information contained in third-party advertisements or linked websites and assumes no responsibility for their content, products, or services.

• Third-party advertisements help keep Milena: AI Photo Video Maker free.
• We do not endorse third-party advertisements, services, or products.
• We are not responsible for any claims, promises, or guarantees made in these advertisements.

Cookies for Advertising

We use cookies to collect information about your online activities and provide personalized advertisements. These cookies:

• Prevent the same ad from appearing multiple times.
• Ensure ads are displayed correctly for advertisers.
• Help advertisers track how many times their ads have been shown.

You can disable cookies in your browser settings, but doing so may affect your ability to access certain features of Milena: AI Photo Video Maker.

Face Data Policy for Milena: AI Photo Video Maker

Collection of Face Data

Milena may access and process photos or videos that include faces, which you voluntarily upload to the app. However, we do not collect biometric data, nor do we use facial recognition or extract facial geometry from your images.

Use of Face Data

Uploaded images or videos are only used to apply the AI-powered effects, such as stylistic filters, avatars, or animations. The face data is never used for identification, surveillance, or authentication purposes. No biometric identifiers are created or stored.

Storage of Face Data

All uploaded media is stored temporarily and securely on our servers only to perform the requested AI processing. Once the generation is completed, all face-related data is automatically and permanently deleted.

Sharing of Face Data

Milena does not share any face data or user-uploaded images with third parties. The only exception is secure, temporary processing by infrastructure providers (e.g., cloud servers), all of whom operate under strict data privacy and processing agreements.

Retention of Face Data

Face data is retained only for the duration of the AI processing task. After the stylized image or video is generated, all original face data is immediately removed and cannot be recovered.

Control Over Face Data

You maintain full control over your data. You can choose which media to upload, and you can revoke access to your camera or photo gallery at any time through your device settings.

Privacy and Security Measures

All image transfers are encrypted end-to-end. We do not store any image beyond its editing purpose. Facial recognition, face tracking, or biometric profiling is never used in any part of our service.

Information Collected Through Microsoft Clarity

Types of Data Processed

Milena: AI Photo Video Maker uses Microsoft Clarity to collect data on user interactions within the app. This may include but is not limited to mouse movements, clicks, and scrolling behavior.

Handling of Sensitive Data

We do not use Microsoft Clarity to process sensitive personal data, including health records, financial information, or government-issued identifications.

Data Security and Protection

We implement industry-standard security measures to protect user data, and Microsoft Clarity also ensures that collected data is handled securely and confidentially.

Use of Data

Data collected via Microsoft Clarity is used to analyze user interactions and improve the overall experience of Milena: AI Photo Video Maker. Additionally, Microsoft may process this data in accordance with its privacy policies to enhance its services.

User Rights

You have the right to access, correct, or delete your personal data collected through Microsoft Clarity. If you wish to exercise these rights, please contact us.

Changes to Our Use of Microsoft Clarity

If there are any updates in how we utilize Microsoft Clarity, including additional data collection or changes in purpose, we will update this Privacy Policy and notify you as required by law.

General Data Protection Regulation (GDPR) Compliance

What is GDPR?

The General Data Protection Regulation (GDPR) is an EU-wide law that governs how companies collect, store, and process personal data of European Union (EU) residents. Milena: AI Photo Video Maker complies with GDPR standards, regardless of where our users are located.

What is Personal Data?

Under GDPR, personal data includes any information that can identify an individual directly or indirectly. Examples include:

• Name, email, phone number
• IP address and geolocation
• Device identifiers
• Biometric and facial recognition data
• Online behavior and browsing history

GDPR Principles We Follow

• Personal data must be collected and processed lawfully, fairly, and transparently.
• Data should only be collected for specific and legitimate purposes.
• Personal data must be stored only for the necessary period.
• Users have the right to access, update, delete, or restrict the processing of their data.

Why is GDPR Important?

GDPR imposes stricter rules on how businesses handle user data and increases enforcement penalties for non-compliance. At Denali Digital Bilişim Limited Şirketi, we take privacy seriously and implement strong security measures beyond GDPR requirements.

User Rights Under GDPR

As a Milena: AI Photo Video Maker user, you have the right to:

• ✅ Access your personal data and request a copy of it.
• ✅ Update or correct any inaccurate personal data.
• ✅ Request deletion of your personal data.
• ✅ Restrict processing of your data in certain situations.
• ✅ Withdraw consent at any time.

To exercise these rights, please contact us. We respond to verifiable requests within one month as required by GDPR.

California Residents' Rights (CCPA Compliance)

The California Consumer Privacy Act (CCPA) requires us to disclose:

• The categories of personal data we collect.
• The purposes for collecting and using personal data.
• The third parties with whom we may share your personal data.

Your Rights Under CCPA

If you are a California resident, you have the right to:

• ✅ Know and access what personal data we collect and how it is used.
• ✅ Request deletion of your personal data.
• ✅ Opt out of the sale of your personal data (We do not sell personal data).
• ✅ Receive equal service regardless of your privacy preferences.

If you wish to exercise any of these rights, please contact us. We will respond within one month as required by CCPA.

California Online Privacy Protection Act (CalOPPA) Compliance

The California Online Privacy Protection Act (CalOPPA) requires businesses to disclose how personal data is collected, used, and shared.

Your Rights Under CalOPPA

If you are a California resident, you have the right to:

• ✅ Know and access what categories of personal data we collect.
• ✅ Request deletion of your personal data.
• ✅ Opt out of data sales (Milena: AI Photo Video Maker does not sell personal data).
• ✅ Receive equal service, regardless of privacy preferences.

To request data access, correction, or deletion, please contact us.

Blocking and Disabling Cookies

You can manage cookies through your browser settings, but disabling cookies may affect your ability to access some Milena: AI Photo Video Maker features. Disabling cookies does not automatically remove them—you must manually delete them from your browser.

Payment Details

For in-app purchases, Denali Digital Bilişim Limited Şirketi does not store or process your credit card or payment details. All transactions are handled by third-party payment processors (such as Apple, Google, or other payment providers) using secure encryption.

Kids' Privacy

Milena: AI Photo Video Maker is not intended for children under 13 years old. We do not knowingly collect personal data from children under this age.

If you are a parent or guardian and believe that your child has provided personal information to Milena: AI Photo Video Maker, please contact us. If we discover that personal data has been collected from a child under 13 without parental consent, we will delete the data immediately.

Changes to Our Privacy Policy

We may update this Privacy Policy from time to time. Changes will be communicated through Milena: AI Photo Video Maker or through direct notifications. If you continue using the app after changes are made, you agree to the updated Privacy Policy.

Third-Party Services

Milena: AI Photo Video Maker may contain third-party content, data, applications, or links to external services.

Denali Digital Bilişim Limited Şirketi does not control or assume responsibility for:

• The accuracy, reliability, or legality of third-party services.
• How third-party services collect, use, or process your data.
• Any damages or losses arising from third-party services.

Using third-party services is entirely at your own risk, and you should review their respective privacy policies.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at:

📧 Email: support@denalidigital.co