PRIVACY POLICY

SPECTRE PRIVACY POLICY

1. General Information

This Privacy Policy explains how Black Paw Eğitim Teknolojileri A.Ş. ("Black Paw", "Company") processes personal data of users who access and use the SPECTRE mobile application ("Application").

Black Paw respects the privacy and security of its users' personal data.

Data Controller:

Black Paw Eğitim Teknolojileri A.Ş.

Address: Reşitpaşa Mah. Katar Cad. İTÜ ARI Teknokent 3 Binası No:4 Sarıyer / Istanbul, Türkiye

Email: aslihandemirsoy@blackpawtech.com

2. Personal Data We Process

During your use of SPECTRE, the following personal data may be processed:

2.1 Account and Identity Information

For account creation, we may process:

• Email address,
• Account information,
• Password information created by the user.

Passwords are securely stored and cannot be accessed by Black Paw personnel.

If you use Google or Apple login, limited information required for authentication may be obtained from the relevant service provider.

2.2 Subscription and Transaction Information

For premium membership services, we may process:

• Subscription status,
• Premium access information,
• License or access code information.

Payments are processed through application marketplace payment systems such as Apple App Store and Google Play Store. Black Paw does not access users' bank or payment card information.

2.3 User Feedback

Information provided by users, including:

• Ratings,
• Reviews,
• Suggestions,
• Support requests

may be processed to improve service quality and user experience.

2.4 Camera and Image Data

Camera access may be required for SPECTRE's Augmented Reality (AR) and AI-powered image analysis features.

Camera access is used only for:

• Running AR experiences,
• Capturing images initiated by the      user.

SPECTRE does not continuously access the camera or record images unless the user actively performs an image capture action.

3. Artificial Intelligence Image Processing

SPECTRE includes AI-powered image analysis features.

Images captured or uploaded by users may be processed for:

• Identifying anatomical structures,
• Providing analysis results,
• Improving AI system performance.

During AI processing:

• Images may be transferred to our servers,
• Relevant anatomical areas may be extracted,
• Images may be anonymized.

Anonymized images may be used for improving and developing SPECTRE AI models.

4. Storage of AI Images

Images processed through AI features:

• Are stored for a maximum period of 3 months.
• Are permanently deleted after this period.

Access to these images is limited to authorized Black Paw personnel who require access for:

• Quality control,
• AI performance improvement,
• System enhancement purposes.

5. Purposes of Processing Personal Data

Personal data may be processed for:

• Creating and managing user accounts,
• Providing SPECTRE services,
• Managing premium memberships,
• Providing user support,
• Evaluating user feedback,
• Operating AI features,
• Improving AI systems,
• Improving service quality,
• Complying with legal obligations.

6. Sharing of Personal Data

Personal data may be shared with:

Technical Service Providers

Data may be stored within infrastructure services used by Black Paw for operating SPECTRE.

SPECTRE's server infrastructure is provided through a VPS service provider located in France.

Application Marketplaces

Premium membership payments may be processed through:

• Apple App Store,
• Google Play Store.

Payment processes are subject to the privacy policies of these platforms.

Institutional Users

For university or institutional licenses, necessary information may be processed for access management purposes.

7. International Data Transfers

Due to SPECTRE's server infrastructure being located in France, personal data may be transferred outside Türkiye.

Black Paw applies necessary technical and administrative measures to protect personal data during such transfers.

8. Data Security

Black Paw applies appropriate measures including:

• Access controls,
• Secure storage methods,
• Authorization procedures,
• Technical and administrative security measures.

9. User Rights

Users have the right to:

• Learn whether their personal data is processed,
• Request information about processed data,
• Request correction of inaccurate data,
• Request deletion of personal data,
• Object to processing activities where applicable.

Requests may be submitted to:

Email:
aslihandemirsoy@blackpawtech.com

10. Account Deletion

Users may delete their accounts.

Following deletion:

• Account information will be deleted,
• Data that does not need to be retained will be removed,
• Data required to be retained under applicable laws may be stored for the legally required period.

11. Updates to This Policy

Black Paw may update this Privacy Policy due to changes in services or legal requirements.

Updated versions become effective when published within the Application.

Black Paw Eğitim Teknolojileri A.Ş.

SPECTRE