Privacy Policy

Effective date: 30 January 2024.

1. Introductory Provisions

1.1. EXXE. (hereinafter referred to as "EXXE DIJITAL TEKNOLOJI ANONIM SIRKETI", "Company", "us", "our" or "we") is dedicated to protecting the privacy rights of our users (hereinafter referred to as "User(s)", "you"). This Privacy Policy (hereinafter referred to as "Policy") describes how and why we collect, store, use, and manage the information, and data, including personal data, that you provide or we collect when you visit our website https://baby-maker.app/ (hereinafter referred to as "Site") or use any EXXE's application provided on any mobile platform (for example, iOS and Android) (hereinafter collectively referred to as the "Service(s)").

1.2. Please note that the scope of this Policy is limited to information and data collected or received by EXXE through or in relation to your use of the Service. EXXE is not responsible for the actions of third parties, the content of third-party websites, the use of information or data you provide to third parties or any products or services they may offer.

1.3. EXXE acts as a Data Controller in relation to personal data that you provide to us.

1.4. By using our Services you agree to our Privacy Policy and confirm that you are at least 13 years old. We do not knowingly collect or solicit personal data from or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services.

1.5. EXXE, Inc. as Data Controller does not and will not process any special categories of personal data.

1.6. From time to time, we can update this Privacy Policy. We may notify you about changes to this Policy by placing a notice via the Services or Site.

2. Use of personal information

2.1. We collect and combine different types of information and/or data (including personal data) together. Here you can find more about what information and/or data we collect about you when we collect it and what information and/or data we do not collect about you:

  • 2.1.1. Registration, account, and sign-up information.
  • 2.1.2. Product/ service purchase.
  • 2.1.3. From other sources.
  • 2.1.4. Social media.
  • 2.1.5. Location information.
  • 2.1.6. Technical and usage information.
  • 2.1.7. Customer enquiries.
  • 2.1.8. Tracking Technologies.

2.1.9. We understand the importance of protecting your privacy and want to provide transparency regarding the collection and usage of Face Data. Please see the "Face Data" section for more information on how we may use Face Data.

3. How We Use the Information

3.1. We use collected information and/or data (including personal data) for the following purposes:

  • 3.1.1. Providing and marketing products and services. We use the information and/or data that we collect about you to analyze your use of our products, applications, services, and content, to facilitate sharing and other interactions with Social Media Sites, and to provide, develop, maintain, personalize, protect, and improve your experience and our offerings. For example, we use information and/or data that we collect from you to enable you to:
    • Get entertainment news and updates;
    • Get information about our products, services, and content;
    • Locate and access personalized information, ads or functionality based on your interests;
    • Engage with interactive features, activities, and Social Media Sites;
    • Provide content, reviews, or enter promotions and contests.

    In addition to this, we use this information and/or data for us and our affiliates, business partners, and third parties to target, offer, market, or advertise products, programs, or services.

    Lawful basis for processing including basis of legitimate interest:

    • Fulfilling contractual obligations (e.g., receive, process, and confirm your subscription or registration, and communicate with you about your account);
    • Legal obligations; and
    • Your consent (where required) due to:
      • Maintaining our services as much as improving and developing new products (to ensure our services are working as intended, such as tracking outages or troubleshooting issues that reports to us);
      • Being more efficient; and
      • Preventing fraud and other misconduct.
  • 3.1.2. Communicating with you. We use information and/or data that we collect about you to communicate with you, in order to:
    • Notify you when we make changes to our policies or terms of use;
    • Respond to your inquiries;
    • Communicate with you about your purchases or transactions;
    • Contact you about your account; or
    • Send you information about promotions, offerings, and our features. You may also choose to receive push notifications from us on your mobile device.

    Lawful basis for processing including basis of legitimate interest:

    • Fulfilling contractual obligations;
    • Legal obligations; and
    • Your consent (where required) due to:
      • Communicating important information;
      • Improving and developing actual and prospective products and services; and
      • Compiling statistics.
  • 3.1.3. Third-party social networks. We use information and/or data that we collect about you when you interact with third-party social networking features to serve you with advertisements and engage with you on third-party social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third-party social network.

    Lawful basis for processing including basis of legitimate interest:

    • Your consent (where required); and
    • Legal obligations due to:
      • Defining types of customers for new products or services;
      • Developing a profile on you and your interactions with us so that we can provide tailored offers, opportunities, and services that may be of interest to you; and
      • Studying how you use our products/services, to develop them, to grow our business, and to improve our marketing strategy.
  • 3.1.4. Use of technical and usage information. We use technical and usage information to improve our design, functionality, and content, and to enable us to personalize your experience with our content and offerings. We use this information in order to:
    • Provide, develop, maintain, personalize, protect, and improve our products, applications, and services, and to operate our business;
    • Perform analytics, including analyzing and reporting on usage and performance;
    • Protect against, identify, and prevent fraud and other unlawful activity; and
    • Create aggregate data about our Users.

    Lawful basis for processing including basis of legitimate interest:

    • Fulfilling contractual obligations;
    • Legal obligations due to:
      • Running our business, provision of administration and IT services, network security, to prevent fraud as much as to comply with a legal obligation; and
      • Defining types of customers for our products and services, to keep our website updated and relevant.
  • 3.1.5. Compliance. We use information and/or data that we collect about our Users to detect, investigate, and prevent activities that violate our terms of use, could be fraudulent, violating copyright or otherwise illegal, to comply with legal requirements, and to protect our rights and the rights and safety of our Users and third parties.

    Lawful basis for processing including basis of legitimate interest:

    • Legal obligations due to:
      • Protecting our business interests and rights, privacy, safety, and property, or that of the public; and
      • Sharing your data with third parties in order to permit us to pursue available remedies or limit damage that we may sustain.

Facial Data Collection

Your Face Data is rendered in memory as Base64 and then cleared immediately afterwards. All Personal Information is stored on your device. When you use our apps, we collect the information that you provide us directly: Photos. We may collect the photos that you take with your camera while using our application. Please note, you won’t be able to upload content from your camera roll unless we can access your device’s camera. To erase this data, simply delete the app; this action is irreversible. In order to enhance our services and AI models, we may occasionally retain anonymized data, without any links to your identity, as a necessary part of our service delivery.Should you decide to remove the app and any photos generated by it, you can do so by deleting the app. Please be aware that all deletion actions are permanent and cannot be undone once confirmed. Your account or specific models, all associated information will be permanently purged from our system, ensuring your complete data removal.

Data Access and Removal

You can always control what information you choose to share with us on the Service. To do so, you can change your settings in the Service or in your mobile device. Alternatively, you can remove the Service from your mobile device entirely.You can remove your data anytime you want. If you ask us to delete your account, we will use commercially reasonable efforts to remove your data from our servers.Any personally identifiable information that (i) you share in text messages, photos, videos or otherwise in or through the application with other users, or (ii) submit on a blog, bulletin board or chat room on our website or elsewhere, can be viewed and used by others, including to send you unsolicited messages or to commit identity theft. We are not responsible for any use or misuse of your information that might result from your disclosure of information.

Your Choices

Marketing communications and sharing with third parties: We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us, and our sharing of information and/or data relating to you with our trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can send us an email at [email protected]

Ad Choices: We work with reputable third parties to present advertisements and engage in data collection, reporting, ad delivery and response measurement, and website analytics on our websites and applications and on third-party websites and applications. These third parties use cookies, web beacons, pixels, or similar technologies to perform this activity. They also obtain information about applications you use, websites you visit, and other information from your device(s) and browser(s) (if using our website) in order to help serve advertising that will be more relevant to your interests on and off our sites and across your device(s) and browser(s) (if using our website). This type of advertising is known as interest-based advertising. For more information about interest-based advertising on your desktop or mobile browser (if using our website), and your ability to opt-out of this type of advertising by third parties that participate in self-regulatory programs, please contact [email protected]

Cookies and Other Technical Information

  • Cookies and other technologies: We, and our affiliates, third-party service providers, and trusted partners send "cookies" to your device and use similar technologies in order to analyze and enhance your user experience with us, as well as for advertising purposes and social features.
  • Cookies are small text files placed in your browser (if using our website). We may also use pixels or "web beacons" that monitor your use of our website.
  • We may also integrate "Software Development Kits" ("SDKs"), JavaScript or portions of code into our applications/video games to perform similar functions as cookies and web beacons.
  • Our websites may use local stored objects ("LSOs") to provide certain content, such as video on demand, video clips, or animation, and better user experience.

Data Retention

We will only retain your personal data for as long as is necessary for the purposes described in this Policy. This means that our data retention periods will vary according to the reason for collection. Generally, your service-related personal data will be kept for as long as you remain our User.

How You Can Exercise Rights in Relation to Your Data

Under certain conditions, you have the right to ask us for a copy of your personal data, as well as to correct it, delete it or restrict its processing, and obtain the personal data that you provided to us in a structured, machine-readable format. You have the right to object to the processing of personal data on the basis of our legitimate interests.

5.2. Third-Party Information Sharing

When sharing information with third parties, we ensure that they assume responsibilities no less than what is outlined in this Privacy Policy. We require these third parties to adhere to the information-sharing practices and standards described herein to uphold the same level of privacy protection.

6. Your Choices

6.1. Marketing Communications

We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from Us, and our sharing of information and/or data relating to you with our trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can send us an email at [email protected]

6.2. Ad Choices

We work with reputable third parties to present advertisements and engage in data collection, reporting, ad delivery and response measurement, and website analytics on our websites and applications and on third-party websites and applications. These third parties use cookies, web beacons, pixels, or similar technologies to perform this activity...

7. Cookies and Other Technical Information

7.1. Cookies and other technologies:

  • 7.1.1. We, and our affiliates, third-party service providers, and trusted partners send "cookies" to your device...
  • 7.1.2. Cookies are small text files placed in your browser (if using our website). We may also use pixels or "web beacons"...
  • 7.1.3. We may also integrate "Software Development Kits" ("SDKs"), javascript or portions of code into our applications...
  • 7.1.4. Our websites may use local stored objects ("LSOs") to provide certain content...

8. Data Retention

8.1. We will only retain your personal data for as long as is necessary for the purposes described in this Policy...

9. How You Can Exercise Rights in Relation to Your Data

9.1. Under certain conditions, you have the right to ask us for a copy of your personal data, as well as to correct it, delete it or restrict its processing...

10. Data Transfer

10.1. We maintain servers around the world and your information may be processed on servers located outside of the country where you live...

11. How to Contact Us

11.1. As a non-EEA resident controller, we have appointed a local representative in the EEA...

If you have any questions about this Privacy Policy you can contact us at [email protected]

Privacy Notice for California Residents

This Privacy Notice for California Residents (hereinafter referred to as "Privacy Notice") supplements the information contained in EXXE, Inc.'s (hereinafter referred to as "EXXE", "Company", "us" or "our", or "we") Privacy Policy (hereinafter referred to as "Site Privacy Policy") and applies solely to all visitors, Users and others who reside in the State of California (hereinafter referred to as "consumers", "you" or "your"). We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used in this Privacy Notice. All capitalized terms not herein defined will have the meaning set forth in Company's Privacy Policy. In case of any inconsistencies with the Company's Privacy Policy, this Privacy Notice shall prevail.

1. Information We Collect

1.1. We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information").

1.2. In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:

  • A. Identifiers: Examples: name, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
  • B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)): Examples: a name, signature, physical characteristics or description, address, and telephone number. Some personal information included in this category may overlap with other categories.
  • C. Protected classification characteristics under California or federal law: Examples: Age, race, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  • D. Commercial information: Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • E. Internet or other similar network activity: Examples: Browsing history (if using our website), search history, and information on a consumer's interaction with a website, application, or advertisement.
  • F. Geolocation data: Examples: Physical location or movements.
  • G. Sensory data: Examples: Audio, electronic, visual, or similar information.
  • H. Inferences are drawn from other personal information: Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

1.3. Personal information does not include:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information;
  • Information excluded from the CCPA's scope, like:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

1.4. We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our consumers or their agents. For example, from information consumers provide to us related to the Services for which they engage us.
  • Directly from you when you provide it to us. For example, if you share your name and contact information to ask a question about our website or app.
  • Indirectly from you. For example, from observing your actions on our websites and in our app.
  • From third parties, for example, our service providers.

2. Use of Personal Information

2.1. We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason for which you provided the information. For example, if you share your name and contact information to ask a question about our website, app, or product we will use that personal information to respond to your inquiry.
  • To provide, support, personalize and develop our websites, apps and products.
  • To process your requests and respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
  • To notify you about changes to our websites, apps or any products or services we offer or provide through our websites and apps.
  • To notify you about changes to our policies and/or terms of use.
  • To maintain a record of our dealings with you.
  • To understand and analyze the usage trends and preferences of our Users, to improve our websites, apps and other products and to develop new features, and functionality.
  • To contact you for administrative and information purposes - this may include providing customer service or sending communications, including changes to our terms of use.
  • To engage features of third-party social networks.
  • For testing, research, analysis and product development.
  • To help maintain the safety, security, and integrity of our websites and apps, and databases, other technology assets and business.
  • To diagnose or fix technological problems in relation to our websites, apps and products.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
  • To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

3. Sharing Personal Information

3.1. We may disclose your personal information to a third party for business purposes. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

3.2. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers.
  • Category B: Personal information categories listed in the California Customer Records statute.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data.
  • Category K: Inferences drawn from other personal information.

3.3. We disclose your personal information for business purposes to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
  • Law enforcement bodies and courts.

3.4. We share your personal information for the following general purposes:

  • Service Providers: We may disclose personal information to third-party service providers that assist us with our operations. For example, analytics, log management, payment processing and data storage and processing services.
  • Protecting our Rights: We may disclose personal information to third parties if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.
  • Corporate Transaction: Personal information may be disclosed as part of a corporate transaction, such as a merger, acquisition, debt financing, sale of Company's assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.

3.5. In the preceding twelve (12) months, we have not sold any personal information.

4. Your rights and choices

4.1. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

4.2. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see "Exercising Access, Data Portability, and Deletion Rights" section), we will disclose to you:

  • (i) The categories of personal information we collected about you.
  • (ii) The categories of sources for the personal information we collected about you.
  • (iii) Our business or commercial purpose for collecting and selling that personal information.
  • (iv) The categories of third parties with whom we share that personal information.
  • (v) The specific pieces of personal information we collected about you (also called a data portability request).
  • (vi) If we disclosed your personal information for a business purpose, a list with disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

4.3. Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see "Exercising Access, Data Portability, and Deletion Rights" section), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • (i) Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
  • (ii) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • (iii) Debug products to identify and repair errors that impair existing intended functionality.
  • (iv) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • (v) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • (vi) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.
  • (vii) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • (viii) Comply with a legal obligation.
  • (ix) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

4.4. Exercising Access, Data Portability, and Deletion Rights

4.4.1. To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either: [email protected]

4.4.2. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

4.4.3. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • (i) Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person; and
  • (ii) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

4.4.4. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

4.4.5. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

4.5. Response Timing and Format

4.5.1. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

4.5.2. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

4.5.3. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

4.6. Personal Information Sales Opt-Out and Opt-In Rights

4.6.1. If you are a California resident and 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt out of future sales at any time.

4.6.2. To exercise the right to opt out, you (or your authorized representative) shall submit a verifiable notice to [email protected]

4.6.3. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

5. Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • (i) Deny you goods or services.
  • (ii) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • (iii) Provide you with a different level or quality of goods or services.
  • (iv) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

6. Changes to our privacy notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice via the Services or on the Site and update the Privacy Notice's effective date. Your continued use of our websites, apps and Services following the posting of changes constitutes your acceptance of such changes.

7. Contact information

7.1. If you have any questions or comments about this Privacy Notice, the ways in which the Company collects and uses your information described here and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact our representative responsible for personal information as follows:

7.2. If you have any questions about this Privacy Notice or our Privacy Policy, you can contact us at [email protected]