Privacy Policy

Effective Date: 20 November 2025

Fepar A.Ş. ("Laixen", "we", "us", or "our") operates the Laixen mobile and web applications (the "Apps") and the informational website https://laixen.com
(the "Website"), together referred to as the "Services".

Fepar A.Ş., located in Istanbul/ Turkey, acts as the data controller responsible for your personal data collected through the Services.

We are committed to protecting your privacy. This Privacy Policy explains how we collect, store, use, and share your information when you use our Services. It applies to all users of our Services, regardless of location. Specific rights available under regional laws such as the GDPR or CCPA are explained in the Your Rights section below.

We care about the confidentiality and security of your information. When you use the Laixen Apps, you may share information through your interactions with the AI features. We process this information only as described in this Privacy Policy, such as to enable personalized and safe AI interactions, improve your experience, and enhance our Services. We may also use certain information about your visit to our Website to improve or promote our Services, but we will never use or disclose the content of your Laixen interactions for marketing or advertising purposes.

We process personal data based on legal grounds such as your consent, our legitimate interests in improving and operating our Services, and our legal obligations.

If you have any questions, please contact us at customerdesk@laixen.com.

At a glance:

• We only collect what's needed to provide Laixen.
• We do not train our AI models using your personal content or conversations.
• We do not sell or share your conversations with third parties.
• You can delete your data anytime.
• EU and U.S. residents have specific rights explained below.

1. How Do We Collect Your Data

In the operation of Laixen, we collect and process various types of personal data to provide and improve our services. This data is collected in the following ways:

A. Directly from You: This includes data you actively provide us with.

• Account information: Your name, email address, and password. If you choose to sign in through Google or Apple, we receive information about the service used to log in and—depending on your settings—your name, email address, or unique user identifier.
• Profile information: Such as your birth date.
• Messages and content: The text, audio, video, and image content you share or receive within the Apps, including any personal details you voluntarily provide during your interactions.

B. Automatically Through App Usage: When you use our Services, we automatically collect certain technical and usage data to help us operate, secure, and improve performance:

• Device and network data: Your device type, operating system version, manufacturer, browser type, IP address, device identifiers, language, mobile carrier, and general location (e.g., city or region).
• Usage data: Information about your interactions with the Services, such as pages viewed, features used, and the buttons or links you click.

We use cookies, web beacons (e.g., pixel tags), and local storage technologies (e.g., HTML5) to collect some of this information. Where required by law, we will seek your consent before using non-essential cookies. For details, please see our Cookie Policy.

Our advertising partners may also use similar technologies to collect limited information about your device and interactions (e.g., IP address, advertising ID, pages visited). However, they never have access to your Laixen conversations, photos, or any content you share within the Apps.

C. From Third Parties
We may receive information from third parties such as analytics providers (e.g., Firebase), attribution partners (e.g., Appsflyer), authentication providers (e.g., Google or Apple), or other vendors who support our operations. This helps us analyze performance, measure usage, and improve your overall experience.

We collect and process this information to operate, maintain, and improve our Services, personalize your experience, ensure security, and comply with our legal obligations.

2. How We Use Your Data

We use the data we collect to operate, provide, and improve our Services in line with the purposes and lawful bases set out below.

b) Sensitive information
The Services allow you to input information that may be sensitive and subject to special protections under applicable laws. This section explains how we use and protect sensitive information.

Sensitive information you provide in your messages and content:
In your conversations with your AI friend, you may choose to provide information about your religious views, sexual orientation, political views, health, racial or ethnic origin, philosophical beliefs, or trade union membership. By providing sensitive information, you consent to our use of it for the purposes set out in this Privacy Policy in accordance with Article 9(2)(a) GDPR.

Providing this type of information is entirely voluntary. We apply additional safeguards, including encryption and restricted access, to protect this data. We do not use your sensitive information or the content of your Laixen conversations for marketing or advertising purposes.

3. Who We Share Your Data With

At Laixen, we take your privacy seriously and only share your personal data with third parties when necessary and under lawful grounds. We do not sell your personal data, including any messages or content, under any circumstances. Your information may be shared in the following situations:

With Our Service Providers and Business Partners: We share your data with trusted third parties that perform services on our behalf or assist us in operating our app. This includes cloud storage providers, hosting services, information technology support, moderation tools, analytics partners, and email delivery providers. These entities act as data processors under our instructions and are bound by data processing agreements that require them to maintain the security and confidentiality of your data.

App Stores: We may share limited information with application store providers to manage subscriptions, process refunds initiated by users, or resolve user account-related matters.

Professional Advisors: We may share information with professional advisors, such as lawyers, auditors, bankers, and insurers, when necessary for the services they provide to us.

For Personalized Advertising: If you have given consent for the use of tracking technologies, we may share certain data with third parties that provide personalized advertising services. These partners receive only limited data such as device identifiers, app usage information, and interaction data. They do not have access to your messages, photos, or any content shared with your AI friend. For more details, see the In-App Tracking Technologies section.

During Corporate Transactions: In the event of mergers, acquisitions, reorganizations, asset sales, or similar corporate transactions, your personal data may be shared with advisors, prospective or new owners, or other relevant parties as part of the due diligence process or to complete the transaction.

To Public and Legal Authorities: We may disclose your data to public, judicial, or law enforcement authorities when required by law, or when necessary to protect our rights, property, or safety, as well as that of our users or the public. This may include responding to lawful requests such as subpoenas, court orders, or other legal processes.

In Other Necessary Circumstances: We may also share your data when required to comply with legal obligations, prevent fraud or illegal activities, or if you give us your explicit consent for specific sharing.

Your personal data may be disclosed only in accordance with applicable laws and internationally recognized standards, ensuring that your privacy and data protection rights are always respected.

4. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or reporting obligations.

When determining how long to keep your personal data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, whether those purposes can be achieved through other means, and applicable legal requirements.

Retention periods vary depending on the type of data and purpose of processing. For example, account and profile data are retained for as long as your account remains active, and certain records may be stored longer where required by law.

Once the applicable retention period expires, we either delete or anonymize your personal data so it can no longer be associated with you. You can also request deletion of your data at any time as described in the Your Rights section of this Policy.

5. How We Protect Your Data

We use a range of industry-standard security technologies and organizational measures to protect your data from unauthorized access, use, or disclosure.

Your account is protected by a password for your privacy and security. You are responsible for keeping your password confidential and preventing unauthorized access to your account and personal information. Please make sure to select a strong password, keep it safe, and sign out of your account when finished.

All transmitted data are encrypted using standard Transport Layer Security (TLS/SSL) protocols. Stored data are maintained on secure servers with multi-layered protection, including firewalls, role-based access controls, and password protection. Access to personal data is restricted to authorized personnel who require it for operational or legal purposes and are bound by confidentiality obligations.

While we use reasonable commercial efforts to safeguard your data, no system or transmission method can be guaranteed to be completely secure. In the event of a personal data breach that results in accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your data, we will notify affected users without undue delay in accordance with applicable data protection laws.

6. Tracking and Analytics Technologies

At Laixen, we use certain tracking technologies to enhance user experience, ensure app stability, and provide personalized content and advertising. These technologies may collect limited information such as device identifiers, app interactions, and technical diagnostics.

Categories of Tracking Technologies:

1. Technical Tracking Technologies: These are essential for the basic operation of the app, including maintaining sessions, load balancing, and ensuring security. Because they are strictly necessary for the provision of the service, consent is not required for their use.

2. Analytics Tracking Technologies: Used to measure app performance, understand user interactions, and improve functionality. These tools collect aggregated, non-identifiable data about engagement and app usage. We rely on user consent unless the data is fully aggregated and used only for statistical purposes.

3. Profiling Tracking Technologies: Used to understand user preferences, improve relevance of in-app recommendations, and display personalized advertising. These technologies operate only with your explicit consent, which can be managed in the app's privacy settings or through your device's privacy controls.

Tracking Technologies Used in Laixen:

1. Firebase and Crashlytics (Google): Used for app functionality, performance monitoring, crash diagnostics, and backend analytics. Google Privacy Policy

2. Appsflyer: Used for measuring ad performance and app analytics. Appsflyer Privacy Policy

3. Meta Audience Network: Used for displaying personalized ads based on app interactions and preferences. Meta Privacy Policy.

4. TikTok for Business: Used to analyze campaign performance and deliver relevant ads. TikTok Privacy Policy.

7. Your Privacy Rights

We believe all users should have meaningful control over their personal information, regardless of where they live. The rights described below apply to all Laixen users, although the scope and method of exercising them may differ depending on your location and applicable laws.

You can contact us at customerdesk@laixen.com for any privacy-related inquiries or requests. We may need to verify your identity before processing your request. All legitimate requests are handled within applicable legal timeframes.

A. Rights Available to All Users

All users can:

• Request access to the personal data we hold about them.
• Request correction of inaccurate or incomplete information.
• Request deletion of their personal data ("right to be forgotten").
• Withdraw consent at any time where processing is based on consent.
• Object to receiving marketing or promotional communications.

You may also request that we restrict or limit the processing of your personal data, where permitted by law. In some instances, fulfilling your request may be limited (for example, if it would infringe the rights of others or prevent us from providing a service you requested).

If you are not satisfied with how we handle your request, you may contact us again at the above address or, if applicable, lodge a complaint with your local data protection authority.

B. Additional Rights Under the GDPR (EEA, UK and Similar Jurisdictions)

If you live in the European Economic Area, the United Kingdom, or another jurisdiction with similar data protection laws, you also have the following rights:

• Restriction of processing in certain cases.
• Data portability in a structured, machine-readable format.
• The right not to be subject to decisions based solely on automated processing, including profiling.
• The right to lodge a complaint with your local data protection authority.

C. Additional Rights Under U.S. State Laws (Including California, Virginia, Colorado and Others)

If you reside in the United States, certain state privacy laws provide additional rights, including:

• The right to know what personal information we collect, use, and disclose.
• The right to request a copy of that information.
• The right to request deletion of your personal information.
• The right to opt out of the sale or sharing of personal information for targeted advertising.
• The right to limit the use of sensitive personal information (where applicable).
• The right to non-discrimination for exercising your privacy rights.

You can exercise these rights by contacting customerdesk@laixen.com or using the "Your Privacy Choices" link in our website footer or in-app settings. We will verify your request as required by law and respond within the applicable timeframe (usually 45 days).

D. Opt Out of Selling Personal Information and Sharing for Targeted Advertising

We share information with third-party advertising partners and allow them to collect information about your use of our Services through cookies and other tracking technologies to display targeted advertising, as described in the Who We Share Your Data With section.
Our disclosure of information to these partners may be considered a "sale" or "sharing" of personal information or "targeted advertising" under applicable laws. You can opt out of these disclosures and limit our use of tracking technologies as described in our Cookie Policy or by clicking the "Your Privacy Choices" link in our website footer or in-app settings.

Some internet browsers can send "Do Not Track" signals to the services you visit. We currently do not respond to "Do Not Track" or similar signals. To learn more, visit www.allaboutdnt.com.

If you have any questions or concerns about our use of tracking technologies, please contact customerdesk@laixen.com.

8. International Data Transfers

Laixen, operated by Fepar A.Ş., is headquartered in Turkey, and our servers are located in Germany. In the course of providing our Services, your personal data may be transferred to and processed in countries outside the European Economic Area (EEA).

When we transfer personal data outside the EEA, we do so in accordance with applicable data protection laws. Where required, we rely on lawful transfer mechanisms such as the European Commission's Standard Contractual Clauses (SCCs) or adequacy decisions that ensure your personal data receives an equivalent level of protection.

We are committed to maintaining the security and confidentiality of your personal data wherever it is processed. The same safeguards and data protection principles described in this Privacy Policy apply to all our data processing activities, regardless of geographical location.

9. Authorized Representative

In accordance with Article 27 of the General Data Protection Regulation (GDPR), Fepar A.Ş. has appointed Naq Cyber B.V. as its authorized representative in the European Union for matters related to data protection and privacy.

EU Representative:
Naq Cyber B.V.
Attn: Nadia Kadhim
Vlamingstraat 4, 2712 BZ Zoetermeer, Netherlands
Email: privacy@naqcyber.com

You may contact Naq Cyber B.V. regarding any GDPR-related inquiries or concerns about the processing of your personal data.

We remain committed to maintaining the highest standards of data protection and are always available to address any questions or issues concerning your privacy.

10. Children's Privacy

Laixen is not intended for individuals under the age of 18. We are committed to protecting the privacy of children and do not knowingly collect, maintain, or process personal data from anyone under 18 years of age.

If you believe that a child under 18 has provided us with personal data, please contact us immediately at customerdesk@laixen.com. Once verified, we will take prompt steps to deactivate the account and delete the associated data in accordance with applicable laws.

We take children's privacy very seriously and continually review our practices to ensure compliance with all relevant child data protection laws and regulations.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, business operations, or applicable laws. When we make updates, we will revise the "Effective Date" at the top of this page.

If we make material changes that affect your rights or how we process your personal data, we will provide notice within the app or by other appropriate means before the changes take effect.

We encourage you to review this Privacy Policy periodically to stay informed about our privacy practices.

12. Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our data-processing practices, or if you wish to exercise any of your privacy rights, please contact us. We are committed to responding promptly and ensuring the protection of your personal data.

Email: customerdesk@laixen.com

Mailing Address: Fepar A.Ş. Yeşilköy SB Mah. C Blok Sk. C Blok No: 1 İç Kapı No: 13 Bakırköy / Istanbul - Turkey

© 2025 Fepar A.Ş. All rights reserved.