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Privacy Policy

Last updated: 8 November 2026

Klozai (“Klozai”, “we”, “us” or “our”) values your privacy. This Privacy Policy explains what personal data we collect when you use the Klozai mobile application (the “App”) and the website at www.klozai.com (the “Website”), why we use it, who we share it with, and the rights you have. It is written to provide the information required by the EU General Data Protection Regulation (GDPR), the UK GDPR and the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA).

1. Data Controller and Contact

The data controller responsible for your personal data is Perfexus Teknoloji A.Ş., which operates Klozai. [TODO: confirm the exact registered legal name of the data controller.]

  • Registered address: [TODO: add the data controller’s registered postal address.]
  • Email: info@perfexus.com
  • EU representative (GDPR Art. 27): [TODO: name the EU representative, or remove this line if one is not required.]
  • UK representative (UK GDPR Art. 27): [TODO: name the UK representative, or remove this line if one is not required.]
  • Data Protection Officer: [TODO: add DPO contact details if a DPO is appointed, or remove this line.]

2. Information We Collect

2.1 Account Information

  • A unique user identifier provided via Sign in with Apple or Sign in with Google
  • Email address, if shared by Apple or Google

2.2 User Content

  • Contracts and documents you upload (PDFs, images or text)
  • AI-generated analysis results and your questions about a document

Uploaded content is processed solely to provide the analysis you request. Documents may contain personal data about you or other people, so please only upload documents you are entitled to share.

2.3 Subscription Information

  • Subscription status, purchased products and transaction identifiers, provided by Apple and RevenueCat

We do not receive or store your payment card details. Payments are handled by Apple.

2.4 Technical Data

  • Device and usage information
  • Application performance and crash reports (Firebase Crashlytics)
  • Analytics data (Firebase Analytics)

2.5 Communications

If you email us, we process your email address and the content of your message to respond to you.

We process personal data only where we have a legal basis to do so:

  • Performance of a contract (GDPR Art. 6(1)(b)): creating and managing your account, signing you in with Apple, analyzing the documents you upload and showing you the results, and providing the subscriptions you purchase.
  • Consent (GDPR Art. 6(1)(a)): processing your documents with AI services after you agree to it in the App, and any other processing for which we ask your consent. You can withdraw your consent at any time; this does not affect processing carried out before you withdrew it.
  • Legitimate interests (GDPR Art. 6(1)(f)): keeping the App and Website secure, detecting and preventing errors and misuse, diagnosing crashes and improving performance, and responding to your messages. You can object to this processing at any time (see Section 9).
  • Legal obligation (GDPR Art. 6(1)(c)): keeping records we are required to keep by law, for example for tax or accounting, and responding to lawful requests from authorities.

4. Use of Artificial Intelligence

Klozai uses artificial intelligence technologies (e.g. Google Gemini) to analyze uploaded contracts.

⚠️ Important Notice: AI-generated outputs are provided for informational purposes only and do not constitute legal advice. Klozai does not use the analysis to make decisions about you that have legal or similarly significant effects.

5. Service Providers and Sharing

We share personal data only with service providers that process it on our behalf and under our instructions, or where the law requires it:

  • Google Cloud / Firebase: authentication, database, file storage, backend functions, website hosting, analytics and crash reporting
  • Google Gemini: AI analysis of the documents you upload
  • RevenueCat: subscription and purchase management
  • Apple: Sign in with Apple and App Store payments (Apple processes payment data under its own privacy policy)

We do not sell your personal data, and we do not share it for targeted or cross-context behavioral advertising. User content is never shared with third parties for marketing purposes.

6. International Data Transfers

Our service providers Google (Google Cloud / Firebase and Gemini) and RevenueCat may process personal data in the United States and in other countries outside your own, including countries outside the European Economic Area (EEA), the United Kingdom and Türkiye. Our backend functions run in a Google Cloud region in the United States.

Where personal data from the EEA or the UK is transferred to a country that is not recognized as providing an adequate level of data protection, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (with the UK International Data Transfer Addendum where applicable), or the EU-U.S. Data Privacy Framework and its UK Extension where the recipient is certified. You can request more information about these safeguards by contacting us.

7. Data Retention

  • Uploaded contracts: automatically deleted 90 days after upload. You can delete them earlier at any time in the App.
  • Account data: kept until you delete your account. When you delete your account, we delete your account data and content, except information we must keep to meet legal obligations.
  • Technical and analytics data: kept for the retention periods configured in Firebase Analytics and Crashlytics. [TODO: state the configured retention periods for Firebase Analytics and Crashlytics.]
  • Emails: kept for as long as needed to handle your request.

8. Data Security

  • Data is protected using industry-standard security measures, including encrypted connections
  • Appropriate technical and organizational safeguards are in place against unauthorized access
  • Access to personal data is limited to what is needed to provide the service

9. Your Rights

Depending on where you live, and in particular if you are in the EEA or the UK, you have the right to:

  • Access the personal data we hold about you and receive a copy of it
  • Rectification of inaccurate or incomplete data
  • Erasure of your data (“right to be forgotten”)
  • Restriction of processing in certain circumstances
  • Data portability: receive the data you provided to us in a structured, commonly used, machine-readable format, or have it sent to another controller
  • Object to processing based on our legitimate interests
  • Withdraw consent at any time, where processing is based on consent
  • Lodge a complaint with a supervisory authority, in particular in the country where you live or work or where an alleged infringement took place. In the UK this is the Information Commissioner’s Office (ICO).

You can delete your account directly in the App. To exercise any other right, email info@perfexus.com. We will respond within one month, and we may need to verify your identity before acting on your request.

10. California Residents (CCPA/CPRA)

If you are a California resident, the CCPA gives you additional rights.

  • Categories we collect: identifiers (user ID, email address), commercial information (subscription status), internet or other electronic activity (device, usage and crash data), and the content of the documents you upload, which may include sensitive personal information. Sources, purposes and recipients are described in Sections 2, 3 and 5. Retention periods are described in Section 7.
  • No sale or sharing: we do not sell personal information and do not share it for cross-context behavioral advertising, and we have not done so in the past 12 months. We do not knowingly sell or share the personal information of consumers under 16.
  • Sensitive personal information: we use it only to provide the services you request, as permitted by the CCPA, and not to infer characteristics about you.
  • Your rights: you can request to know, access, correct and delete your personal information, and you will not be discriminated against for exercising these rights. You may use an authorized agent. To make a request, email info@perfexus.com.

11. Children

Klozai is not directed to children under 16, and we do not knowingly collect personal data from children under 16. If you believe a child has provided us with personal data, please contact us and we will delete it.

12. Cookies and the Website

The Website does not set cookies and does not use analytics, advertising or other tracking technologies, so it does not show a cookie banner.

To deliver the Website and protect it against abuse, our hosting provider (Firebase Hosting by Google) processes technical data such as your IP address, browser type and the page you requested. All fonts, scripts and images of the Website are served from our own domain; the Website does not load content from third-party servers.

13. Changes to This Policy

This Privacy Policy may be updated from time to time. We will announce material changes through the App or the Website and update the “Last updated” date above.

14. Contact

For privacy-related inquiries or to exercise your rights: 📧 info@perfexus.com