Privacy Policy

Last updated: April 21, 2026

This privacy notice for İnvivo Yazılım ve Teknoloji A.Ş., operating as RaqunAI ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

Download and use our mobile application (RaqunAI), or any other application of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

Summary of Key Points

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect any information from third parties? We do not collect any information from third parties. However, our AI processes video content from third-party platforms (such as Instagram and TikTok) that you explicitly choose to share with us in order to extract and organize structured knowledge on your behalf.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

01 — What Information Do We Collect?

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names
email addresses
usernames
passwords

Content You Submit for AI Processing. When you use RaqunAI's core feature, you voluntarily share video links or video content from third-party platforms such as Instagram and TikTok. We use this content solely to extract structured knowledge (such as recipes, ingredients, steps, locations, products, or workout details) on your behalf. We do not permanently store the original video content. Only the AI-extracted structured data is saved to your personal knowledge library.

Application Data. When you use our mobile application, we may collect the following types of information to provide and improve our Services:

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera and other features. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. This log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports, and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

02 — How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To power AI extraction features. We process video content you share with us to extract and organize structured knowledge into your personal library.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

03 — What Legal Bases Do We Rely On To Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the United Kingdom or European Economic Area

The UK General Data Protection Regulation (UK GDPR) and EU General Data Protection Regulation (EU GDPR) require us to explain the valid legal bases we rely on to process your personal information. We rely on the following legal bases:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services, managing your account, processing payments, and delivering the AI extraction features you sign up for.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not override your fundamental rights and freedoms. This includes extracting structured data from videos you share (which may contain personal information of third parties), analysing how our Services are used to improve them, preventing fraud, and keeping our Services secure. Where we rely on legitimate interests, we conduct a balancing test, which you can request a summary of by contacting us.
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as responding to a lawful request from public authorities, to cooperate with law enforcement, to meet tax and accounting requirements, or to exercise or defend our legal rights.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If the information is publicly available and is specified by the regulations

04 — When And With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
AI Service Providers. We use third-party AI providers, currently including OpenAI and Anthropic, to process video content and extract structured information. These providers act as data processors on our behalf under data processing agreements that (i) prohibit use of your content for training their models, (ii) require appropriate technical and organizational security measures, and (iii) limit processing to the purpose of providing the extraction service to us.
Payment Processors & Subscription Management. Subscription payments are processed by Apple (App Store) and Google (Google Play). We use RevenueCat to manage subscription status and entitlements across platforms. We do not receive or store full payment card details. These providers process your payment data under their own privacy policies.
Hosting and Infrastructure Providers. We use cloud hosting and storage providers (currently including DigitalOcean) to run our Services. They process personal data as processors on our behalf.
Analytics and Error Monitoring Providers. We use analytics (currently including Google Analytics) and error/crash reporting tools to understand usage and fix issues. Where legally required, these are only loaded after your consent.
Push Notification Providers. We use push notification services to deliver in-app and device notifications you have opted into.
Legal and Regulatory Bodies. We may disclose your information to courts, regulators, or law enforcement where legally required or permitted.

05 — Do We Use Cookies And Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

06 — How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

07 — How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

08 — Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

09 — What Are Your Privacy Rights?

In Short: Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. You may review, change, or terminate your account at any time.

In many regions (such as the EEA, UK, Canada, Brazil, and Turkey), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided below.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at [email protected].

10 — Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11 — Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

Category A. Identifiers — Contact details, such as real name, email address, unique personal identifier, online identifier, Internet Protocol address, and account name — YES (email, username, IP)
Category B. Personal information as defined in the California Customer Records statute — Name, contact information — YES (name, email)
Category C. Protected classification characteristics — NO
Category D. Commercial information — Subscription and transaction information — YES (subscription status)
Category E. Biometric information — NO
Category F. Internet or other similar network activity — Browsing history, app usage, interactions with our Services — YES
Category G. Geolocation data — Device location (approximate, through IP) — YES (approximate only)
Category H. Audio, electronic, sensory, or similar information — Video content shared by the user for AI processing — YES (user-submitted only, not permanently stored)
Category I. Professional or employment-related information — NO
Category J. Education Information — NO
Category K. Inferences drawn from collected personal information — Usage preferences and knowledge categories derived from app activity — YES
Category L. Sensitive personal information — We only collect sensitive personal information as defined by applicable privacy laws or with your consent.

We will use and retain the collected personal information as needed to provide the Services or for:

Category A — As long as the user has an account with us
Category B — As long as the user has an account with us
Category D — As long as the user has an active subscription or account with us
Category F — As long as the user has an account with us
Category H — Only for the duration of the AI processing session; original video is not permanently stored
Category K — As long as the user has an account with us

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending upon the state where you live, you may also have the following rights:

Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon's privacy law)
Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at [email protected], or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

12 — Do Residents of the United Kingdom or European Economic Area Have Specific Rights?

In Short: If you are located in the UK or the EEA, you have specific rights under the GDPR regarding your personal data, including the right to access, rectify, erase, restrict processing, data portability, and object to processing.

If you are a resident of the United Kingdom or European Economic Area (EEA), you have certain data protection rights. RaqunAI aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data.

If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us at [email protected].

In certain circumstances, you have the following data protection rights:

Right to access — the right to request copies of your personal data.
Right to rectification — the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
Right to erasure — the right to request that we erase your personal data, under certain conditions.
Right to restrict processing — the right to request that we restrict the processing of your personal data, under certain conditions.
Right to object to processing — the right to object to our processing of your personal data, under certain conditions.
Right to data portability — the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
Right to withdraw consent — where we rely on consent to process your personal data, you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at [email protected].

You also have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the EEA or the Information Commissioner's Office (ICO) in the UK.

13 — International Data Transfers

In Short: Your information may be transferred to, stored, and processed in countries other than your own. Where it is, we use legally recognized safeguards.

We are based in Turkey. Some of our service providers and sub-processors — including AI providers, cloud hosting providers, and analytics providers — are located outside Turkey and the European Economic Area, including in the United States.

When we transfer personal information outside the European Economic Area or the United Kingdom to a country that has not been deemed to provide an adequate level of protection, we rely on one or more of the following safeguards:

Standard Contractual Clauses (SCCs) approved by the European Commission;
The UK International Data Transfer Addendum to the EU Standard Contractual Clauses, or the UK International Data Transfer Agreement;
Adequacy decisions issued by the UK or European Commission;
Certifications under recognized frameworks (e.g., the EU–US Data Privacy Framework and the UK Extension thereto), where applicable.

You may request a copy of the relevant safeguards in place for a specific transfer by contacting us at [email protected].

14 — Do Residents of Brazil Have Specific Privacy Rights? (LGPD)

In Short: If you are a resident of Brazil, you have specific rights under the Lei Geral de Proteção de Dados (LGPD) regarding your personal data.

If you are a resident of Brazil, you have certain rights under the LGPD, including:

Confirmation of the existence of processing
Access to your personal data
Correction of incomplete, inaccurate, or outdated data
Anonymization, blocking, or deletion of unnecessary or excessive data
Portability of your data to another service or product provider
Deletion of personal data processed with your consent
Information about public and private entities with which we have shared your data
Information about the possibility of denying consent and the consequences thereof
Revocation of consent

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

15 — Do Residents of Turkey Have Specific Privacy Rights? (KVKK)

In Short: If you are a resident of Turkey, you have specific rights under the Kişisel Verilerin Korunması Kanunu (KVKK, Law No. 6698) regarding your personal data.

If you are a resident of Turkey, you have the following rights under the KVKK:

The right to learn whether your personal data has been processed
The right to request information about the processing if your personal data has been processed
The right to learn the purpose of the processing and whether it is being used for its intended purpose
The right to know the third parties to whom your personal data has been transferred domestically or abroad
The right to request the rectification of incomplete or inaccurate data
The right to request the deletion or destruction of personal data under conditions prescribed by law
The right to request notification of the operations carried out under rectification and deletion to third parties to whom your personal data has been transferred
The right to object to a result that is against you arising exclusively from the analysis of your data processed through automated systems
The right to claim compensation if you have suffered damage due to the unlawful processing of your personal data

To exercise any of these rights, please contact us at [email protected]. We will respond within thirty (30) days in accordance with the KVKK.

16 — Do We Make Updates To This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

17 — How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

İnvivo Yazılım ve Teknoloji A.Ş.
Erzene Mah. Ankara Cad. EBİLTEM / 172 /14, Bornova / İzmir, Turkey
Email: [email protected]

18 — How Can You Review, Update, Or Delete The Data We Collect From You?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please contact us at: [email protected]