Privacy Policy

Overview

This Privacy Policy describes how Dr. Cleaner treats information that it collects and receives related to your use of Dr. Cleaner's products, services, and websites. Our primary goal in collecting information is to provide and improve our products and services.

General

1. At Dr. Cleaner (“we”, “us”, “our”), we regularly collect and use information that could identify an individual (“personal data”), in particular about your purchase or use of our products, services, mobile and software applications and websites (“you”, “your”). The protection of your personal data is very important to us, and we understand our responsibilities to handle your personal data with care, to keep it secure and to comply with legal requirements.

2. By using Application, the Services or the Site, you consent to the privacy practices described in this Policy.

3. This Policy covers our collection, use and disclosure of your information through the Applications, the Services and the Site. It does not cover any collection, use or disclosure by third parties through any applications, Web sites, products or services that we do not control or own, such as Facebook, or any third-party features or services made available via an Application, the Services or the Site. All trademarks, trade names, and logos of third parties featured on the Applications or the Site belong to their respective owners.

4. If you wish to contact our Privacy Officer, you may contact with email: [email protected].

What Information do We Collect?

a. Personal Information. We do not collect Personal Information. "Personal Information" is information that identifies you or another person, which may be transmitted or received when you use an Application, the Services and/or the Site. Personal Information includes your geographic area information, names, physical addresses, email addresses, telephone, fax, SSN, information stored within your Device and other information you transmit or receive using an Application, the Service and/ or the Site which identifies you or another person.

b. non-personal identification. We may collect non-personal identification information about Users whenever they interact with our apps. Non-personal identification information may include the type of your phone and technical information about Users means of connection to our apps, such as the versions of phone model and other similar information.

1.Session and Usage Data. "Session and Usage Data" is information about your use of an Application, the Services and/or the Site and includes, without limitation, connection and service-related data submitted to us through your use of an Application, the Services or the Site. Session and Usage Data includes information relating to the connection request, server communication and data sharing, including network measurements, quality of service, and date, time and area. We also may aggregate Session and Usage data as described in Aggregate Information below. Please note that Session and Usage Data does not include any Personal Information nor does it include Content you may transmit or share through the use of an application (such as photos, contacts, calendar appointments, etc.), the Services, or the Site.

2. Log Data. When you interact with us or use an Application, the Services or our Site, our systems may automatically collect your unique User Device number, the IP address, type of browser or operating system you use, and the dates and times of your use ("Log Data").

3. Aggregate Information. "Aggregate Information" is data we collect about a group or category of services or Users from which individual User identities have been removed. In other words, information on how you use the Applications, the Services and the Site may be collected and combined with information about how others use the Applications, the Services and the Site, but no personally identifiable information will be included in the resulting Aggregate Information. Aggregate Information helps us understand trends in our Users' needs so that we can better consider new features or otherwise tailor the Applications, the Services and the Site.

4. Other Information. You may provide us with various information in connection with your interaction with our Services. For example, you may through tagging functionality report a phone number as spam or some other attributes to be included in spam blocking directories. We will collect the information you provide in connection therewith, as well as any other information you provide through the services or when you communicate or interact with us.

If you do not provide some of the information mentioned below, you may not be able to continue using the product and / or services that we provide, and if you do not agree that the information to be collected after your installation or use of the product, you may stop using or uninstall our product and / or services, or contact us for advice; for the other types of information, your refusal to provide or opt-out option may cause you unable to access certain specific features or get the best experience.

(1) Device information

We collect device-specific information (such as your hardware model, operating system version etc.).

(2) Log information

When you use our product and service or view the content provided by us, we automatically collect and store certain information in server logs. This includes: Details of how you used our service, such as your scanning number of junk files.

(3) Internet Protocol address

Device event information such as crashes, system activity, hardware settings, browser type, the date and time of your request and referral URL.

(4) Location information

When you use Weather features or services, we may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS.

The collection and use of location information is for weather report and if you refuse to or stop providing it, or we can’t provide any weather information at all. For more details on location information, you can also find out in the following section of “Permissions on your device”.

(5) Email address

When you choose to activate our App Lock function, you may choose to provide us with a valid email address as the “recovery email” which could be used to reset the password of your App Lock (you may choose not to set the recovery email, but in this case, we’ll not be able to help you reset a password).

c. Permissions on your device

In providing our product’s functions and services, we may need you to allow certain “permissions” on your device, which will enable to information collection and usage relevant to those functions. These include the permissions described in the list below (please take note that we may revise and update this list from time to time, for reasons such as update or revision of our product, technology upgrading such as changes in your phone’s operating system, or legal and policy requirements. Such changes will be posted in our updated Privacy Policy):

1.Read and delete files on storage

2.Photos / media / files

3.Phone statue and user identity

4.Apps running background

5.Camera

6.WLAN

7.Wi-Fi and Network State

8.Shortcuts

9.Location

10.Bluetooth

11.Contacts

12.Battery status

13.Kill background applications

You can check if such permissions are allowed or not for our product and service, which can be done by checking “Settings – Apps” and / or “Settings – Permissions” in your device, and thereby decide whether each permission will continue to be allowed or will be denied. The specific way to review the status of such permissions and deny them may vary in different devices, and please refer to the notes or instructions provided by relevant device OEMs and OS developers. In case that you’re unable to carry out the relevant steps and adjust the settings in your currently-used product or device, please contact us or the OEM of your device.

Please note that allowing these permissions will be deemed as your consent to allow us to collect and use relevant information to realize relevant functions; when you deny or disable the permissions in whole or in part, it means you have refused to provide related information to us, therefore also making us unable to provide you those functions relevant to such permissions. To the extent allowed by applicable laws, your decision to deny a certain permission on your device does not affect or invalidate our previous handling of your relevant information which has been based on your prior consent to allow such permission.

How and Why do we use this Information?

a. Personal Information —— since we do not collect Personal Information, we may not use your personal information in any way.

• To make our service available. We use information that you submit and information that is processed automatically to provide you with all requested services.

b. Non-Personal Information. We may use Non-Personal Information for any purpose as below: 1 To personalize user experience —— We may use your Non-Personal Information to understand demographics, customer interest, and other trends among our Users;

2 To help develop our service —— We may use Non-Personal Information to provide, maintain, improve and modify the Applications, Services and the Site and develop new services, such as maintaining User spam lists and build a community-based spam blocking directory;

3 To further develop Phone Clean Apps business. We may use Non- Personal Information for promotion and marketing purposes.

How your information may be disclosed?

a. Personal Information. In general, we use Session and Usage Data internally to serve our Users and enable them to take maximum advantage of the Applications, the Services and the Site. We do not store Personal Information and therefore we do not disclose your Personal Information.

b. Non-Personal Information. We may disclose Non-Personal Information to our trusted partners who shall comply with this privacy policy and the relevant privacy laws. We do not combine Non-Personal Information with Personal Information (such as combining your name with your unique User Device number).

Transfers of Your Information

If you choose to use the Service or provide your information to us, your information may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located, including the United States. Such countries may have laws that are less protective than the country in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Site or Service.

Links to other Web sites and Third-Party Ads

The Services may include advertisements regarding or otherwise contain hyperlinks to other websites, including those of our business partners, vendors and advertisers. Advertisements for third parties and their products may be included with the Services and those third-party advertisements and web sites may include a cookie, web beacons, or other device(s) of the third party. We do not have control over the cookies, web beacons, or other devices used by third parties and do not have access to whatever information they may collect. You acknowledge and agree We are not responsible for the content or for the privacy practices employed by third parties.

Disclosure of Your Information

1. If you violate laws and regulations (such as sending harassment messages), we will legally disclose your personal information.

2. Your payment information may be share with third parties as needed for billing purposes and to prevent fraud.

Security

We implement industry standard security measures intended to protect against the loss, misuse and alteration of the information under our control. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit on or through the Service and you do so at your own risk.

Retention

1. Personal data shall be processed and stored as long as required by the purpose they have been collected for.

Therefore:

• Personal data collected for purposes related to the performance of a contract between us and you shall be retained until such contact has been fully performed.

• Personal Data collected for the purposes of the Company’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Company within the relevant sections of this document or by contacting the Company.

2. The company may be allowed to retain personal data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Company may be obligated to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

3. Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Child’s Privacy

Our website is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under the age of 18 may provide any personal information to the Website. If you are under 18, do not use or provide any information on this Website or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under the age of 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

For Individuals in European Economic Area, Switzerland and/or the United Kingdom

1. This section only applies to individuals that access or use our Service while located in the European Economic Area, Switzerland and/or United Kingdom (collectively, the “Designated Countries”) at the time of data collection. We may ask you to identify which country you are located in when you use some of the Services, or we may rely on your IP address to identify which country you are located in.

2. We act as a data controller with regard to any personal information collected from individuals accessing or using its Service. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers or are otherwise acting on our behalf are “data processors” that handle your personal information in accordance with our instructions.

3. Legal Bases for Processing Your Personal Information. We describe our legal bases for processing throughout this Policy. Below is a list of the purposes described in our policy with the corresponding legal bases for processing:

• Users have given their consent for one or more specific purposes;

• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

• processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

4. Your Individual Rights. We provide you with the rights described below when you use our Service. If you would like to exercise your rights under applicable law, please contact us at [email protected]. Please note, we may seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal information.

• Right to Withdraw Your Consent. If we ever asked for your consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

• Right of Access. Upon your request, we will provide you with a copy of your personal information in our files without undue delay and free of charge, unless we permitted by law to charge a fee. Your access may be limited to the extent it would adversely affect the rights and freedoms of other individuals.

• Right to Rectification (or “Correction”). You may request to correct or update any of your personal information in our files. We may provide you with the ability to update some or all of your personal information directly via the Services.

• Right to Erasure (or the “Right to be Forgotten”). Upon your request, we will erase any of your personal information in our files that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

• Right to Restriction. You have the right to restrict our processing of your personal information under certain conditions. During the time which restriction of processing applies, we will only process your restricted personal information with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.

• Right to Object. You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent; contract; or legitimate interests. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

• Right to Data Portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller,” where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. You right to data portability only applies to personal information provided by you to us.

• Notification to Third Parties. When we fulfill your individual rights requests for correct (or rectification), erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.

• Automated Individual Decision-Making, Including Profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

• Limitations to Individual Rights Requests. We may limit your individual rights requests in the following ways:

I. Where denial of access is required or authorized by law;

II. When granting access would have a negative impact on other's privacy;

III. To protect our rights and properties; and

IV. Where the request is frivolous or burdensome.

• Transfer of Your Personal Information. We transfer your personal information subject to appropriate safeguards as permitted under the applicable data protection laws. Specifically, when your personal information is transferred out of the Designated Countries, we have the required contractual provisions for transferring personal information in place with the third-parties to which your information is transferred. For such transfers, we rely on legal transfer mechanisms such as Standard Contractual Clauses or we work with U.S. based third parties that are certified under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.

• Right to Lodge Complaints. If you believe that we have infringed or violated your privacy rights under applicable law or this Policy, please contact us at [email protected], so that we can work with you to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

Kamil Kulekci

Last updated: June 2022