TERMS OF SERVICE, PRIVACY POLICY AND DATA PROTECTION NOTICE

N'OLUYO INFORMATIVE TEXT ON THE PROCESSING OF PERSONAL DATA WITHIN MEMBERSHIP PROCESSES

N'oluyoTerms of Service Privacy Policy KVKK Notice

Last Updated: February 10, 2026

At AI Impact (“N'oluyo”), we value the protection of your personal data and expect you to show the same sensitivity. Therefore, reading this text, which explains in detail what personal data we process and for what purposes, and demonstrating that you clearly understand the obligations of N'oluyo, as the “Data Controller” responsible for their administrative and technical security, is very important to us.

Why am I reading this text?

Article 10 of Law No. 6698 on the Protection of Personal Data (“KVKK”), which entered into force on April 7, 2016, requires that the persons whose personal data are processed (referred to as data subjects in the KVKK) be informed by the “Data Controller” using such data. As the Data Controller, we must also prove that you have been informed about the personal data we will process about you.

What personal data do we process and how are they obtained?

As N'oluyo, we obtain the personal data covered by this informative text through digital means (referred to in the KVKK as “automated methods”) when you register via our mobile application and during your ongoing membership. The personal data obtained and the legal basis for their collection are explained below:

Data Category

Processed Personal Data

Legal Basis for Collection

Communication Data

Your gender, date of birth, email, phone number, ip address, device id, if provided

Processing is necessary for the establishment and performance of the membership agreement.

Processing Security Data

Your password information, email and mobile phone verification details, IP address

Processing is mandatory to fulfill our legal obligations through your use of our N'oluyo mobile application.

For what purposes and legal grounds are the collected personal data used?

The table below details the personal data processing purposes, the categories of personal data used, and the legal basis for processing:

Processing Purpose

Relevant Personal Data Categories

Legal Basis for Processing

To establish the membership agreement

Identity, Communication

Necessary for the establishment and performance of the contract.

To create your membership profile and record past applications

Identity, Communication

Necessary for the fulfillment of our legal obligations.

To provide notification communications regarding your membership

Identity, Communication

Necessary for the fulfillment of our legal obligations.

To ensure accuracy and verification of your contact information

Identity, Communication, Processing Security

Necessary for the fulfillment of our legal obligations.

To ensure, audit, and improve system security

Processing Security

Necessary for the fulfillment of our legal obligations.

To maintain and update technical infrastructure, detect and resolve system issues, and carry out password renewal operations

Communication, Processing Security

Necessary for the fulfillment of our legal obligations.

Is your personal data transferred to third parties?

Yes, your personal data may be transferred to our business partners, official authorities, auditors, lawyers, and financial advisors, but only within specific purposes and with your knowledge. Specifically, data may be transferred to:

What rights does the KVKK grant you?

The KVKK grants you rights including (but not limited to): (a) learning whether your personal data are processed; (b) requesting information if they have been processed; (c) learning the purpose of processing and whether they are used accordingly; (d) knowing the third parties to whom your data are transferred domestically or abroad; (e) requesting correction if incomplete or incorrect; (f) requesting deletion or destruction. You can find the full list and details of these rights in Article 11 of the KVKK.

How can you exercise your rights?

To exercise your rights, you can submit requests in writing (e.g., via registered letter with return receipt) or through a registered electronic mail (KEP) address, secure electronic signature, mobile signature, or the email address previously notified and registered in our system.

N'oluyo CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA WITHIN THE SCOPE OF PERSONALIZATION

As AI Impact (“N'oluyo”), we value the protection of your personal data and expect you to show the same sensitivity. Therefore, it is important for us that you read this text explaining in detail which of your personal data we use and for what purposes, and by doing so, show that you clearly understand the obligations of N'oluyo, acting as the "Data Controller", in ensuring their administrative and technical security.

Why am I reading this text?

Article 10 of the Personal Data Protection Law No. 6698 (“KVKK”), which came into force on April 7, 2016, obliges the “Data Controller” to inform individuals whose personal data is processed (referred to as the data subject under the KVKK). As the Data Controller, we are also required to prove that you have been informed about the personal data we will process regarding you.

What personal data is collected and how is it obtained?

We, as N'oluyo, obtain your personal data within the scope of this clarification text through digital means when you update and personalize your membership profile via our mobile application (referred to in the KVKK as “automated means”). The types of personal data obtained and the legal basis for obtaining them are explained below:

Data Category

Processed Personal Data

Legal Basis for Collection

Identity Data

Your gender, date of birth, email, phone number, ip address, device id, if provided

Collected with your explicit consent when personalizing your profile

Legal Transaction Data

Record of your explicit consent

Required to fulfill our legal obligations under the personalization process

For what purpose and on what legal basis is your personal data used?

The purposes for processing your personal data within the scope of our legal obligation to inform are detailed below, along with the relevant data categories and legal bases:

Purpose of Data Processing

Relevant Data Category

Legal Basis for Processing

● Personalizing your membership profile at your request,

● Segmenting our members based on the obtained information,

● Creating statistics related to our website processes

Identity

Explicit consent

● Recording your consent or rejection regarding your membership account

Identity, Legal Transaction

Necessary to fulfill our legal obligations

● For the purpose of monitoring and conducting legal affairs

Identity, Legal Transaction

Necessary for the establishment, use, or protection of a right

Is your personal data shared with third parties?

Yes, we may need to share your personal data with our business partners, public authorities, auditors, lawyers, and financial advisors. However, such transfers are made only for specific purposes and with your knowledge. Your personal data may be transferred to:

What rights does KVKK grant you?

KVKK provides you with several rights regarding your personal data, including but not limited to: (a) learning whether your personal data is processed, (b) requesting information if it has been processed, (c) learning the purpose of processing and whether it is used in line with that purpose, (d) knowing third parties to whom your data is transferred, (e) requesting correction if the data is incomplete or incorrect, (f) requesting deletion or destruction of your personal data. You can find all your rights in Article 11 of the KVKK.

How can you exercise your rights?

If you wish to exercise these rights, you may send your requests to us in writing (e.g., via a notice or registered letter with return receipt) or through registered electronic mail (KEP), secure electronic signature, mobile signature, or via the email address you previously provided and registered in our system.

Terms of Service

Company: AI Impact (“N'oluyo”, “we”, “us”)

1. Acceptance of Terms 2. Community Guidelines 3. Eligibility 4. Rights You Grant Us 5. Content of Others 6. Privacy 7. Respecting Rights 8. Other Users’ Content 9. Copyright Policy 10. Suspension & Restrictions 11. Service Changes 12. Disclaimers 13. Limitation of Liability 14. Indemnity 15. Governing Law & Jurisdiction 16. Severability 17. No Waiver 18. Assignment 19. Entire Agreement 20. Contact Us 21. Changes to These Terms

1. Acceptance of Terms

By downloading, accessing, or using N'oluyo (the “Services”), you confirm that you have read, understood, and agree to be bound by these Terms of Service (“Terms”) and our Privacy Policy. If you do not agree, do not use the Services and delete your account.

2. Community Guidelines

1. Respectful Behavior
Insults, threats, bullying, hate speech, or harassment are prohibited. Users must respect the boundaries of others and comply with applicable local laws.

2. Inappropriate Content
Sexual, explicit, or content targeting or involving minors is strictly prohibited.

3. Privacy
Sharing personal information (such as phone numbers, addresses, identification details, etc.) and directing users to communicate outside the app are not allowed.

4. Safety
If you are subjected to bullying, harassment, threats, or insults, leave the room and report the user. Please submit the incident to us together with any available evidence. We may apply necessary sanctions, including permanent restrictions, in accordance with Article 10.

5. Public Audio Rooms

Enforcement Notice
We may enforce these Rules and Terms at our sole discretion. Enforcement actions may include content removal, limitation or revocation of access to certain rooms or features, account suspension, or permanent bans. For details, please refer to Article 10.


3. Eligibility

You must be legally capable of entering into these Terms and meet any minimum age requirements applicable in your jurisdiction. If you are under the age where consent is required, you must have your parent/guardian’s consent to use the Services.

4. Rights You Grant Us (License & Safety/Quality Capture)

License for operation. You retain ownership of your content. You grant N'oluyo a worldwide, non-exclusive, royalty-free license to host, store, use, reproduce, modify, adapt, publish, display, and distribute your content solely to operate, provide, maintain, protect, and improve the Services.

Public vs. private scope. Only Public Voice Rooms are inherently public. The broader license language above applies only to content you submit in Public Voice Rooms. It does not apply to private communications (if any).

Safety/quality capture (narrowed). In Public Voice Rooms only, we may capture and retain limited audio/content for safety, abuse prevention, dispute resolution, and quality assurance. Access is restricted to authorized personnel. Retention: 30 days, unless a longer period is legally required (e.g., a valid authority request or ongoing investigation). We do not record private communications (if any) unless we show you a just-in-time notice and obtain consent where required by law.

5. Content of Others

Content available via the Services is the sole responsibility of the person who makes it available. We do not endorse, guarantee, or assume responsibility for such content.

6. Privacy

Your use of the Services is subject to our Privacy Policy, which explains how we collect, use, and share information.

7. Respecting Rights

Do not post content that violates law or third-party rights (including privacy, publicity, or intellectual property). You must have the necessary rights to submit any content you provide.

8. Other Users’ Content

If you believe any content violates these Terms or the law, please report it in-app or email support@noluyo.app.

9. Copyright Policy and Notice Procedure

We comply with applicable law (including Türkiye’s FSEK 5846) and accept copyright notices in a DMCA-compatible format for international senders. Upon valid notice, we act expeditiously and may terminate repeat infringers.

Send notices to support@noluyo.app including: (i) rights holder/agent signature, (ii) identification of the work, (iii) identification of allegedly infringing material and its location, (iv) contact information, (v) good-faith statement of unauthorized use, (vi) accuracy statement and authority to act.

10. Suspension, Termination, and Feature Restrictions

At any time and at our sole discretion, with or without notice and to the extent permitted by applicable law, we may: (a) temporarily or permanently suspend or terminate your account or access; (b) limit, throttle, or revoke access to some or all features, rooms, or areas; (c) remove, refuse to display, or restore any content; (d) geo-block content or restrict devices; (e) place your account on hold while we investigate; (f) require re-verification or additional eligibility checks.

Grounds (examples). Suspected or actual violations of these Terms or Guidelines; user safety and abuse prevention; fraud or spam risk; protection of our systems or other users; legal or regulatory requests; or when we believe action is necessary to prevent harm.

Appeal. You may appeal an enforcement action by contacting support@noluyo.app. We will review and may uphold, modify, or reverse our decision at our sole discretion.

No liability; no refunds. Except where required by law, we are not responsible for losses arising from enforcement actions and have no obligation to issue refunds or compensation due to access limitations or account closure.

11. Service Changes

We may modify, suspend, or discontinue all or part of the Services at any time, including changing room sizes, availability, eligibility requirements, or introducing/removing features. Where reasonably practicable, we will provide notice. We are not liable for changes, outages, or discontinuations, except where required by law.

12. Disclaimers

THE SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE.” TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

13. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, REVENUE, DATA, OR GOODWILL, ARISING OUT OF OR RELATED TO YOUR USE OF THE SERVICES.

14. Indemnity

You agree to indemnify and hold N'oluyo and its affiliates, officers, employees, and agents harmless from any claim or demand arising out of your content, your use of the Services, or your violation of these Terms or applicable law.

15. Governing Law & Jurisdiction

These Terms are governed by the laws of Türkiye. The courts of İstanbul (Turkey) shall have exclusive jurisdiction, without prejudice to mandatory consumer protection rules that may grant you additional rights in your place of residence.

16. Severability

If any provision of these Terms is found invalid or unenforceable, the remaining provisions shall remain in full force and effect.

17. No Waiver

Failure to enforce any provision shall not constitute a waiver of that or any other provision.

18. Assignment

You may not assign these Terms without our prior written consent. We may assign these Terms at any time.

19. Entire Agreement

These Terms, together with the Privacy Policy and any supplemental terms, constitute the entire agreement between you and us regarding the Services.

20. Contact Us

Email: support@noluyo.app

21. Changes to These Terms

We may update these Terms from time to time. When we make material changes, we will provide reasonable advance notice (e.g., in-app notice or email) unless a change must take effect sooner for legal/compliance reasons or to prevent abuse, in which case changes may be effective immediately. The “Last Updated” date above will be revised. Your continued use of the Services after changes become effective constitutes acceptance of the updated Terms. If you do not agree, stop using the Services and delete your account.

Privacy Policy

1. Information We Collect 2. Purposes & Legal Bases 3. Sharing 4. Storage, Security & Retention 5. International Transfers (KVKK) 6. Your Rights 7. Data Deletion & Requests 8. Children’s Privacy 9. Changes 10. Contact

1. Information We Collect

2. Purposes & Legal Bases

Purposes. Provide and operate the Services; ensure security and abuse prevention; improve quality and features; resolve disputes; provide support.

Audio/Content (Public Voice Rooms). Safety, moderation, abuse detection, quality assurance, dispute resolution.

Legal bases (KVKK). (i) KVKK Art. 5/2-(d) — personal data manifestly made public by the data subject (applicable where you choose to speak in Public Voice Rooms); and/or (ii) explicit consent for cases not covered by 5/2-(d).

3. Sharing

We may share personal data with service providers, professional advisors, group companies, and competent authorities where necessary, under appropriate contractual and technical safeguards and only for the purposes described above or as required by law.

4. Storage, Security & Retention

We implement commercially reasonable technical and organizational measures to protect personal data.

Retention. Audio/Content data from Public Voice Rooms is retained for 30 days, unless a longer retention is legally required (e.g., valid authority request or ongoing investigation). Other data is retained no longer than necessary for the purposes described, subject to legal obligations.

5. International Transfers (KVKK)

We transfer personal data abroad only in accordance with Turkish data protection law (KVKK), including when: (i) the Turkish DPA (KVKK Board) has issued an adequacy decision for the recipient country; or (ii) you provide explicit consent; or (iii) we implement Board-approved undertakings or other binding mechanisms permitted by law.

6. Your Rights (KVKK Art. 11)

You may request: to learn whether your personal data is processed; to request information; to learn the purpose and whether used accordingly; to know third parties to whom data is transferred; to request correction or deletion; to object to processing under certain conditions; and other rights provided by law.

7. Data Deletion & Requests

To exercise your rights or request deletion, contact support@noluyo.app. We may need to verify your identity before responding.

8. Children’s Privacy

The Services are not directed to children under 18. If we learn that we have collected personal data from a child under 18, we will take reasonable steps to delete it.

9. Camera Use in Private Rooms and Visibility of Images

The camera feature available in the application may only be used within private rooms. Once a user activates the camera, their image becomes visible in real time to all participants present in the room.

During camera usage:

10. Screen Recording and Third-Party Recording Risk

N'oluyo does not record, store, or archive camera images. However:

By activating the camera feature, the user explicitly acknowledges and accepts that:

11. User Responsibility

The user acknowledges that any image shared via the camera feature:

The user accepts these risks knowingly and voluntarily.

12. Changes

We may update this Privacy Policy from time to time. Material changes will be notified through reasonable means (e.g., in-app or email). Continued use after the effective date constitutes acceptance.

13. Contact

Email: support@noluyo.app


KVKK Clarification Text (Membership Processes)

Data Controller: AI Impact (N'oluyo) — support@noluyo.app

Personal Data Categories & Legal Basis

Communication / Transaction Security. Email, IP address, verification and account data — processed within the scope of establishment/performance of the contract and legal obligations.

Content / Audio (Public Rooms only). Audio streams and related content produced in Public Audio Rooms — processed pursuant to PDPL Art. 5/2-(d) (data made public by the data subject). In cases falling outside the scope of Art. 5/2-(d), explicit consent is obtained.

Purposes of Processing

Provision and improvement of the service; security and abuse prevention; dispute resolution; quality assurance; user support.

Data Transfers

Suppliers, professional advisors, authorized authorities, and group companies — limited to the stated purposes and subject to appropriate safeguards.

Retention Period

Audio/content data from Public Audio Rooms: 30 days (longer only if legally required or if there is an ongoing legal process). Other data are retained for the period necessary for the purposes or in accordance with legal obligations.

Explanation Regarding the Processing of Camera Images

Within the scope of the camera feature, N'oluyo:

Does not record camera images, Does not store them, Does not process them as personal data within its systems.

Camera images are used solely for real-time communication and automatically end when the session ends.

User’s Explicit Consent and Risk Awareness

By activating the camera feature, the user:

Acknowledges that their image may be viewed by other users in the room, that these images may be recorded by third parties via screen recording or screenshots, and that N'oluyo has no technical or legal control over such recordings,

and accepts that they have given explicit consent within this scope.

Rights and Application

Rights under PDPL Art. 11 (access, request for information, rectification, deletion, objection, etc.). Application: support@noluyo.app. Identity verification may be requested.

KVKK Clarification Text (Personalization)

Data Controller: AI Impact (N'oluyo) — support@noluyo.app

Personal Data Categories & Legal Basis

User-Provided Profile Data. Optional attributes (e.g., gender, year/date of birth) — based on explicit consent to the extent applicable.

Legal Transaction Data. Consent and preference records — processed for legal compliance and the establishment/protection of rights.

Content / Audio (Public Rooms). To the extent relevant in the context of personalization and security, based on PDPL Art. 5/2-(d) (data made public) and/or explicit consent where required.

Purposes of Processing

Personalization and segmentation; service quality; statistics and analytics; security and abuse prevention.

Data Transfers

Suppliers, professional advisors, authorized authorities, and group companies — limited to the stated purposes and subject to appropriate safeguards.

Retention Period

Personalization data are retained for as long as your consent remains valid or until the purposes are fulfilled (without prejudice to legal obligations). Audio/content data from Public Audio Rooms are retained for 30 days; they may be retained longer if legally required.

Rights and Application

You may withdraw your consent at any time and exercise your rights under PDPL Art. 11 via support@noluyo.app. Identity verification may be requested.

© 2026 AI Impact • support@noluyo.app