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KVKK

PERSONAL DATA PROCESSING NOTICE (KVKK)

Last Updated: May 20, 2026

This Disclosure Text has been prepared by NUKAI LABS FZ-LLC (“Company”), acting as the data controller, in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”), published in the Official Gazette dated 07/04/2016 and numbered 29677.

This text is provided in order to fulfill the obligation of disclosure under Article 10 of KVKK regarding the processing of personal data of natural persons using the AstroMera mobile application (“Mobile Application”).

1. Data Controller

Your personal data is processed by the following company acting as the data controller:

NUKAI LABS FZ-LLCAddress: Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, United Arab EmiratesE-mail: info@nukailabs.com

2. Personal Data Processed

Within the scope of the Mobile Application, the following personal data may be processed:

Identity and Profile Data

Name and surname

Date of birth

Place of birth

Time of birth

Contact Data

E-mail address

Usage and Transaction Data

Generated reports and analysis history

Application usage information

Session information

Notification preferences

Technical and Device Data

Device type

Operating system information

Application version

Technical performance data related to application usage

Your personal data is collected through the Mobile Application, via digital systems and technical infrastructure services, fully or partially by automated means.

3. Purposes of Processing Personal Data

Your personal data is processed for the following purposes:

Creation and management of Mobile Application membership

Performing astrological analyses based on your birth information

Providing users with personalized reports and content

Conducting analysis and content generation processes through AI-supported systems

Improving user experience and enhancing service quality

Sending notifications in line with user preferences

Ensuring system security and carrying out information security processes

Fulfilling legal obligations

4. Legal Grounds for Processing Personal Data

Your personal data is processed in accordance with Article 5 of KVKK based on the following legal grounds:

Being directly related to the establishment or performance of a contract

Fulfillment of the Company’s legal obligations

Legitimate interests of the Company (provided that fundamental rights and freedoms are not harmed)

Explicitly stipulated by laws

Where necessary, the explicit consent of the data subject

5. Transfer of Personal Data

Your personal data may be transferred, in accordance with Articles 8 and 9 of KVKK and for the purposes stated above, to the following parties:

Astrological calculation service providers

AI-based analysis and content generation service providers

Cloud and technical infrastructure service providers

Legally authorized public institutions and organizations

Business partners from whom the Company receives services

For the technical provision of the service, certain personal data may be shared with service providers located abroad. These transfer activities are carried out in accordance with Article 9 of KVKK and by taking the necessary security measures.

6. Retention Period of Personal Data

Your personal data is retained:

for the duration of your Mobile Application membership

and for the period required by applicable legislation or for as long as necessary for the purposes of processing following the termination of membership

Personal data whose retention period has expired is deleted, destroyed, or anonymized in accordance with KVKK and relevant legislation.

7. Your Rights Under KVKK

Pursuant to Article 11 of KVKK, you have the following rights as a data subject:

To learn whether your personal data is processed

To request information if your personal data has been processed

To learn the purpose of processing and whether it is used in accordance with that purpose

To know the third parties to whom your data is transferred domestically or abroad

To request correction if your data is incomplete or incorrectly processed

To request deletion or destruction under Article 7 of KVKK

To request notification of these operations to third parties to whom data has been transferred

To object to the occurrence of a result against you through analysis exclusively by automated systems

To request compensation for damages in case of unlawful processing

You may submit your requests regarding these rights to the Company via the following contact address, together with information and documents verifying your identity:support@astromera.com

Your requests will be concluded within 30 days at the latest in accordance with Article 13 of KVKK.

9. Explicit Consent Statement

Users’ personal data (name, surname, e-mail address, date of birth, time of birth, and place of birth), within the scope of the AstroMera mobile application;

performing astrological analyses based on birth information,

providing personalized reports, content, and interpretations,

conducting analysis and content generation processes through AI-supported systems,

improving user experience and enhancing service quality

may be processed by NUKAI LABS FZ-LLC and, where necessary, may be shared with service providers located domestically and abroad for the realization of these purposes.

Personal data may be processed and transferred only if users provide their explicit consent for the purposes stated above.

Users have the right to withdraw their explicit consent at any time.

8. Changes to the Text

The Company reserves the right to make changes to this Disclosure Text in line with changes in applicable legislation and data processing processes. The updated text will be published within the Mobile Application or on the relevant website.

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