This Privacy Policy explains how Clovy Yazılım Teknolojileri A.Ş. ("Clovy App Studio", "we", "us", "our") collects, uses, and shares information about you when you use the Fanly mobile application ("Fanly", "the App"). Fanly is an AI photo and video maker: you upload photos and the App generates new images and short videos from them.
We are committed to protecting your privacy in accordance with the Turkish Personal Data Protection Law (KVKK No. 6698) and the EU General Data Protection Regulation (GDPR), where applicable.
Fanly is operated by Clovy Yazılım Teknolojileri A.Ş., a company registered in Türkiye with its principal place of business in Ankara. For privacy-related questions, contact us at support@clovyappstudio.com.
Fanly does not require you to create an account with an email address or password. When you first open the App, we create an anonymous account for you and assign it a random user identifier. This identifier is not linked to your name, email address, phone number or Apple ID.
To generate content, we process what you choose to provide:
We access your camera or photo library only after you grant permission, and only when you choose to add a photo.
For each generation we keep a technical record: your anonymous user identifier, the template used, its coin cost, a processing identifier, status and timestamps. We also keep your coin balance and a history of coin purchases, spends and refunds. These records do not contain your photos, your face data or the text you enter.
We do not collect or store credit card numbers or other payment instruments. All payments are processed by Apple and never reach our servers.
If you grant App Tracking Transparency permission on iOS, we collect the Advertising Identifier (IDFA) and limited install attribution data to measure the effectiveness of our marketing. You can revoke this permission at any time in Settings → Privacy & Security → Tracking.
Your list of creations, recently used photos, your AI processing consent and cached app settings are stored locally on your device and are not sent to our servers.
When you use an AI feature, you choose one or more photos (for example a selfie) and may enter text such as a name or number. These photos may contain your face. We call this "face data" in this policy.
Fanly does not use face data to identify you, does not create facial recognition templates or biometric identifiers, and does not use your face for authentication. Your photos are used only as input to generate the image or video you request.
Photos are collected only when you select them from your photo library or take them with your camera inside the App, and only after you agree to the "AI data processing" prompt. If you do not agree, no photos or inputs are sent and no content is generated.
Your photos and inputs are used solely to process your request and return the generated image or video to you. We do not use face data for advertising, marketing, profiling, analytics, or to train AI models, and we do not sell it.
To generate your content, your photos and inputs are sent to a third-party AI processing provider that runs the AI models creating your image or video. The provider processes this data only on our behalf and only to fulfil your request, under a contractual agreement that requires it to protect the data at a level equal to or greater than described in this policy and prohibits using it for any other purpose, including training AI models. We do not share face data with any other third party.
You can delete individual creations in the App at any time. You can delete your account in Settings → Delete Account & Data. To have your photos or generated content deleted before the 30-day period ends, contact us at support@clovyappstudio.com. We will process the request within 30 days.
We ask for your permission in the App before sending any photos or inputs to our AI processing provider. You can decline. In that case AI features will not run.
Photos that contain your face are treated as a special category of personal data under KVKK and GDPR and receive heightened protection.
We share data with the following processors under contractual agreements that require them to safeguard your information:
| Service | Purpose | Data shared | Privacy policy |
|---|---|---|---|
| AI processing provider | Image and video generation | Photos and text inputs you submit; generated outputs (stored in Germany, deleted after 30 days) | See Section 3 |
| Supabase | Backend, anonymous authentication, database | Anonymous user ID, generation records, coin balance and history | supabase.com/privacy |
| RevenueCat | Subscription and purchase management | Anonymous user ID, App Store transaction identifiers, subscription status | revenuecat.com/privacy |
| Adjust | Install attribution and marketing measurement | IDFA (with ATT consent), device identifiers, install events | adjust.com/privacy-policy |
| Amplitude | Product analytics | Anonymous user ID, in-app events, device metadata | amplitude.com/privacy |
| Apple | App distribution and payments | Purchase data, IDFV, IDFA (with ATT consent) | apple.com/legal/privacy |
We do not sell your personal data to third parties.
Some of our processors are located outside Türkiye and the EU. Data transfers are protected by Standard Contractual Clauses or equivalent safeguards, as required by KVKK and GDPR. Photos you upload for AI processing are stored in Germany (EU).
Under KVKK and GDPR you have the right to:
To exercise these rights, email support@clovyappstudio.com. You can also delete your account directly inside the App at any time. Your anonymous user ID is shown in Settings; including it in your email helps us find your data.
Fanly is intended for users 13 years of age or older. We do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal information, contact us and we will delete it.
We implement administrative, technical, and physical safeguards designed to protect your information. Communications between the App and our servers are encrypted in transit using TLS. Stored data is encrypted at rest by our infrastructure providers. Despite these safeguards, no system is completely secure, and we cannot guarantee absolute security.
We may update this Privacy Policy from time to time. The "Effective date" above indicates when the latest version took effect. Material changes will be communicated through the App.
Clovy Yazılım Teknolojileri A.Ş.
Üniversiteler Mah. İhsan Doğramacı Bul. No: 31 İç Kapı No: 23
Çankaya / Ankara 06800, Türkiye
support@clovyappstudio.com