Last updated: April 8, 2026, 
FATEFULL MOMENT PRIVACY POLICY 
 
1.  Introduction ..................................................................................................................................... 2 
2.  Summary of Key Points .................................................................................................................... 2 
3.  Definitions ....................................................................................................................................... 2 
4.  What data we collect about you ..................................................................................................... 3 
5.  How we use your personal information (For COPPA) ..................................................................... 4 
6.  How we use your personal data (for GDPR) .................................................................................... 4 
7.  Legal Basis for Use of Your Personal Information ........................................................................... 8 
8.  We share information about you as follows or as otherwise described in this Privacy Policy: ...... 8 
A.  Sharing Your Personal Data ........................................................................................................ 8 
B.  Service Providers ........................................................................................................................ 9 
C.  Cookies ....................................................................................................................................... 9 
D.  Analytics ..................................................................................................................................... 9 
9.  Data Transfer and Security ............................................................................................................ 10 
A.  Data Transfer ............................................................................................................................ 10 
B.  Data Security ............................................................................................................................ 10 
10.  Data Retention: How long we keep your personal data .......................................................... 10 
11.  Your rights ................................................................................................................................ 11 
12.  Children’s Privacy and Parental Controls ................................................................................. 11 
13.  Privacy Policy Changes and Updates ........................................................................................ 12 
14.  Further questions and how to make a complaint .................................................................... 12 
 
 
 
 
 
 
 
 
 

1. Introduction

At FATEFULL MOMENT, we extend a warm welcome to you! FATEFULL MOMENT is an artificial

intelligence-powered application designed for use by both adults and children. This Privacy

Policy explains how we collect, use and process the personal data you share with us when

creating your membership account and using the application.

This Privacy Policy explains how information about you is collected, used and disclosed by

Edicon Tech Bilgi ve Eğitim Teknolojileri A.Ş. when you use our website and mobile application

(“FATEFULL MOMENT”) (together the “Services”). All references in this policy to “FATEFULL

MOMENT” , ", "our", "us" or "we", “company” refer to Edicon Tech Bilgi ve Eğitim Teknolojileri

A.Ş., or our group companies, as appropriate.

Company Information:

Our registered Tax ID number is 3241190621 in Turkey and our registered office is located at

Maslak Mah. Bilim Sk. No:5A, Sun Plaza, 16. Kat, Doping Hafıza, Sarıyer/İstanbul

We are always looking to improve the information we provide to our users and contacts, so if

you have any feedback on this privacy policy, please let us know at our email address:

legal@edicontech.com . For any questions, or complaints, please see Section 14 (Further

questions and how to make a complaint) below.

2. Summary of Key Points

This Privacy Policy applies to all users of the Services, including both adult users and children.

The principles and safeguards set out in this Policy are designed to reflect the specific nature,

scope, and functionality of FATEFULL MOMENT as an artificial intelligence-based assistant.

In particular, this Policy addresses:

 AI-Based Interactions: Transparency regarding how we process data for user–AI

engagement, learning features, and automated responses.

 Mixed-Audience Protection: Differentiated treatment of data for children and adult

users in strict accordance with applicable laws.

 Global Compliance: Our commitment to complying with the Children’s Online Privacy

Protection Act (COPPA), the General Data Protection Regulation (GDPR), the Turkish

Personal Data Protection Law (KVKK), and applicable U.S. state privacy laws.

 Data for AI Improvement: How we collect, anonymize, and aggregate data to improve

our AI models, algorithms, and safety features.

Our Commitment: FATEFULL MOMENT is committed to data minimization. We apply

appropriate technical and organizational safeguards and process personal data only for

legitimate, clearly defined purposes. FATEFULL MOMENT does not sell personal data to third

parties.

3. Definitions

Prior to fulfilling our obligation to disclose information, we would like to clarify certain key

concepts as follows:

What is Personal Data? Any information that helps to identify a natural person is considered

personal data. This includes not only traditional identifiers surname, and education

information but also things like IP address, and device IDs.

What is Personal Information (PI)? PI is a more specific subset of personal data. It refers

specifically to information that is related to a natural person who can be identified directly or

indirectly, in particular by reference to an identifier such as age, name, address, phone

number, e-mail address gender, and more. When Personal Information is protected by the

Children's Online Privacy Protection Act (COPPA), personal data is subjected to the General

Data Protection Regulation (GDPR).

What Is Data Collecting Activity? It refers to the process of gathering and storing information

from various sources. In the context of digital technology, it typically involves collecting and

storing data about users and their activities online. This data can include Personal Information

such as name, surname, age, and email information. Data is collected for various reasons,

including to improve companies’ products and services, personalize user experiences.

Who Is the Data Controller? The data controller is the entity or organization that determines

the purposes and means of processing personal data. In other words, they are the ones

responsible for deciding why and how personal data is collected, used, and shared. This can

be an individual or a company that collects and processes personal data. The data controller

is responsible for complying with relevant data protection laws and ensuring that the personal

data is handled in a secure and lawful manner. In this sense, our company is a data controller.

4. What data we collect about you

A. Account Information Data: When you register for FATEFULL MOMENT, we collect

account-related information such as your email address, phone number, password or,

your Apple ID or Google account information.

B. User Profile Data: We may collect profile-related information provided by you, including

your first and last name, and general location information such as country and city. This

information is used to personalize and tailor the Services, customize content, and provide

an age-appropriate user experience.

C. Online Identifiers and Other Technical Data: We automatically collect certain technical

and usage-related information when you access or use the Services. This may include log

data, device identifiers, device model, operating system version, application version,

language preferences, and usage statistics. We may also collect general location

information, such as country and city, which is typically derived by our third-party service

providers from your IP address. We use this information to operate, maintain, secure, and

improve the Services, and to analyze usage patterns.

D. Usage/In-App Data: We collect data relating to your use of the Services, including

information generated through your use of the AI-powered application and chat-based

interactions. This may include interaction patterns, feature usage, machine-learning–

derived signals, and in-app choices. Such data is processed primarily by FATEFULL

MOMENT’s artificial intelligence systems in order to personalize and enhance the user

experience, improve the relevance of AI Outputs, and support the proper functioning of

the Services. This information is not used to directly identify individual users and is

processed in accordance with the purposes set out in this Privacy Policy.

E. Data When You Subscribe to Our Services: Payment processors you use, such as Apple

Pay and Google Pay, will process all purchases, and you will be subject to their terms and

conditions and privacy policy. Your billing information, transaction details, and purchase

history may be retained and used by the payment processors to resolve subsequent billing

disputes and inquiries. We do not collect any of your payment information.

F. Subscription Data: We collect data about the purchase history and subscription details

(this does NOT include payment method details or banking information which is collected

and processed by a third-party), such as subscription type, subscription starting and

ending times, payment processor information (Google or Apple), user ID.

G. Data Collected by Cookies and Other Tracking Technologies: We use various

technologies to collect data, and this may include sending cookies to your mobile device.

Cookies are small data files stored on your device’s internal memory that help us to

improve our Services and your experience and see which areas and features of our

Services are popular. We may also collect data using web beacons (also known as

“tracking pixels”). Web beacons are electronic images that may be used in our Services or

emails and help deliver cookies, count visits, and understand usage and campaign

effectiveness. For more information about cookies, please see Section 8(C) (Cookies)

below.

H. Personal Information and Personal Data when you contact our customer support

function: We collect your e-mail address, your first name, your surname and certain data

about your device, including your mobile phone network and operator, and generated

device identifier information (as well as any other data you include in your correspondence

with us), including any updates to any of that data. This information is used solely to

respond to inquiries, provide support, and improve the quality of our customer service.

5. How we use your personal information (For COPPA)

FATEFULL MOMENT is designed to minimize the collection and processing of Personal

Information from children under the age of 13. We collect and process such information only

where necessary to provide the Services and only after obtaining verifiable parental consent,

as required under the Children’s Online Privacy Protection Act (COPPA).

In limited circumstances, such as when a parent or child contacts our customer support team,

we may process Personal Information (including contact details and correspondence content)

solely for the purpose of responding to inquiries, providing support, and fulfilling our

obligations under applicable law.

6. How we use your personal data (for GDPR)

We will collect, use and store the personal data listed above for the following purposes of

processing your personal data and legal basis for data processing. Also, you can find the

method of collecting your personal data below:

Processed

Personal Data

Processing Purposes

Legal Basis

Methods of

Collecting Personal

Data

Account

Information Data;

User Profile Data.

Account creation

and account

management

Legitimate interest:

Legitimate interests

of the data controller,

provided that it does

not infringe on the

fundamental rights

and freedoms of the

data subject.

Directly from the

user during account

registration and

profile setup

Account

Information Data;

Usage and In-App

Interaction Data;

Online Identifiers

and Technical Data

Provision of the

Services and core

functionality

Contractual

obligation: For the

performance of the

contract (Terms of

Service), we have

with you or to take

steps to enter a

contract with you.

Collected by

automatic methods

through the

Site/Mobile

Application.

AI Interaction Data

(Prompts and In-

app Outputs);

Usage and In-App

Interaction Data;

Technical Data

AI assistant and chat-

based interactions

Contractual

obligation: For the

performance of the

contract, we have

with you or to take

steps to enter a

contract with you,

Legal Obligation: For

compliance with a

legal obligation we

have

Legitimate interest:

Legitimate interests

of the data controller,

provided that it does

not infringe on the

fundamental rights

and freedoms of the

data subject.

Public task and

official functions: For

the establishment,

Collected by

automatic methods

through the

Site/Mobile

Application.

exercise or protection

of a right.

User Profile Data;

Usage and In-App

Interaction Data;

machine-learning–

derived interaction

signals

Personalization of

the Services and user

experience.

Legitimate interest:

Legitimate interests

of the data controller,

provided that it does

not infringe on the

fundamental rights

and freedoms of the

data subject.

Collected by

automatic methods

through the Mobile

Application.

Personal Data

when you contact

our customer

support function

Improvement of the

Services, analytics,

and product

development

Contractual

obligation: For the

performance of the

contract, we have

with you or to take

steps to enter a

contract with you,

Legal Obligation: For

compliance with a

legal obligation we

have

Legitimate interest:

Legitimate interests

of the data controller,

provided that it does

not infringe on the

fundamental rights

and freedoms of the

data subject.

Public task and

official functions: For

the establishment,

exercise or protection

of a right.

Collected by

automatic methods

through the Mobile

Application.

AI interaction data

processed in

anonymized and

aggregated form

AI model

improvement and

safety mechanisms

Legitimate interest:

Legitimate interests

of the data controller,

provided that it does

not infringe on the

fundamental rights

and freedoms of the

data subject.

AI interaction data

processed in

anonymized and

aggregated form

Technical Data;

Usage Data;

Account identifiers

Security, fraud

prevention, and

misuse detection

Legitimate interest:

Legitimate interests

of the data controller,

provided that it does

not infringe on the

fundamental rights

and freedoms of the

data subject.

Legal Obligation: For

compliance with a

legal obligation we

have

Automatically

collected through

security logs and

monitoring systems

Subscription Data;

user ID;

transaction

identifiers

Subscription

administration (non-

payment data)

Legal Obligation: For

compliance with a

legal obligation we

have.

Contractual

obligation: For the

performance of the

contract, we have

with you or to take

steps to enter a

contract with you,

Automatically from

app stores and

subscription

management

systems

Data required by

applicable law

Compliance with

legal obligations and

lawful requests

Legal Obligation: For

compliance with a

legal obligation we

have.

Data required by

applicable law

Relevant account,

usage, and

communication

data

Establishment,

exercise, or defense

of legal claims

Legitimate interest:

Legitimate interests

of the data controller,

provided that it does

not infringe on the

fundamental rights

and freedoms of the

data subject.

Generated in

connection with

disputes or legal

processes

*Some data may be generated when you interact with the FATEFULL MOMENT assistant, such

as messages you send and responses you receive. This data is processed automatically by the

AI to provide and personalize the Service.

7. Legal Basis for Use of Your Personal Information

We consider that the legal bases for using your Personal Information as set out in this privacy

policy are as follows:

A. our use of your Personal Information is necessary to perform our obligations under any

contract with you (for example, to comply with the terms of service of our apps); or

B. where a does not apply, our use of your Personal Information is necessary for our

legitimate interests or the legitimate interests of others. Our legitimate interests are to:

 run, grow and develop our business (as well as the businesses of our group

companies) including funding our business;

 operate, maintain and improve our apps and our marketing optimization efforts;

 understand the way in which our apps are used; and

 for internal group administrative purposes.

If we rely on our (or another person's) legitimate interests for using your Personal Information,

we will undertake a balancing test to ensure that our (or the other person's) legitimate

interests are not outweighed by your interests or fundamental rights and freedoms which

require protection of the Personal Information. You can ask us for information on this

balancing test by using the contact details at section 12.

8. We share information about you as follows or as otherwise described in this Privacy

Policy:

A. Sharing Your Personal Data

 With any member of our company group, which means our subsidiaries, our

ultimate holding company and its subsidiaries;

 With vendors, consultants and other service providers who need access to such

information to carry out work on our behalf;

 In response to a request for information if we believe disclosure is in accordance

with any applicable law, regulation or legal process, or as otherwise required by

any applicable law, rule or regulation;

 If we believe your actions are inconsistent with the spirit or language of our user

agreements or policies, or to protect the rights, property and safety of FATEFULL

MOMENT or others;

 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; and

 With your consent or at your direction.

We also may share aggregated information or de-identified information, which cannot

reasonably be used to identify you.

We may allow third parties to provide analytics services in connection with our Services. These

entities may use cookies, web beacons and other tracing technologies to collect information

about your use of our Services, including your location, device model, operating system

information, and usage information. This information may be used by FATEFULL MOMENT and

others to, among other things, analyse and track data, determine the popularity of certain

content, deliver content that is relevant to your use of the Services.

Our Services may also integrate third party Application Program Interfaces (APIs), which allow

others to collect and process information about you, including your geo-location information,

to provide you with content.

Third-party analytics technologies are integrated into our Services, so you may manage your

preferences or limit the use of certain analytics technologies through your device or browser

settings, where available.

B. Service Providers

We may share personal data with third-party service providers, vendors, and consultants who

perform services on our behalf and who require access to such information to carry out their

work. These service providers may include, without limitation, hosting and infrastructure

providers, analytics providers, customer support tools, security services, and AI-related

service providers.

Service providers are authorized to process personal data only as necessary to perform

services for FATEFULL MOMENT and are contractually obligated to protect such data and to

process it in accordance with applicable data protection laws and our instructions.

C. Cookies

Our Services use cookies and similar technologies to operate properly, enhance user

experience, remember preferences, and understand how the Services are used. Cookies are

small data files stored on your device that help us provide, protect, and improve the Services.

We use cookies and similar technologies for purposes such as:

-Enabling core functionality and authentication;

-Remembering user preferences and settings;

-Analyzing usage patterns and improving performance and reliability;

-Enhancing security and preventing misuse.

You may configure your browser or device settings to refuse or delete cookies. Please note

that disabling cookies may limit the availability or functionality of certain features of the

Services.

In addition to cookies, we may use similar technologies such as pixel tags, web beacons, or

similar tools to measure the effectiveness of the Services and understand user interactions.

These technologies typically work in conjunction with cookies, and restricting cookies may

impair their functionality.

D. Analytics

FATEFULL MOMENT analyzes usage patterns and user interactions in order to understand how

the Services are used and to improve functionality, performance, and user experience.

FATEFULL MOMENT and its service providers may use server logs, cookies, and similar tracking

technologies to collect and analyze certain technical and usage information, such as user

identifiers, general location information (e.g., country), device type, operating system, and

usage data.

This information may include interaction frequency, session duration, feature usage, and

other aggregated usage metrics. Analytics data is used to evaluate the effectiveness of the

Services, identify areas for improvement, and enhance overall service quality.

Where required by applicable law, users may manage or limit the use of analytics technologies

through device or browser settings.

9. Data Transfer and Security

A. Data Transfer

The transfer of data across borders is a common occurrence in our global operations. We may

transfer your Personal Information to other companies within FATEFULL MOMENT or third-

party entities located around the world, in accordance with the purposes outlined in our

the United States, please note that your information may be transferred to a location that

does not have similar data protection regulations. By using our services, you consent to the

transfer of your information to the U.S. or any other country where FATEFULL MOMENT or its

affiliates maintain facilities, as well as the use and disclosure of your information as described

in our Privacy Policy.

B. Data Security

To ensure the safety of your Personal Information, we employ technical, physical, and

organizational security measures that guard against unauthorized access, loss, and misuse.

Our most infrastructure is built on our cloud provider’s services. We also conduct routine

monitoring of our systems to detect and address potential security threats. However, as

electronic communications and information processing technology are not entirely infallible,

we cannot guarantee the complete safety and security of any data transmitted to us via the

Internet or stored on our systems. Despite the implementation of our physical, technical, and

organizational safeguards, there remains the possibility that Personal Information be

accessed, altered, or destroyed by others. In the event of a security breach resulting in

compromised Personal Information, we will comply with applicable laws by promptly notifying

our users. Here some of security measures we take with respect to user data: Separate testing

vs. production environments, Internal access control procedures (e.g., access limited to

personnel with strict need-to-know and valid login credentials, password management

procedures, etc.).

10. Data Retention: How long we keep your personal data

We will hold your personal data on our systems only for as long as required to provide you

with the services you have requested or to perform the purpose for which that data was

collected.

You may request that we update, correct, or delete information about you at any time by

emailing us at legal@edicontech.com, but note that we may retain certain information as

required by law or for legitimate business purposes. We may also retain cached or archived

copies of information about you for a certain period.

Most device browsers are set to accept cookies by default. If you prefer, you can usually

choose to set your device browser to remove or reject browser cookies. Please note that if

you choose to remove or reject cookies, this could affect the availability and functionality of

certain features of our Services.

With your consent, we may send push notifications or alerts to your mobile device to provide

App-related information, service updates, and other related messages. You can deactivate

these notifications by changing your notification settings on your device.

In some circumstances you can ask us to delete your data: see "Your Rights" below for further

information.

In some circumstances we may anonymize your personal data (so that it can no longer be

associated with you) for research or statistical purposes, in which case we may use this data

indefinitely without further notice to you.

11. Your rights

You have certain rights in relation to your Personal Information. If you would like further

information in relation to these or would like to exercise any of them, please contact us via

email at legal@edicontech.com at any time. You have the following rights:

 Right of access.

 Right to update your information.

 Right to delete your information.

 Right to restrict use of your information.

 Right to data portability.

 Right to object.

We will consider all such requests and provide our response within a reasonable period (and

in any event within 2 weeks after receiving your request unless we tell you we are entitled to

a longer period under applicable law). Please note, however, that certain Personal Information

may be exempt from such requests in certain circumstances, for example if we need to keep

using the information to comply with our own legal obligations or to establish, exercise or

defend legal claims.

12. Children’s Privacy and Parental Controls

FATEFULL MOMENT is designed for use by both adults and children. Where required by

applicable law, we obtain verifiable parental consent before collecting or processing Personal

Information from children under the age of 13.

Parents or legal guardians may review, update, or request deletion of their child’s account

information and may manage parental controls, as applicable. Parents may also receive

account-related information and usage insights related to their child’s use of the Services. To

exercise parental rights or make changes to a child’s account, please contact us at

[legal@edicontech.com].

13. Privacy Policy Changes and Updates

We may periodically update this Privacy Policy, so it's important to check in FATEFULL

MOMENT app regularly. The date of the latest version is always displayed at the top of this

page.

If we make changes, we will notify you by publishing the date we made any change at the top

of the policy and, depending on the significant changes, we will provide you with a prominent

notice on this website or in the app before the changes take effect. If any of these changes

affect the data we've collected from you in a less protective way and if required by law, we

will seek your parent's renewed consent (e.g. by adding a statement to our website’s

homepage or sending you a push notification).

14. Further questions and how to make a complaint

If you have any questions or complaints about our collection, use or storage of your Personal

Information, or if you wish to exercise any of your rights in relation to your Personal

Information, please contact legal@edicontech.com . We will investigate and attempt to

resolve any such complaint or dispute regarding the use or disclosure of your Personal

Information.