Cookie Policy

1. Introduction

This Cookie Policy ("Policy") explains how EDROIDA GÖRSEL TEKNOLOJİ HİZMETLERİ LTD. ŞTİ. ("we", "our", "us") uses cookies, tracking technologies, and similar mechanisms in connection with the Othermy mobile application and its associated website (www.othermy.com) (collectively, the "Platform").

This Policy should be read together with our Privacy Policy and Terms of Use. By using our Platform, you agree that cookies may be placed on your device in accordance with this Policy. You can modify or withdraw consent at any time through your device or browser settings.

2. What Are Cookies?

Cookies are small text files stored on your device by websites or mobile applications to recognize you and remember your preferences. They allow us to personalize your experience, analyze performance, enhance security, and provide AI-driven features that rely on contextual data.

Cookies can be:

• Session cookies: Expire when you close the app or browser
• Persistent cookies: Remain stored until deleted manually or automatically

In addition to cookies, we also use web beacons, SDKs, and local storage for similar purposes.

3. Types of Cookies We Use

3.a Essential Cookies

Required for the basic operation of the Othermy App, such as user authentication, security, and core functionality. Without these, the app cannot function properly.

Examples: Firebase Authentication Token, Secure session identifiers, CSRF protection tokens

3.b Performance & Analytics Cookies

Help us understand how users interact with the app and website. We use Firebase Analytics and Google Cloud Monitoring to track crashes, performance bottlenecks, and usage trends.

Collected data may include: App version, OS version, device type, user interaction events, error and crash logs

3.c Functional Cookies

Enable advanced personalization, such as remembering preferred language, theme, and session settings. Used for smoother user experience across devices.

Examples: Preferred app language, "Keep me signed in" preference, Accessibility settings

3.d Advertising & Marketing Cookies

Used only on our website, not in the app. These cookies help us analyze marketing campaign effectiveness and understand referral sources (Google Ads, Meta Pixel). We do not serve targeted ads within the Othermy App.

3.e AI-Interaction Cookies

Specific to the Othermy AI system, these cookies temporarily store conversational context and AI interaction preferences. This helps maintain continuity when creating your digital AI copy and ensures smoother dialogue flow. All such data is encrypted and stored securely within your user session.

4. Third-Party Cookies & SDKs

We integrate third-party tools that may use cookies or SDK-based tracking to improve performance and ensure functionality:

All third-party partners comply with GDPR, CCPA, and EU–US Data Privacy Framework.

5. How We Use Cookies

We use cookies and tracking technologies to:

1. Maintain secure login sessions
2. Personalize the AI and app experience
3. Measure performance and user engagement
4. Detect and prevent fraud or misuse
5. Comply with data protection and AI transparency laws

No cookie data is ever sold or rented. Aggregated analytics may be used to improve algorithms and app quality.

6. Managing Cookie Preferences

In-App

• Go to Settings → Privacy & Cookies
• Disable Analytics or AI Personalization cookies
• Essential cookies cannot be disabled (required for core functionality)

On the Website

• Adjust preferences through the cookie consent banner
• Withdraw consent anytime by clearing browser cookies

In Your Browser

• Chrome: chrome://settings/cookies
• Safari: Preferences → Privacy
• Firefox: Options → Privacy & Security
• Edge: Settings → Site Permissions → Cookies and Data Stored

Note: If you disable all cookies, some app features (like login persistence or AI memory) may not work as intended.

7. Data Retention & Expiration

Expired cookies are automatically deleted. You may also manually delete cookies at any time.

8. Legal Basis for Cookie Usage

Under GDPR (Art. 6):

• Consent: for analytics, personalization, and marketing cookies
• Legitimate interest: for essential security and authentication cookies

We always seek explicit consent before setting non-essential cookies.

Under CCPA: Cookies may be considered "personal information." You have the right to opt out of any data sale or sharing under California law.

Under the EU Artificial Intelligence Act: Cookies that influence AI model behavior or personalization are clearly disclosed and fully user-controlled.

9. AI Contextual Data Storage

As Othermy builds your digital persona, temporary contextual cookies help maintain conversation continuity between AI sessions. These are short-lived, encrypted, and automatically deleted after session termination.

We never use cookie data for AI model training or third-party analytics.

10. Children's Privacy

Our cookies are not designed to track or profile users under 16. If you believe a minor has been tracked inadvertently, please contact privacy@othermy.com for immediate removal.

11. International Data Transfers

Data collected through cookies may be processed in:

• Turkey (primary operations)
• European Union (Google Cloud)
• United States (OpenAI API endpoints)

All transfers follow Standard Contractual Clauses (SCCs) and adequacy decisions under EU and US frameworks.

12. Your Rights

You have the right to:

• Access cookie-related data
• Request deletion or anonymization
• Object to tracking
• Withdraw consent anytime

Requests: privacy@othermy.com
Response time: within 30 days (GDPR standard)

13. Security of Cookie Data

We apply multiple layers of protection:

• AES-256 encryption for sensitive session cookies
• HTTPS/TLS 1.3 for transmission
• Secure, HttpOnly, and SameSite flags enabled

We conduct regular vulnerability scans and comply with OWASP Mobile Security Guidelines.

14. Updates to This Policy

We may update this Cookie Policy periodically to comply with new AI, privacy, or data protection laws. Major changes will be communicated via:

• Email notification (if consented)
• In-app alert
• www.othermy.com/cookies