Legal

Privacy Policy

Last Update: March 2026

Introduction

We respect your privacy and are committed to protecting your personal data. With this Privacy Policy (“Policy”), we explain how HubX Yazılım Hizmetleri Anonim Şirketi (“HubX”) collects and processes your information and personal data, the protection and privacy, and data security measures implemented, including your rights.

This Policy is applicable on MarketingX's app, website and social media platforms owned by MarketingX (collectively “MarketingX / Services / App”).

Your access and use of MarketingX is governed by this Privacy Policy and Terms of Use (“Terms”). The Terms apply to the definitions within this Policy and the provisions not included in this Policy. We recommend you to review the Terms of Use to be informed about the definitions, functions and features of MarketingX.

By accessing or using MarketingX, you agree to the collection and use of information and personal data in accordance with this Policy, and that you have reviewed and understood the processing of your information and personal data, including your rights. If you do not agree with the Terms or Privacy Policy, please do not use the Website, and/or the Services offered by MarketingX.

Collection of Information and Processing Purposes

We may collect the following information and personal data when you access MarketingX, or otherwise utilize (“use”) the Website, and/or the Services:

1. Personal Information and Contact Information

Name, account handle, User ID, E-mail Address.

This information is used to create a library of edited photos, create and edit photos and images, and communicate with you through or about MarketingX, updates or your requests.

2. Technical Data

IP address, logs, device type and name, operating system, type and date of subscription, account ID, page ID.

These data are processed for the purpose of ensuring the functionality of the app, crash and error detection, conducting technical analysis, carrying out the activity in accordance with the legislation and technical data security.

3. Customer Transaction

Subscription plan, billing cycle, transaction ID, invoice.

This data is processed for the purpose of determining the customer's subscription plan, providing and improving the services and membership plans. No credit card information is collected by us.

4. Images and Videos

Uploaded images and videos.

These data are processed for the sole purpose of creating, enhancing or editing creatives and UGC.

5. Marketing and Analytics Data

Cookies, analytics data, user preferences, interaction with marketing emails or ads.

These data are processed for personalized advertising, performance tracking of campaigns upon your explicit consent. Please note that you may withdraw your consent any time.

Cookies are small text files stored on a user's device that help a website or platform function properly, remember preferences, and improve the user experience. Essential cookies are strictly necessary for the operation and security of the service, such as enabling login and session management. Non-essential cookies are used only where the user has provided their explicit consent, in accordance with applicable data protection laws, and are processed solely for purposes such as analytics, performance measurement, and improving the functionality and user experience of the platform.

6. The Information Disclosed by Users

Within the scope of the data minimization principle adopted in accordance with the GDPR, MarketingX takes care not to process any data other than the above and is unnecessary for the application. Data that is not included in the app but shared through contact or other means is deemed to be disclosed by users. These are also protected within the scope of relevant legislation and adequate data protection measures. Please ensure that you upload only images and videos that belong to you or those you are authorized to use. We accept no liability otherwise.

Sharing of Information

Your personal data will not be sold, traded, or otherwise transferred to third parties for commercial purposes. Your data may be transferred for the reasons explained below:

(a) Service Providers

We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, customer service, and cloud services. This includes cloud providers (Google, CloudFlare, Amazon Web Services), data analytics providers (Facebook, Google, Appsflyer, Firebase).

(b) Business and Communication Partners

We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services. This includes service providers (Intercom, Firebase) and payment service providers (Paddle).

(c) Advertising Partners

We may share your personal information with third-party advertising partners. These third-party advertising partners may set technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g. page visited, location, time of day) upon your consent. These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as personalized advertising. This includes measurement partners (Firebase, Clarity).

(d) Analytics Partners

We may share anonymized usage logs and interaction data with analytics partners. This includes information like feature usage frequency, interaction patterns, and performance metrics. This data does not include your personal images, videos, or other user-generated content. The data is used exclusively for analytics to understand user engagement, identify areas for improvement, and enhance the functionality and performance of our application. This includes analytics partners (Google, Amazon Web Services, Firebase).

(e) Law Enforcement and Public Authorities

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Anonymized Data: We may use anonymized data for analytical purposes. Anonymized data is processed in such a way that it can no longer be attributed to a specific individual, ensuring your privacy is maintained. Please review the Data Destruction and Anonymization heading for the process.

AI Use: Users acknowledge that certain functionalities rely on AI-assisted systems and that outputs may not always be unique, accurate, or error-free. Users are solely responsible for their inputs and for ensuring that their use of the generated content complies with applicable laws and regulations, including adding a notice that the image has been generated with AI where required.

Ad Spy Feature: AdSpy utilizes Meta's public ad library data. It provides users with an integrated analysis experience regarding competitor advertising strategies by utilizing fields that are already made publicly available by Meta, such as ad copy, headlines, link descriptions, publication dates, platforms where the ads are published on social media, and estimated reach ranges. Through these data points, users can visually track which advertising creatives and messages remain active in specific markets, how long they run, on which platforms they are distributed, and how their performance and presence evolve over time. This enables marketing teams to shape their own creative strategies and advertising spending decisions based on competitor market insights, while identifying emerging trends and innovations in the industry to develop more competitive campaigns. In this process, MarketingX processes only data that has already been made publicly available on ad libraries and does not collect user data or perform any other data collection methods with any other purposes or scopes.

Storage of Information

We are committed to ensuring that your personal data is stored securely and in compliance with applicable laws and regulations.

Retention of Personal Information: We may store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Data Destruction and Anonymization: When personal data is no longer necessary or the retention period has expired, we will either securely delete or destroy the data to prevent unauthorized access or retrieval, or we will anonymize the data. Anonymization involves processing the data in such a way that it can no longer be attributed to you, ensuring that it can be used for analytical or research purposes without compromising your privacy. Once data is anonymized, it is irreversibly altered and cannot be traced back to any individual.

Data Deletion: Users may request the deletion of their personal data at any time by contacting our support team through the available contact channels. Upon verification of the request, we will take the necessary steps to delete the relevant personal data in accordance with applicable data protection laws. Please note that once the data are deleted, associated records such as account information, history, and preferences cannot be recovered. As a result, if users wish to use the app again after deletion, they will need to create a new account and start from scratch.

Security Measures

We take the security of your personal data very seriously and implement measures to ensure protection as of the General Data Protection Regulation (GDPR). Our key principles include:

Safety Measures: Personal data is processed within the company only by authorized personnel, in a way that is not publicly accessible, and verification or additional confidentiality declarations required in processing special data categories if available.
Access Controls: Access to personal data is restricted to authorized personnel only, ensuring that only those who need to access your information can do so.
Regular Security Audits: We conduct regular audits and assessments of our security practices to identify and address potential vulnerabilities.
Data Minimization: We only collect and retain personal data that is necessary for the purposes specified.
Data Storage: User data is hosted on AWS and protected through appropriate data storage and security measures. Personal data are periodically deleted in accordance with our data retention and deletion policy; however, if users wish to exercise their right to deletion at any time, they may refer to the Data Deletion section of this policy for further information.
Incident Response Plan: We have established an incident response plan to quickly address any potential data breaches or security incidents.

While we strive to maintain a secure digital environment, yet no digital environment can be fully secure, we encourage users to take their own precautions when accessing and using the app, including utilizing relevant antivirus software, implementing a secure firewall, accessing the website over a safe Wi-Fi connection, and ensuring that the device used to access the app is secure and up to date.

In the event of any potential data breach or security incident, users are encouraged to inform HubX immediately. We will analyze the situation to determine if there is a security problem and take necessary measures to mitigate any risks. Your security and privacy are our top priorities, and we are committed to maintaining adequate standards of data protection as required by relevant legislation.

Corporate Affiliates and Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of MarketingX or any of its Corporate Affiliates. Please note that Corporate Affiliate means any person or entity which directly or indirectly controls, is controlled by or is under common control with MarketingX, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Rights Under GDPR

The General Data Protection Regulation No. 2016/679 (GDPR) establishes a comprehensive framework for the protection of personal data within the European Union and the European Economic Area. Under GDPR, users have the following rights regarding their personal data as data subjects:

Right to Access: Obtain confirmation and access to personal data being processed.
Right to Rectification: Request correction of inaccurate or incomplete data.
Right to Erasure: Request deletion of personal data under certain conditions.
Right to Restrict Processing: Request limitation of data processing in specific situations.
Right to Data Portability: Receive personal data in a machine-readable format and transfer it to another controller.
Right to Object: Object to the processing of personal data, especially for direct marketing.
Rights Related to Automated Decision-Making: Not to be subject to decisions based solely on automated processing, unless certain conditions apply.

To exercise these rights, users must send an email or petition clearly stating the right they wish to enforce, along with their name and accurate contact details. A response will be provided within the legal time period.

California Residents

The California Consumer Privacy Act (CCPA) requires us to disclose the categories of Personal Information we collect, the sources from which it is collected, how it is used, and the third parties with whom it may be shared, as described above, where applicable. The rights of California residents are as explained below:

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us. Please note that we do not sell personal information of our users. For more information about these rights, please contact us.

Updates to Privacy Policy

We reserve the right to update this privacy policy at any time to reflect changes in our practices, legal obligations, or operational needs. Users are encouraged to review this policy regularly to stay informed about how we protect their personal data and to understand their rights and responsibilities. The revision date is stated in the introduction of the policy. Any updates will take effect immediately upon posting. If users do not agree with the amendments, they should discontinue using the app. Continued use of the website after such updates constitutes acceptance of the revised policy.

Contact

This privacy policy constitutes the entire understanding between you and us regarding the collection, use, and protection of your personal data. If you have any questions or concerns regarding this policy or our data practices, please contact us via support@marketingx.ai

HubX Yazılım Hizmetleri Anonim Şirketi
Çınarlı Mah. Ankara Asfaltı Cad. No:15-411 Konak/İzmir