Terms of Use | Routine AI

ROUTINE AI TERMS OF USE AND PRIVACY AGREEMENT

Date of Last Update: 19.04.2026

Data Controller: Eylul Erbil (Routine AI)* *

Welcome to the Routine AI application. By downloading, creating an account and using our application, you declare that you have read, understood and accepted all the terms below by confirming them in an electronic environment. This text regulates the fulfillment of the obligation to clarify pursuant to the Law No. 6698 on the Protection of Personal Data and the relevant legislation, as well as the legal terms to which users are subject. In accordance with the rule stated in the Decision of the Personal Data Protection Board dated 17.03.2022 and numbered 2023/134, which specifies that “the Privacy Policy is essentially a text prepared to fulfill the obligation to clarify, but is also used in place of an explicit consent text; therefore, regarding personal data processing activities carried out based on the explicit consent condition according to paragraph (f) of Article 5 of the Communiqué on the Procedures and Principles to be Followed in Fulfillment of the Obligation to Clarify, the condition that explicit consent must be fulfilled separately from the obligation to clarify is not met”, this agreement is not an explicit consent text, and separate confirmation mechanisms are presented during the registration phase for transactions requiring explicit consent.

1. MEDICAL DISCLAIMER AND LIMITS OF THE SERVICE

Routine AI is not a medical device, diagnostic tool or dermatologist. The skin care routines, product analyses and recommendations provided through the AI-powered features of the application, based on your answers to survey questions and the photos you upload, are entirely for information and cosmetic purposes. The application in no way diagnoses skin diseases, suggests medical treatment or gives recommendations of a prescriptive nature.

If you have a severe skin problem, conditions such as severe acne, eczema, rosacea, psoriasis, unexpected allergic reactions, or a specific health condition such as pregnancy or breastfeeding, you must consult a specialist physician before following the suggestions in the application. If you are using medications such as blood thinners, oral or topical isotretinoin, retinoids, birth control pills, or antibiotics, your doctor's advice regarding cosmetic product interactions is essential. Our company cannot be held responsible for any health problems arising from actions taken using Routine AI.

2. PERSONAL DATA PROCESSING AND CLARIFICATION STATEMENT

Pursuant to the Law No. 6698 on the Protection of Personal Data, our company, in its capacity as the Data Controller, processes your general data such as name, gender, date of birth, skin tone and skin type within the scope of sub-paragraph (c) of the 2nd paragraph of Article 5, based on the legal ground of the performance of the contract.

In the event that you upload health data to our application, such as pregnancy status, breastfeeding status, medications used, skin conditions and allergen sensitivities, as well as your facial photos, these data are in the status of private personal data within the scope of Article 6 of Law No. 6698. In light of the finding highlighted in the Decision of the Personal Data Protection Board dated 29.06.2022 and numbered 2022/630, which states “In the image containing the pre- and post-operative nose visuals, the eyes of the data subject were covered using visual characters, however, the visual content did not consist solely of the nose, and parts of the face such as eyebrows, mustache, etc., that could identify the data subject were clearly included and not anonymized”, the facial photos you upload to the application are accepted as biometric data and personal data to the extent that they make your identity identifiable.

These private data are processed only as a result of the active consent you provide with your specific and free will, in line with the principle expressed in the Decision of the Personal Data Protection Board dated 27.02.2020 and numbered 2020/173, which defines explicit consent in “sub-paragraph (a) of the 1st paragraph of Article 3 of the Law titled Definitions as: consent regarding a specific subject, based on information and declared with free will”. Uploading a facial photo is entirely optional, and our users who do not upload a photo may continue to benefit from the service through survey questions.

3. TRANSFER OF DATA ABROAD AND USE OF THIRD-PARTY ARTIFICIAL INTELLIGENCE

Routine AI utilizes externally provided artificial intelligence large language models and hosts its database on servers located in Frankfurt, Germany, in order to offer users the best skin analysis.

Pursuant to the Decision of the Personal Data Protection Board dated 17.03.2022 and numbered 2022/249, it is accepted that “the transfer of personal data abroad is no different from other personal data processing activities such as modification, reorganization, recording, storage and preservation”, and the same decision states that in Article 9 of Law No. 6698, “it is stipulated in paragraph (1) that personal data cannot be transferred abroad without the explicit consent of the data subject”. In accordance with these mandatory provisions, the transfer of your health data and photos to servers abroad and to external artificial intelligence service providers is only carried out if you check the separate confirmation box regarding international transfer presented during the registration phase.

4. DATA SECURITY, RETENTION PERIOD AND DESTRUCTION POLICY

Our company is obliged to ensure data security within the scope of Article 12 of Law No. 6698. The rule specified in the Decision of the Personal Data Protection Board dated 25.03.2021 and numbered 2021/311, stating “...it is necessary to accurately determine the probability of risks occurring in relation to the protection of this data and the losses they would cause if they occur, and to take appropriate measures”, as well as the obligations in the Decision dated 16.06.2020 and numbered 2020/463 regarding “regularly checking security software messages, access control records and other reporting tools, taking action upon warnings from these systems, and regularly conducting vulnerability scans and penetration tests to protect information systems against known vulnerabilities”, are strictly fulfilled by our company.

Furthermore, in line with the precedent emphasized in the judgment of the Istanbul 4th Civil Court of First Instance dated 14.06.2023, Docket No. 2022/100 and Decision No. 2023/534, which states “Conducting penetration tests at certain intervals is among the administrative and technical measures that must be taken at the point of preventing unauthorized access to personal data and ensuring its secure preservation”, our systems are subjected to regular security tests and your data is stored encrypted with cryptographic methods. Since it is stated in the Decision of the Personal Data Protection Board dated 24.08.2023 and numbered 2023/1465 that “making personal data accessible is a personal data processing activity according to paragraph (e) of Article 3 of the Law, access controls against algorithmic errors are strictly audited.

Your data will be stored as long as your account is active. Pursuant to Article 7 of Law No. 6698, as reminded in the Decision of the Personal Data Protection Board dated 18.05.2022 and numbered 2022/491, “in the event that the reasons requiring its processing cease to exist, personal data shall be deleted, destroyed or anonymized by the data controller ex officio or upon the request of the data subject”. When you delete your account, with the exception of our legal retention obligations, all your photos and health data will be destroyed immediately.

5. DATA SHARING WITH JUDICIAL AUTHORITIES

As a rule, data belonging to our users is not shared with third parties. However, in the event of a duly submitted request from official judicial authorities, legal obligations will be fulfilled within the framework of the provisions of the Code of Civil Procedure No. 6100 and the Code of Criminal Procedure No. 5271, pursuant to the principle stated in the Decision of the Personal Data Protection Board dated 14.09.2023 and numbered 2023/1578 that “it is necessary to respond even if the documents requested in the court writ contain data regarding health and sexual life; pursuant to sub-paragraph (b) of the 2nd paragraph of Article 8 of the Law, personal data may be transferred without seeking the explicit consent of the data subject provided that adequate precautions are taken”, and the rule in the same decision regarding the “applicability of the provision in sub-paragraph (d) of the 1st paragraph of Article 28 of the Law which states 'Processing of personal data by judicial authorities or execution authorities in relation to investigation, prosecution, judicial or execution proceedings'.".

6. DATA PORTABILITY AND COMPETITION LAW COMPLIANCE

Our company respects the users' right of ownership over their own data and the fundamental principles of competition law. The standard mandated for a platform within the scope of the data portability obligation in the Decision of the Competition Board dated 20.12.2024 and numbered 24-54/1224-522, which states “to establish the infrastructure that will enable corporate members to effectively port the real estate and vehicle advertisement data they enter into the SAHIBINDEN platform to competing platforms and to keep the data contained in these advertisements up to date, without requesting any fee”, has been adopted by Routine AI in favor of individual users. Upon your request, the skin care routines and data you have entered into the application will be provided to you free of charge in a machine-readable standard format to enable you to port them to other platforms.

7. INTELLECTUAL PROPERTY, SUI GENERIS DATABASE AND UNFAIR COMPETITION

The design, source codes, algorithms and original text contents of the Routine AI application belong to our company. The database formed as a result of the cosmetic product details and routines entered into the application by users has been created through the significant effort and investment of our company. As stated in the judgment of the Bakirkoy 2nd Civil Court of First Instance dated 17.10.2025, Docket No. 2023/940 and Decision No. 2025/971, it is clear that “the said data has acquired the nature of a sui generis database by being processed by the plaintiff in a structured systematic order with technical contributions such as filtering and category creation”. In accordance with the rule emphasized in the same court decision, which states “even if the advertisement contents are entered by individuals, the way the platform processes and presents the relevant data, its classification, and investments regarding user experience require said contents to be accepted as a work product within the scope of commercial activity”, the Routine AI database is under legal protection.

It is strictly prohibited for third parties or competing firms to extract data from our application without permission. Actions characterized as unfair competition in the aforementioned decision of the Bakirkoy 2nd Civil Court of First Instance, such as “Web Scraping, the computer program technique of extracting information from websites, collecting data from the plaintiff's real estate site without consent by using different IP addresses each time despite two warning letters sent through a notary and the blocking of IP addresses”, will constitute unfair competition pursuant to sub-paragraph (c) of the 1st paragraph of Article 55 of the Turkish Commercial Code No. 6102, and legal action will be initiated immediately in case of violation.

Product names and ingredient details belonging to third-party cosmetic brands within the application are used strictly for the purpose of informing the consumer within the framework of fair use under the Law No. 5846 on Intellectual and Artistic Works and the Industrial Property Code No. 6769.

8. SUBSCRIPTION, PAYMENTS AND CANCELLATION TERMS

Routine AI offers paid subscription options that provide additional features to users. Payments are collected through the app store account linked to your device upon confirmation of the purchase transaction. Your subscription will automatically renew unless the auto-renew feature is turned off at least 24 hours before the end of the current subscription period. Cancellation and refund processes are directly subject to the policies of the respective app stores. Deleting the application from the device does not automatically cancel the subscription.

9. USER RIGHTS AND CONTACT

Pursuant to Article 11 of the Law No. 6698 on the Protection of Personal Data, you have the right to access, correct, delete, and request the portability of your data. Your requests will be finalized free of charge within thirty days at the latest within the scope of the relevant legislation. For any requests regarding this agreement or your personal data, you can contact us via our support e-mail address. In legal disputes, Turkish Law shall apply, and the courts and enforcement offices of the location where the company headquarters is situated shall have jurisdiction.