Privacy Policy

This Privacy Policy explains how TIER2 GLOBAL MARKETING SOLUTIONS AND CONSULTANCY FZCO (“we”, “us”) collects and uses personal data when you use Doctorfinetuner (the “Service”). We are the controller of the personal data described here. If you are in Türkiye, our KVKK Notice gives this information in Turkish.

1. Who we are

TIER2 GLOBAL MARKETING SOLUTIONS AND CONSULTANCY FZCO is a free zone company registered with the International Free Zone Authority (IFZA), with its registered address at Building A1, Dubai Digital Park, Dubai Silicon Oasis (DSO), Dubai, United Arab Emirates. You can contact us about privacy at [email protected].

2. Personal data in your documents

Documents you upload may contain personal data about you or other people. For that data, you decide what to upload and why, and we process it on your behalf only to provide the Service, as described in section 10 of our Terms of Service. Please do not upload the types of sensitive data listed in section 4 of the Terms.

3. Personal data we collect

• Account data: your email address and name. If you sign up with email, your password, which our sign-in provider stores only in hashed form. If you sign in with Google, the name, email address and profile picture link that Google shares with us. We also record when your account was approved and when you accepted our Terms and this Policy.
• Your content: the text extracted from the documents you upload (we do not keep the original file), the project name and goal you enter, the passages cut from your document, and the summaries, examples and datasets generated for you.
• Usage and credit data: your credit balance and transactions, the runs you start, the model you choose, run status and timing, and the number of tokens processed.
• Technical data: IP address, browser and device information, and logs of requests and errors that our hosting and sign-in providers record when you use the Service.
• Communications: messages you send us, for example by email.

4. How we use personal data

We use personal data for the purposes below. Where the EU or UK General Data Protection Regulation applies, the legal basis is shown for each purpose.

• To create and run your account and provide the Service, including processing your documents and generating datasets — performance of our contract with you.
• To run early access, including reviewing and approving accounts and adding credits — performance of our contract with you and our legitimate interest in opening the Service in stages.
• To keep the Service secure, prevent abuse and enforce our Terms — our legitimate interests.
• To find and fix problems and make the Service more reliable, using usage and technical data — our legitimate interests. We do not read your documents for this unless you ask us to look into a specific run.
• To answer your requests and tell you about your account and about changes to the Service, our Terms or this Policy — performance of our contract with you and our legitimate interests.
• To keep records and meet legal obligations, for example under accounting and tax rules — compliance with legal obligations.

We do not sell personal data, we do not use it for advertising, and we do not use your documents or generated datasets to train AI models.

5. Service providers

We use the following providers to run the Service. They process personal data on our behalf under their data protection terms.

• Supabase — database, user sign-in and account emails. European Union (Frankfurt, Germany).
• Vercel — website hosting and application servers. United States.
• Inngest — background job processing. While a run is processed, the text of your document, its passages and the generated examples pass through Inngest and are kept there for a limited period. United States.
• Google — the Gemini models that generate datasets, and Google sign-in if you use it. United States and other countries where Google operates. Google does not use content sent through its paid Gemini API to improve its products, and keeps it only for a limited period to detect abuse.

We may also share personal data with our professional advisers, with authorities where the law requires it, and with a buyer or successor if our business is reorganized or sold.

6. International transfers

We are based in the United Arab Emirates, and our providers store and process data in the European Union, the United States and other countries. These countries may not offer the same level of protection as the country where you live. Where the law requires it, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, where our providers offer them.

7. How long we keep data

• Document text and passages: deleted 30 days after the run.
• Generated examples, datasets, run summaries and project details: kept until you ask us to delete them or close your account.
• Account data: kept while your account is open and deleted within 30 days after you ask us to close it.
• Credit transactions and other records we must keep by law: kept for as long as the law requires, for example for accounting and tax purposes.
• Logs and backups: kept by our providers for a limited period and then deleted.

The periods above apply to the current version of the Service. If you used an earlier version of Doctorfinetuner, data from that version remains in our systems and is covered by this Policy; you can ask us to delete it at any time. Records of paid processing from that version are kept for accounting and dispute purposes.

8. Security

We use encrypted connections, access controls and providers that encrypt stored data. Only people who need access to run and support the Service can access your data. No system is completely secure, so we cannot guarantee absolute security.

9. Your rights

Depending on where you live, you may have the right to access your personal data and get a copy of it, to correct it, to delete it, to restrict or object to certain processing, to receive it in a portable format, and to withdraw consent where we rely on consent. To use these rights, email [email protected] from the address linked to your account. We reply within 30 days and may need to confirm your identity first.

You can also complain to a data protection authority: in the European Union, the authority in your country; in the United Kingdom, the Information Commissioner’s Office; in the United Arab Emirates, the UAE Data Office; in Türkiye, the Personal Data Protection Board (see our KVKK Notice).

10. Cookies and similar technologies

We use only the cookies needed to keep you signed in. Your light or dark theme choice is stored in your browser. We do not use analytics or advertising cookies.

11. Children

The Service is not for anyone under 18, and we do not knowingly collect personal data about children.

12. Changes to this Policy

We will update this Policy when our practices change and show the date of the latest version at the top. If a change is significant, we will ask you to review it before you continue to use the Service.

13. Contact

TIER2 GLOBAL MARKETING SOLUTIONS AND CONSULTANCY FZCO
Building A1, Dubai Digital Park, Dubai Silicon Oasis (DSO), Dubai, United Arab Emirates
[email protected]