GDPR Policy

This policy provides additional information and rights under the General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA), the United Kingdom, and Switzerland. For general information, the Privacy Policy applies.

What is the EEA? The European Economic Area consists of the 27 European Union member states plus Iceland, Liechtenstein, and Norway. The GDPR applies throughout this area. References to "EEA" in this policy mean this group of countries.

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1. Data Controller

Ramazan Sancar and Batınay Ünsel (jointly). Contact: <[email protected]>. An EU representative, if required, will be designated here: [EU REPRESENTATIVE / IF REQUIRED].

2. Legal Bases (Art. 6)

• Contract (b): account and service provision.
• Legitimate interest (f): security, abuse prevention, service improvement.
• Legal obligation (c): recordkeeping, responding to requests.
• Consent (a): adult content, marketing, optional analytics/cookies.

3. Your Rights (Arts. 15–22)

• Access, rectification, erasure ("right to be forgotten"), restriction, data portability, objection, and the right not to be subject to solely automated decisions.
• Right to withdraw consent for consent-based processing (without retroactive effect).

Requests are fulfilled free of charge within one month (extendable for complex cases). Contact: <[email protected]>.

4. Hosting and International Transfers (Chapter V)

Your data is primarily hosted in Germany (Hetzner, Nuremberg — within the EEA), which is advantageous for EEA users (data stays in the EU). Some providers (e.g., Apple, Google, Sentry) may transfer data outside the EEA; such transfers rely on appropriate safeguards (Standard Contractual Clauses / adequacy decisions) or explicit consent.

5. Retention

Data is kept only as long as necessary. See Privacy Policy §8.

6. Automated Decision-Making

We do not make solely automated decisions producing legal effects. Automated checks such as moderation and the age gate are subject to human review.

7. Children's Data (Art. 8)

The minimum age to use the App is 13. Under GDPR Art. 8, the age at which a child's consent alone is valid for information society services varies by member state between 13 and 16. If you are below that threshold in your country, processing based on consent (optional analytics and marketing) requires parental/guardian authorization; in that case we disable the relevant features or seek verifiable parental consent.

If we identify data belonging to a user below the applicable threshold, we delete the account and the data. If you believe a child has shared data this way, contact <[email protected]>.

8. United Kingdom and Switzerland

• United Kingdom: this policy also applies for the purposes of the UK GDPR and the Data Protection Act 2018. You may complain to the Information Commissioner's Office (ICO) — ico.org.uk. Under the UK GDPR, the age of a child's consent is 13.
• Switzerland: your rights under the revised Federal Act on Data Protection (revFADP/nLPD) are substantially the same as those described here. The supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC) — edoeb.admin.ch.

Where a representative in the EU or the UK is required, the details will be published in this section.

9. Data Protection Officer (DPO)

We assess that we do not meet the conditions for a mandatory DPO under GDPR Art. 37 (being a public authority, large-scale regular and systematic monitoring, or large-scale processing of special category data), and therefore no DPO has been appointed. Data protection questions are handled at <[email protected]> and <[email protected]>. If circumstances change, we will appoint a DPO and update this policy.

10. Complaints and Judicial Remedies

You have the right to lodge a complaint with the data protection supervisory authority of the EU member state where you reside, where you work, or where the alleged infringement took place (Art. 77). A list of authorities is available at edpb.europa.eu. Your rights to an effective judicial remedy (Art. 79) and to compensation (Art. 82) are also reserved.

11. Contact

<[email protected]> — <[email protected]>