The controller within the meaning of Law 6698 and the GDPR for the processing of personal information is:
Appstun Digital Solutions, Batuhan Karababa,
If you have any questions about the processing of your personal information, as well as your rights regarding data protection, please contact us.
“Personal information” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Legal bases for processing
The processing of your personal information may be based on the following legal grounds:
– consent serves as our legal basis for processing operations where we obtain your consent for a specific processing purpose. • contract, insofar as the processing of personal information is necessary for the performance of a contract, e.g., if you use the App. The same applies to such processing operations that are necessary for the performance of pre-contractual measures, for example in the case of enquiries about the App. • legal obligation, insofar as we are subject to a legal obligation that requires the processing of personal information, such as for the fulfillment of tax obligations. • legitimate interest, applies on the basis of our legitimate interests, e.g., when using service providers as part of the App. Our interest is directed towards the use of a user-friendly, appealing, and secure presentation as well as optimization of the App, which serves our business interests as well as meeting your expectations.
What are your rights?
You have the following rights:
– Right of access • Right to rectification • Right to restriction of processing • Right to erasure • Right to information • Right to data portability • Right to object • Right of withdrawal
To assert these rights, please contact us at any time using the details provided.
Exercising Your Privacy Rights
To exercise your rights, please contact us. In accordance with Law 6698 and the GDPR, we will need to confirm your identity to process your requests and we may require you to provide information associated with your account or transactions with us, or to provide government identification, signed declarations and other proof of identity.
Accuracy and updating your information
If you believe that the personal information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing or withdraw your consent, please contact us.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer your requests. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of Personal information, notably where such requests would not allow us to provide our service to you anymore.
When you send a data subject access request
The legal basis for the processing of your personal information in the context of handling your data subject access request is our legal obligation and the legal basis for the subsequent documentation of the data subject access request is both our legitimate interest and our legal obligation.
Collection of Personal information
Personal information may be collected in two ways, that is directly when you for example volunteer it to us or automatically for example when you install and use our App. As indicated above we have made sure that as little as possible information that directly identifies you is collected.
a) Using the App
b) When you contact us
If you contact us, your transmitted personal information will be automatically stored for the purpose of processing the request or contacting you. We delete the data accruing in this context after the storage is no longer necessary for the processing of your request or restrict the processing if there are legal retention obligations. The legal basis for processing is our legitimate interest and/ or a contractual or precontractual measure.
Automatically collected data
a) Downloading the App
The App can be downloaded from the Apple App service “App Store” a service of Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, US. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.
b) Installing the App
As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. We cannot influence which personal data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.
c) Starting the App
Every time you start the App, your data is synchronized, and your device communicates with our server through a signed token. The transmission takes place automatically and is a prerequisite for the secure functioning of the App and is therefore mandatory.
d) Device information
We or rather Apple on our behalf collects information from and about the device(s) you use to access the App, including hardware and software information such as IP address, device ID and type, device-specific and App settings and properties, App crashes, advertising IDs (AAID).
Our App uses the analysis service Mixpanel, a service of Mixpanel Inc, to help us improve our service, Mixpanel logs page views and App activity. You can also stop the analysis of data about your activity with the so-called “opt out cookie”, which you can activate at http://mixpanel.com/optout/. Please note that we, have no influence on the further use of your data by Mixpanel Inc.
The APP uses the Firebase Realtime Database and Messaging tools, which is part of the Firebase APP of Google Inc. By integrating Google services, Google may collect and process information (including personal data). It cannot be excluded that Google also transfers the information to a server in a third country. We cannot influence which data Google actually collects and processes. However, Google states that, among other things, the following information (including personal data) may be processed in principle: Log data (in particular the IP address, Location-based information, Unique application numbers, Cookies and similar technologies for information on the types of cookies used by Google, please visit https://policies.google.com/technologies/types.
For the management and analysis of in-app purchases, the App uses the product RevenueCat from Revenue Cat, Inc. You consent to the collection of data by the App and its transmission to RevenueCat. If the storage of the provided data by the third-party provider is not desired, the use of the App is to be refrained from.
The APP uses the Twilio cloud-based communication service to manage your communications according to your requirements. By integrating Twilio services, Twilio may collect and process information (including personal data). It cannot be excluded that Twilio also transfers the information to a server in a third country. We cannot influence which data Twilio actually collects and processes.
i) Authorizations and access
We may request access or permission from your mobile device for certain features (internet, microphone usage and push notifications). The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can change your permissions at any time via the settings menu of your device.
j) Push messages
When you use the app, you will receive so-called push messages from us, even if you are not currently using the App. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device.
How we use information?
The main reason we use your data is to deliver and improve our services as follows:
– to provide our App to you, • provide you with customer support and respond to your requests, • to improve our App and develop new features and services, • retain data related to fraudulent activities to prevent against recurrences, • to ensure legal compliance, • assist law enforcement, and • enforce or exercise our rights.
How long do we store your data?
In general, all personal information you provide using the App is stored using Twilio and Firebase and are subject to their Privacy Policies. However, when you volunteer personal information to us for example by contacting us, we keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. In practice, we delete or anonymize your data, unless:
– we must keep it to comply with applicable law, • we must keep it to evidence our compliance with applicable law, • there is an outstanding issue, claim or dispute requiring us to keep the relevant data until it is resolved, or • the data must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security.
In addition, we only store personal information for as long as it is necessary for the purposes for which it is processed or for as long as any consent you have given us has been revoked by you. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 10 years, irrespective of the processing purposes.
How do we protect your data?
We work hard to protect you from unauthorized access to or alteration, disclosure, or destruction of your personal information. As with all online technology, we take steps to secure your data, however we do not promise, and you should not expect, that your personal information will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures. We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security.
Further, databases or data sets that include Personal information may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal information may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.
How we share your data?
We may disclose your personal information to third parties:
– for the purposes of providing services that you request from us, fulfilling our obligations arising from any contracts entered into between you and us (for example, payment confirmations when you take out a subscription) in connection with your use of the App, • in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets, or • if we or substantially all of our shares or assets are acquired by a third party, in which case Personal information held by us about our customers will be one of the transferred assets.
Personal information and children
The services available on our website are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal information from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact.
Automated individual decision-making including profiling
We do not make automated decisions in individual cases, including profiling.
Because we’re always looking for new and innovative ways to improve our App, this policy may change over time.
Queries and Complaints
Any comments or queries on this policy should be directed to us using the contact details provided. If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.