KVKK Notice

1. Data controller

Under the Turkish Personal Data Protection Law No. 6698 (“KVKK”), your personal data is processed by the data controller within the scope described below.

Data controller: Zekeriya Bilgin (publisher of the Word Cards app). Address: Belen / Hatay, Türkiye. Contact: support@wordcards.app

2. Categories of personal data processed

• Identity: name / display name, user ID
• Contact: email address
• Customer transaction: subscription status, purchase/receipt data, store transaction references
• In-app user activity: learning progress, quiz results, custom lists, favorites, preferences and settings
• Usage/analytics: in-app event and usage statistics, error and performance data (Firebase Analytics and related services)
• Advertising/marketing transaction security: when AdMob is enabled, advertising identifiers, ad interactions, consent preferences, and fraud-prevention signals
• Transaction security: device identifier, device/app technical information, logs, IP address
• Notifications: local notification preferences; Expo/APNs/FCM notification token when remote push is enabled

3. Purposes of processing

• Membership/account creation and authentication
• Providing, maintaining, personalizing, and backing up the service
• Running subscription processes, purchase verification, and premium entitlement
• Ad delivery, ad measurement, consent enforcement, and ad-fraud prevention
• Analytics, performance measurement, debugging, and product improvement
• Information security, abuse prevention, and legal rights protection
• Fulfilling legal obligations

4. Legal grounds for processing

Your personal data is processed under Article 5 of the KVKK on the grounds that processing is necessary for the establishment or performance of a contract, compliance with a legal obligation, establishment/exercise/protection of a right, legitimate interest provided it does not harm your fundamental rights and freedoms, and where required, your explicit consent. Advertising personalization, tracking, or non-essential local storage are handled through consent or valid preference mechanisms in relevant regions.

5. Method of collection

Your personal data is collected electronically through automated and partly automated methods when you register, use the app, complete store/subscription transactions, and through notification, advertising, and analytics SDKs.

6. Transfer of personal data (KVKK Art. 8-9)

To provide the service, your data is shared on a limited basis with domestic/international service providers: Supabase (authentication, data storage, and backup — European Union), Apple and Google (store payments and sign-in), RevenueCat (subscription verification), Google Firebase (analytics, performance, and future notification infrastructure), Google AdMob / Google Mobile Ads (ad delivery and measurement), Cloudflare (website analytics). Sharing with public authorities and legal advisers occurs only for legal obligations, disputes, or rights protection. International transfers are handled under KVKK, applicable legislation, and provider protection mechanisms.

7. Retention period

Personal data is retained for as long as the processing purpose requires. Account and learning data are retained while the account is active. After an account deletion request, personal data is deleted, destroyed, or anonymized within 30 days at the latest. Limited records required for tax, accounting, store/platform audit, payment disputes, security, fraud prevention, or legal claims are retained only for the period required by law or the legitimate purpose.

8. Your rights as a data subject (KVKK Art. 11)

• Learn whether your personal data is processed
• Request information if it has been processed
• Learn the purpose of processing and whether it is used accordingly
• Know the third parties to whom it is transferred at home or abroad
• Request correction if it is incomplete or inaccurate
• Request its deletion or destruction
• Request that correction/deletion be notified to third parties it was transferred to
• Object to a result against you arising solely from automated analysis
• Claim compensation for damage due to unlawful processing

9. How to apply

To exercise the rights above, send your requests to support@wordcards.app. Your application will be concluded as soon as possible and within 30 days at the latest, in accordance with Article 13 of the KVKK.