Last updated: [Effective Date]
This Privacy Policy explains how [Company Legal Name] ("Appory", "we", "us") collects, uses, shares, and protects personal data when you visit our website, create an account, or use our applications and services (together, the "Services"). We are committed to handling your data in line with the EU General Data Protection Regulation ("GDPR") and Turkey's Law on the Protection of Personal Data No. 6698 ("KVKK").
The data controller is [Company Legal Name], located at [Company Address]. You can reach us about any privacy matter at info@appory.app. Where required, our representative or Data Protection Officer can be contacted at the same address.
This policy applies to personal data we process about visitors, account holders, subscribers, and people who contact us. It does not cover third-party websites or services that we link to but do not operate.
Under the GDPR we rely on: performance of a contract (to deliver the Services you sign up for), consent (for optional marketing and non-essential cookies, which you may withdraw at any time), legitimate interests (to secure and improve our Services), and legal obligation (to meet our statutory duties). Under the KVKK we process data on the corresponding bases set out in Articles 5 and 6, including your explicit consent where required.
Our products are generally built using artificial intelligence. Some features may process your inputs through our own or third-party AI models to generate results. We aim to use the minimum data necessary, apply appropriate safeguards, and do not sell your personal data. Where a feature would use your content to improve or train models beyond providing the feature itself, we will tell you and, where required, ask for your consent. AI outputs can be imperfect and should not be relied on as professional advice.
We share personal data only as needed with: service providers (such as hosting, analytics, and customer-support tools) acting under contract on our behalf; app stores and payment processors for purchases; and authorities or other parties where required by law or to protect rights and safety. We may also share data in connection with a merger, acquisition, or asset sale, subject to this policy.
Your data may be processed outside your country, including outside Turkey or the European Economic Area. Where we transfer data internationally, we use appropriate safeguards such as the European Commission's Standard Contractual Clauses and equivalent KVKK mechanisms, and obtain your explicit consent where required.
We keep personal data only as long as necessary for the purposes described here, to comply with legal obligations, resolve disputes, and enforce agreements. When data is no longer needed, we delete or anonymise it.
Subject to applicable law, you have the right to access, rectify, erase, restrict, or object to the processing of your personal data, to data portability, and to withdraw consent at any time. Under the KVKK (Article 11) you may also learn whether your data is processed and request that inaccurate data be corrected. To exercise any right, contact us at info@appory.app. You also have the right to lodge a complaint with a supervisory authority, the Turkish Data Protection Authority (KVKK Kurumu) or your local EU data protection authority.
The Services are not directed to children under [13/16, per your market], and we do not knowingly collect their personal data. If you believe a child has provided us data, contact us and we will take appropriate steps to delete it.
We use technical and organisational measures designed to protect personal data against unauthorised access, loss, or misuse. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
We may update this policy from time to time. We will post the updated version here and revise the "Last updated" date, and where changes are material we will provide additional notice.
For any question about this policy or your personal data, contact [Company Legal Name] at info@appory.app or [Company Address].