KVKK Privacy Notice (Türkiye)

Privacy notice under Law No. 6698

SECTION 1Data controller

Under KVKK (Turkish Personal Data Protection Law No. 6698), your personal data is processed by KolekciApps LLC as the data controller, within the scope explained below.

Legal name: KolekciApps LLC — a limited liability company registered in the State of Wyoming, United States of America.
Correspondence address: Cheyenne, Wyoming, USA.
Email: destek@clickchatapp.com

KolekciApps LLC acts as a data controller not established in Türkiye; the company has no headquarters, branch or place of business in Türkiye, and your personal data is processed on servers located abroad. Since the App is offered to users in Türkiye, the provisions of Law No. 6698 apply to this activity.

Data Controllers' Registry (VERBİS) and representative in Türkiye

Law No. 6698 and the related secondary legislation set out obligations for data controllers not established in Türkiye to register with the Data Controllers' Registry (VERBİS) and to appoint a data controller representative established in Türkiye.

If VERBİS registration is completed and a data controller representative is appointed in Türkiye for our company, the representative's name, address and contact details together with the registry record information will be added to this notice and published, and will become publicly available through VERBİS. As long as this information does not appear in this notice, the relevant registration and appointment have not been completed.

Until this information is published, you may send all applications and requests under Law No. 6698 to the email address below; your applications are assessed in accordance with the procedure explained in Section 9 of this notice.

SECTION 2Personal data processed and collection method

Your personal data is collected electronically through the App by automated means. The main categories of data processed:

• Identity data — name, age/year of birth, gender.
• Contact data — email address, in-app message content.
• Location data — location obtained with device permission and the city you select.
• Visual and audio data — profile photos, Stories, voice messages.
• Customer transaction data — coins balance, purchase and subscription records.
• Transaction security data — IP address, device and app version, session records, notification identifier.

SECTION 3Purposes of processing

• Creating the membership record and managing the account.
• Providing the match, Discover, chat, Stories, Feed and voice room services.
• Carrying out purchase transactions relating to coins and Premium membership.
• Ensuring community safety, reviewing reports, detecting fake and inappropriate accounts.
• Improving the service and resolving errors and performance issues.
• Sending notifications and carrying out communication activities to the extent you allow.
• Fulfilling legal obligations.

SECTION 4Legal grounds

Your data is processed on the following legal grounds set out in Article 5 of the KVKK:

• Establishment and performance of a contract (art. 5/2-c) — membership, messaging and purchase transactions.
• Legitimate interest (art. 5/2-f) — security, abuse detection and maintaining service quality.
• Legal obligation (art. 5/2-ç) — retention and notification obligations arising from legislation.
• Explicit consent (art. 5/1) — consent-based processing such as location data and marketing notifications. Location data is collected only on the basis of the explicit consent you give through the location permission screen shown on your device. If you do not grant permission, location data is not processed; you can continue to use the App based on the city you select.

SECTION 5Special categories of personal data

ClickChat does not request special categories of personal data from you. The data listed in Article 6 of the KVKK (race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership of an association, foundation or trade union, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data) is not requested during registration and is not offered as a mandatory profile field.

That said, given the nature of a dating and chat app, you may by your own choice add information that could be considered special category data (for example your belief, health condition or sexual orientation) to your profile, bio, photos, Stories, Feed posts, messages or conversations in voice rooms.

If you make such information visible on your profile or in your posts, that data is processed pursuant to Article 6/3 of the KVKK on the legal ground that it relates to personal data made public by the data subject and is consistent with the intention to make it public; limited solely to displaying your content to other users and providing the service. In cases that do not fall within the scope of making data public, such data is processed only where your explicit consent exists; you may withdraw your explicit consent at any time and delete the relevant content.

In report and moderation processes, content may be viewed solely for the purpose of assessing the application, enforcing the community guidelines and establishing, exercising or protecting a right, and limited to that review. This data is not used for marketing, profiling or advertising purposes.

SECTION 6Parties to whom data is transferred and the purpose of each transfer

Your personal data is not sold to third parties and is not transferred for marketing purposes. Your data is transferred only to the following groups of recipients, for the purposes stated next to them and limited to the data necessary for that purpose:

• Google Firebase — cloud infrastructure provider (data processor)
  Purpose of transfer: creating the membership record and authentication (sign-in with Google, Apple or email), hosting your profile information and message content, storing photo and voice message files, sending notifications to the extent you allow, keeping error and performance logs to resolve malfunctions.
  Legal ground: performance of the contract (art. 5/2-c) and legitimate interest (art. 5/2-f).
• RevenueCat — subscription and purchase management provider (data processor)
  Purpose of transfer: verifying coins and Premium purchases, tracking your subscription status and renewal/cancellation information, handling entitlement and refund processes.
  Legal ground: performance of the contract (art. 5/2-c).
• Agora — real-time audio infrastructure provider (data processor)
  Purpose of transfer: technically delivering the voice room service, transmitting the audio stream between participants and ensuring connection quality.
  Legal ground: performance of the contract (art. 5/2-c).
• Apple App Store and Google Play store services
  Purpose of transfer: carrying out in-app purchase transactions, payment and billing handled by the store, verification of purchase receipts and subscription management. Your payment card details are processed by the store and are not transmitted to us.
  Legal ground: performance of the contract (art. 5/2-c) and legal obligation (art. 5/2-ç).
• Competent public authorities and institutions and judicial authorities
  Purpose of transfer: responding to requests for information and documents arising from legislation, fulfilling legal obligations and establishing, exercising or protecting a right; limited solely to the data requested.
  Legal ground: legal obligation (art. 5/2-ç) and the establishment, exercise or protection of a right (art. 5/2-e).
• Other users
  Purpose of transfer: delivering the match, Discover, chat, Stories, Feed and voice room services. Data you make visible on your profile and in your posts (profile photo, bio, Story, Feed post, messages you send and your conversations in voice rooms) is shown to other users by the nature of the service. You have the option to hide your age and distance information.
  Legal ground: performance of the contract (art. 5/2-c).

SECTION 7Retention period

Your data is retained for as long as your account is active and for the period necessary for the purpose of processing. If you delete your account, your data is permanently deleted within 30 days; records for which legislation requires retention are kept for the relevant period.

SECTION 8Your rights (KVKK Article 11)

Pursuant to Article 11 of the Law, as a data subject you have the right to:

1. Learn whether your personal data is processed,
2. Request information if your personal data has been processed,
3. Learn the purpose of processing and whether the data is used in accordance with that purpose,
4. Know the third parties in Türkiye or abroad to whom your data is transferred,
5. Request correction if the data has been processed incompletely or inaccurately,
6. Request its erasure or destruction,
7. Request that correction, erasure and destruction operations be notified to the third parties to whom your data has been transferred,
8. Object to a result to your detriment arising from analysis carried out exclusively by automated systems,
9. Request compensation for damages if you suffer damage due to unlawful processing

as set out in the Law.

SECTION 9Application procedure

You may submit your requests concerning the rights listed in Section 8 to the data controller in Turkish and containing the information below, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller.

Information your application must contain

• Your name and surname; and your wet signature if the application is made in writing,
• Your Turkish ID number if you are a citizen of the Republic of Türkiye; your nationality, passport number or ID number if any if you are a foreign national,
• Your residential or business address for service of notice,
• Your email address, telephone and fax number for notification purposes, if any,
• A clear and comprehensible statement of the subject of your request.

Any information and documents relating to your request should be attached to your application. Information verifying your identity is required so that it can be confirmed the application is made on your behalf; if an application is made on behalf of someone else, a power of attorney containing special authority is required.

Channel for submitting the application

You may send your applications by email to destek@clickchatapp.com. Legislation provides that an application may be made in writing, or by using a registered electronic mail (KEP) address, secure electronic signature, mobile signature, or an email address previously notified to the data controller by the data subject and registered in the data controller's system. As the data controller is not established in Türkiye, the KEP, secure electronic signature and mobile signature channels may not be available in practice; for this reason we kindly ask you to send your applications primarily to the email address above, and to use the other methods provided for in the legislation if you prefer.

Response time and fee

Your application is concluded free of charge as soon as possible depending on the nature of the request, and in any case within 30 days at the latest from the date it reaches the data controller. However, if the process requires an additional cost, the fee in the tariff set by the Turkish Personal Data Protection Board may be charged. The response is delivered to you in writing or electronically, depending on the nature of your request.

Your right to complain to the Board

If your application is rejected, if you find the response insufficient, or if your application is not answered within the time limit; you may file a complaint with the Turkish Personal Data Protection Board within 30 days of learning of the response and in any case within 60 days from the date of application (KVKK art. 14). In order to resort to complaint before the Board, the route of application to the data controller must first be exhausted. Your right to claim compensation under general provisions is reserved.

You can deactivate or delete your account directly from the Settings screen inside the App; you do not need to submit an application for these actions.