KVKK Disclosure Notice
This notice has been prepared under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") to inform you how your personal data is processed when you use the Riddlo mobile app ("Riddlo").
1. Data controller
Your personal data is processed by İlker Doğan as the data controller. Contact: support@riddlo.app
2. Personal data processed
- Identity and account: name, email address (if Apple or Google shares it), Apple / Google account ID; for Apple sign-in, the sign-in token Apple issues, used to remove Riddlo's connection in the Apple account when the account is deleted.
- Profile: date of birth, gender, photos, bio.
- Location: approximate location (if you allow it).
- User content and interactions: gate questions and answers, gate question suggestions, messages (text, photos, audio), likes, profile visits, blocks, last active time.
- Safety records: reports and their attachments, account closure decisions, digest (hash) of a deleted account's Apple / Google account ID.
- Legal transaction records: records of accepting and reading legal documents.
- Purchase information: subscription type and status (no payment details are processed).
- Device and transaction security: notification address, device language, ad verification transaction ID, digest (hash) of the device identifier, IP address and access time.
3. Purposes and legal grounds
- Membership and providing the service (creating your account, showing your profile, gate and gate question suggestions, discover, likes and messaging, notifications, Premium subscription): being directly related to the establishment or performance of a contract (KVKK art. 5/2-c).
- Ensuring safety and community rules (reviewing reports, removing content that breaks the rules, closing accounts, preventing fake accounts and fraud, verifying rewarded ads, usage limits, preventing limits and blocks from being bypassed by deleting and re-creating an account, and preventing closed accounts from opening new ones): the data controller's legitimate interest, provided your fundamental rights and freedoms are not harmed (KVKK art. 5/2-f).
- Fulfilling legal obligations (age 18 check, access log under Law No. 5651, requests from competent authorities): legal obligation (KVKK art. 5/2-ç).
- Protecting rights (keeping consent, subscription and report records): establishment, exercise or protection of a right (KVKK art. 5/2-e).
- Sending offer notifications (push notifications about Premium offers, discounts and new features): based only on the explicit consent (KVKK art. 5/1) and the approval under Law No. 6563 you give by turning on Settings › Notifications › Offer notifications in the app. Not consenting does not affect your use of the service; you can withdraw your consent at any time in the same place. The dates of granting and withdrawing consent are recorded.
Apart from this, we have no processing activity based on your explicit consent; ads are not personalised.
4. Method of collection
Your personal data is collected electronically through the Riddlo mobile app: some of it you enter yourself (profile, gate questions and question suggestions, messages, reports), some is received from Apple or Google when you sign in with them, and some is generated automatically while you use the app (location, interactions, device and access information).
5. Transfers
Your personal data is transferred, limited to the purposes in section 3 and only as much as necessary, to the following recipients:
- Our service providers: Supabase (database and file storage, Germany), Apple and Google (sign-in, notification delivery, finding your area from your location, store purchases; Google also serves ads, USA), Expo (notification delivery, USA) and RevenueCat (subscription tracking, USA). Because these providers are located abroad, your data is transferred abroad (KVKK art. 9).
- Competent public authorities and courts: only when required by law.
As part of how the app works, your profile information, gate questions and messages are shown to other users to the extent described in the Privacy Policy. Your personal data is not sold.
6. Your rights
Under Article 11 of KVKK, by applying to the data controller you have the right to:
- learn whether your personal data is processed,
- request information about it if it is processed,
- learn the purpose of processing and whether it is used in line with that purpose,
- know the third parties in Türkiye or abroad to whom it is transferred,
- request its correction if it is incomplete or inaccurate,
- request its deletion or destruction under the conditions in KVKK art. 7,
- request that correction, deletion and destruction be notified to the third parties to whom it was transferred,
- object to an outcome against you resulting from analysis exclusively by automated systems,
- claim compensation if you suffer damage due to unlawful processing.
You can apply by email to support@riddlo.app, stating your name and the sign-in method you use on Riddlo (Apple / Google). Your application is concluded free of charge within 30 days at the latest. Additional information may be requested to verify that the account is yours.
For more details, see the Privacy Policy. The Turkish version of this notice is the reference version; this English text is a translation.