1. Data Controller
This disclosure notice has been prepared in accordance with Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") to inform you about the processing of your personal data.
Data Controller: Pooferi
Contact: info@pooferi.org
2. Personal Data Processed
| Data Category | Data Types |
|---|
| Identity Information | Name, surname, username |
| Contact Information | Email address, phone number |
| Visual Data | Profile photo |
| User Activity Data | Posts, comments, messages, in-app interactions |
| Transaction Security | IP address, device information, log records, session data |
| Marketing Data | Notification preferences |
3. Purposes of Data Processing
Your personal data is processed for the following purposes:
- Execution and management of user registration and account processes
- Provision, maintenance, and improvement of application services
- Management of subscription and membership processes
- Sending notifications and informational communications
- Ensuring information security and preventing unauthorized access
- Compliance with legal obligations and regulatory requirements
- Statistical analysis and service quality measurement
- Processing and responding to user support requests
- Content moderation and community safety enforcement
4. Legal Basis for Processing
Your personal data is processed based on the following legal grounds as defined in Articles 5 and 6 of the KVKK:
- Explicit consent: For marketing communications and optional features
- Performance of a contract: For providing the Service as agreed in the Terms of Service
- Legal obligation: For compliance with legal and regulatory requirements
- Legitimate interest: For service improvement, security, and fraud prevention
- Establishment of a right: For exercising or defending legal rights
5. Data Transfer
5.1 Domestic Transfers
Your personal data may be shared with competent public authorities upon lawful request, in accordance with Articles 8 and 9 of the KVKK.
5.2 International Transfers
In the course of providing the Service, your personal data may be transferred to the following international service providers:
| Recipient | Country | Purpose | Safeguards |
|---|
| Google Cloud (Firebase) | EU | Infrastructure services | Data Processing Agreement |
| RevenueCat | USA | Subscription management | Data Processing Agreement |
| Apple Inc. | USA | iOS app distribution | Platform Agreement |
| Google LLC | USA | Android app distribution | Platform Agreement |
| Cloudflare | Global | Website hosting | Data Processing Agreement |
6. Data Retention Period
| Data Type | Retention Period |
|---|
| Account data | Duration of account + 30 days after deletion |
| User-generated content | Duration of account + 30 days after deletion |
| Log and security data | 2 years |
| Transaction records | 10 years (legal requirement) |
| Communication records | 3 years |
7. Your Rights Under KVKK
Pursuant to Article 11 of the KVKK, you have the following rights:
- a) To learn whether your personal data is being processed
- b) To request information about data processing if your data has been processed
- c) To learn the purpose of data processing and whether data is used in accordance with its purpose
- d) To know the third parties to whom your data is transferred domestically or internationally
- e) To request correction of incomplete or inaccurate data
- f) To request deletion or destruction of your data under the conditions set forth in Article 7 of the KVKK
- g) To request that corrections, deletions, or destruction be notified to third parties to whom data has been transferred
- h) To object to outcomes arising exclusively from automated processing of your data that are against your interests
- i) To claim compensation for damages arising from unlawful processing of your data
8. How to Exercise Your Rights
To exercise your rights under Article 11 of the KVKK, you may submit your request through the following channels:
- Email: Send your request to info@pooferi.org with the subject line "KVKK Request"
- In-app: Settings > Account > Data Requests
Your request must include:
- Your full name and surname
- Your email address registered with Pooferi
- A clear description of your request
- Supporting documents if applicable
We will respond to your request free of charge within 30 days at the latest. If the request requires additional processing, we may charge a fee as determined by the Personal Data Protection Board.
9. Data Security Measures
We implement the following technical and administrative measures to protect your personal data:
Technical Measures
- TLS/SSL encryption for all data in transit
- Firebase Authentication for secure access control
- Firestore security rules for data access restriction
- Role-based access control (RBAC) system
- Regular security audits and penetration testing
- Automated log monitoring and anomaly detection
Administrative Measures
- Data processing agreements with all service providers
- Regular review of data processing activities
- Incident response and data breach notification procedures
- Minimum data collection principle (data minimization)
10. Changes to This Notice
This disclosure notice may be updated in accordance with changes in legislation or our data processing practices. Updates will be communicated through the App and published on this page.
11. Contact
For all KVKK-related inquiries and data subject requests: