This Privacy Policy explains how [Tunugi Group Legal Entity Name] (“Tunugi”, “we”) collects, uses and protects personal data when you use our website, apps and games (the “Services”). We act as the data controller under the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and, where applicable, the EU General Data Protection Regulation (“GDPR”).
1. Who we are
[Tunugi Group Legal Entity Name], [Street, District, City, Country]. Registry: [Trade registry / MERSIS number]. Privacy contact: [email protected].
2. Data we collect
- Contact data you send us (name, email, message) through forms or email.
- Account data if an app offers accounts (email, display name, encrypted password).
- App content you enter, e.g. habits, budgets or health entries. Health apps may read data from Apple Health or Google Health Connect only with your explicit permission.
- Technical data: device type, OS version, app version, crash logs and IP address.
- Purchase data: subscription status from Apple or Google. We never receive your card details.
3. Why we use it (purposes and legal bases)
| Purpose | Legal basis |
|---|---|
| Providing and operating the Services | Performance of a contract |
| Answering your messages and support requests | Legitimate interest / your request |
| Processing health data | Your explicit consent (KVKK Art. 6, GDPR Art. 9) |
| Security, fraud prevention and crash diagnostics | Legitimate interest |
| Optional analytics and marketing emails | Consent, which you can withdraw at any time |
| Legal, tax and accounting obligations | Legal obligation |
4. Health data
Health and wellness data is sensitive. We process it only with your explicit consent, only for the feature you use, and never for advertising. Where possible it is stored on your device. We never sell health data or share it with advertisers or data brokers. Our health apps are not medical devices.
5. Sharing
We do not sell personal data. We share it only with service providers who help us run the Services (such as hosting, email and crash reporting), under contracts that require them to protect it, with app stores for purchases, and with authorities when the law requires it.
6. International transfers
Some providers may process data outside Türkiye or the EEA. In that case we rely on the safeguards required by KVKK Article 9 and GDPR Chapter V, such as standard contractual clauses.
7. How long we keep data
We keep data only as long as needed for the purpose it was collected: account data until you delete your account, contact messages for up to 2 years, and records required by law for the statutory period.
8. Your rights
Under KVKK Article 11 and the GDPR you may ask to access, correct, delete or export your data, object to or restrict processing, and withdraw consent. Email [email protected]. We reply within 30 days. You can also complain to the Personal Data Protection Authority (KVKK) or your local supervisory authority.
9. Children
Our Services are not directed to children under 13 (or the minimum age in your country) without parental consent. If you believe a child gave us data, contact us and we will delete it.
10. Security
We use encryption in transit, access controls and data minimisation. No system is 100% secure, but we work hard to protect your data.
11. Changes
We will post updates on this page and, for important changes, notify you in the app or by email.