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KVKK Disclosure

Information notice under Turkey's Personal Data Protection Law (Law No. 6698).

Last updated: June 2026

1. Data Controller

Data Controller: KLEYM Application Developer

kleymapp@gmail.com

2. Identity & Contact Data

Data collected: full name (from Apple or Google account), email address, username (nickname).

Processing purpose: Account authentication and management. Legal basis: Performance of service contract (KVKK Art. 5/2-c).

3. Location Data

Data collected: real-time GPS coordinates during drawing sessions (foreground and background while active), approximate location for Proximity Chat (3 km radius; messages auto-deleted after 24 hours), city name for regional leaderboard rankings.

Processing purpose: Game mechanics — territory drawing, area calculation, leaderboard scoring, and map features. Legal basis: Explicit consent (KVKK Art. 5/1) and performance of service contract (KVKK Art. 5/2-c).

4. Visual Data

Data collected: profile photo (optional, user-uploaded).

Processing purpose: Profile personalization and social features. Legal basis: Explicit consent (KVKK Art. 5/1).

5. Game & Statistics Data

  • Polygon territories (coordinates, area size).
  • Battle history: won/lost territory records.
  • Current and cumulative territory statistics.
  • Level and rank.
  • Lobby-based statistics (General, Walking, Cycling, Car, Sea, Air).
  • Bonus score data.

Processing purpose: Delivering the game service and leaderboards. Legal basis: Performance of service contract (KVKK Art. 5/2-c).

6. Communication Data

  • Club messages (real-time; visible to club members).
  • Direct messages (DM) between friends.
  • Proximity Chat messages (automatically deleted after 24 hours).

Processing purpose: Social features. Legal basis: Performance of service contract (KVKK Art. 5/2-c).

7. Technical Data

Data collected: APNs device token.

Processing purpose: Push notifications (territory loss, friend requests, club activity). Legal basis: Legitimate interest (KVKK Art. 5/2-f) and explicit consent.

8. Transfer of Personal Data

Your personal data may be shared with the following service providers, subject to appropriate safeguards under KVKK Article 9:

  • Supabase Inc. (USA) — database and authentication infrastructure.
  • Apple Inc. (USA) — App Store, Sign in with Apple, APNs, StoreKit.
  • Google LLC (USA) — Google Sign-In, for users who sign in with Google only.
  • Mapbox Inc. (USA) — map rendering and visualization.

Transfers are carried out subject to the recipient country providing adequate protection or through commitment of adequate protection between data controllers, in accordance with KVKK Article 9.

9. Your Rights Under KVKK Article 11

As a data subject, you have the right to:

  • Learn whether your personal data is being processed.
  • Request information about the processing of your personal data.
  • Learn the purpose of processing and whether data is used in accordance with that purpose.
  • Learn the third parties to whom your data is transferred, domestically and internationally.
  • Request correction of incomplete or inaccurate data.
  • Request deletion or destruction of your personal data under applicable conditions.
  • Request that correction or deletion operations be notified to third parties to whom your data was transferred.
  • Object to automated decisions made solely by automated systems that produce adverse effects.
  • Claim compensation for damages arising from unlawful processing of your data.

To exercise your rights, contact kleymapp@gmail.com. We will respond within 30 days. If your request is rejected or left unanswered, you may file a complaint with the Personal Data Protection Board (KVKK).

10. Data Security

  • All data transmission is encrypted via TLS/HTTPS.
  • Database access is controlled with Row Level Security.
  • Authentication uses a JWT-based secure token system.
  • Data access is restricted to authorized personnel only.

11. Cookies and Tracking

The KLEYM iOS app does not use cookies. No third-party advertising networks or behavioral analytics SDKs are used.

12. Changes

This disclosure text may be updated as needed. Changes will be communicated via app update or in-app notification.