KVKK · Law No. 6698, Article 10

Data Protection Notice

Effective: August 12, 2026Version 1.0

This notice has been prepared by Fırat Erol, acting as data controller, pursuant to Article 10 of Turkish Personal Data Protection Law No. 6698 (the "Law") and the Communiqué on the Procedures and Principles for Fulfilling the Disclosure Obligation.

1. Identity of the Data Controller

Data controller
Fırat Erol (individual developer)
Country
Türkiye
Email
info@firat-erol.com.tr

2. Categories of Personal Data Processed

CategoryData processed
IdentityNickname, profile picture, app-generated identifier, system-assigned unique user identifier
ContactEmail address, phone number — only for accounts created in earlier versions of the App; no longer collected
Visual recordsHand photos (up to 4), AI-generated design images
Transaction securitySecret key hash (SHA-256), session token hash (earlier versions), IP address, device identifier, client information (user-agent)
Customer transactionSubscription status and dates, product identifier, entitlement identifier, store information
Marketing / usageLike records, favorite themes, generation history, free-text design requests

3. Purposes of Processing

4. Method of Collection and Legal Grounds

Your personal data is collected electronically, through the mobile application, by fully automated means and based on your own declaration.

Data / activityLegal ground (Law, Art. 5)
Account creation via device identifier; identity, contact, and subscription dataDirectly related to the conclusion or performance of a contract (Art. 5/2-c)
Secret key hash, session token, IP addressLegitimate interests of the data controller (Art. 5/2-f) and performance of a contract (Art. 5/2-c)
Processing hand photos and generating designs with AIExplicit consent (Art. 5/1)
Transferring hand photos and design requests to an AI provider located abroadExplicit consent (Art. 9) and/or standard contractual clauses notified to the Authority
Retention of billing and transaction recordsCompliance with a legal obligation (Art. 5/2-ç)
Keeping usage statistics and improving service qualityLegitimate interests (Art. 5/2-f)

A note about hand photos: Your hand photos are processed solely so that nail art can be rendered on your nails. They are not used for identity verification or person recognition. Nevertheless, to ensure the highest level of data protection, we treat this data as subject to explicit consent and do not process it without your consent.

5. Recipients and Purposes of Transfer

Recipient groupData transferredPurposeLocation
AI service providers
(Features & Labels, Inc. — fal.ai; Google LLC — Gemini API)
Hand photos, free-text design requests, reference design and theme images Generating the design image (fal.ai); verifying uploads and describing reference designs (Gemini) Abroad (United States)
Subscription infrastructure provider
(RevenueCat, Inc.)
Unique user identifier, subscription and purchase data Validating and managing subscription status Abroad (United States)
App marketplace
(Apple Inc.)
Purchase and payment data Subscription sales and billing Abroad (United States / Ireland)
Hosting service provider All application data Server and database hosting Abroad — Hetzner Online GmbH, Finland (EU)
Authorized public institutions Requested data Statutory duty to provide information Domestic
Legal, accounting, and audit service providers Relevant transaction records Fulfilling legal obligations and protecting legal rights Domestic

Transfers abroad. Under Article 9 of the Law, transfers to countries without an adequacy decision are carried out on the basis of your explicit consent and/or appropriate safeguards such as standard contractual clauses notified to the Turkish Data Protection Authority.

6. Retention Periods

DataRetention period
Account and contact dataFor the duration of membership; destroyed within 30 days of account deletion
Hand photosUntil deleted by the user or the account is closed; destroyed immediately upon withdrawal of consent
Generated design imagesFor the duration of membership
Session tokens (earlier versions of the App only)30 days (invalidated automatically thereafter)
Rate-limit records60 seconds
Billing and financial records5 years under the Tax Procedure Law; 10 years under the Turkish Commercial Code

Personal data whose retention period has expired is deleted, destroyed, or anonymized, either on our own initiative or upon your request, in accordance with the Regulation on Deletion, Destruction or Anonymization of Personal Data.

7. Your Rights as a Data Subject

Under Article 11 of the Law, by applying to the data controller you have the right to:

  1. Learn whether your personal data is being processed;
  2. Request information about such processing if it has occurred;
  3. Learn the purpose of processing and whether the data is used in line with that purpose;
  4. Know the third parties, in Türkiye or abroad, to whom your data is transferred;
  5. Request correction of your personal data if it is incomplete or inaccurate;
  6. Request deletion or destruction of your personal data under the conditions set out in Article 7;
  7. Request that actions taken under items (5) and (6) be notified to third parties to whom the data was transferred;
  8. Object to an outcome adverse to you arising solely from automated analysis of your data;
  9. Claim compensation for damage suffered as a result of unlawful processing of your personal data.

8. How to Submit a Request

You may submit requests concerning the rights above, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, through any of the following channels:

Depending on the nature of the request, your application is concluded free of charge within 30 days at the latest. If the process requires an additional cost, a fee set in the tariff determined by the Board may be charged.

If your application is rejected, if you find our response insufficient, or if we fail to respond in time, you may file a complaint with the Turkish Data Protection Board within 30 days of learning our response and, in any case, within 60 days of your application date. See kvkk.gov.tr.

Informational only

This document is provided for information purposes only and contains no declaration of consent. For processing activities that require consent, please see the separate Explicit Consent Statement.