KVKK Privacy Notice
Last updated:
This notice is provided under Article 10 of Türkiye's Personal Data Protection Law No. 6698 (KVKK) for the processing of personal data in Simurg Apps applications and on simurgapps.com. The Turkish version is the authoritative text.
Data controller
Simurg Apps — Ömer Koç (individual developer) Address: Kadıköy, Istanbul, Türkiye Email: destek@simurgapps.com
Data processed and collection methods
Personal data is collected electronically, by automated or partly automated means, through information you enter in the app, Apple or Google sign-in responses, our servers, analytics and crash reporting services, purchase notifications from app stores and RevenueCat, advertising services and support correspondence. Depending on the app, the categories are:
- Identity and contact: profile name, email address (in apps with accounts)
- Customer transactions: subscription status, product and transaction IDs, in-app balance movements
- Transaction security: user and installation IDs, IP address, session records, error logs
- User content: birth details, texts and feature results you enter
- Marketing and analytics: usage analytics where allowed; advertising ID in apps that show ads
- Requests and complaints: support correspondence
Each app's privacy page explains exactly what data it processes: Elandra, Bolt Drop.
Purposes and legal grounds
- Providing the app, creating and managing accounts, handling purchases and subscriptions: necessary for entering into or performing a contract (KVKK Art. 5(2)(c))
- Information security, abuse prevention, troubleshooting: legitimate interests, provided they do not harm your fundamental rights and freedoms (Art. 5(2)(f))
- Legal obligations: explicitly provided by law and legal obligation (Art. 5(2)(a), 5(2)(ç))
- Establishing, exercising or protecting rights: Art. 5(2)(e)
- Optional usage analytics, personalised advertising and marketing communications: explicit consent (Art. 5(1))
Providing this notice and obtaining consent are separate steps; reading this notice does not by itself constitute explicit consent.
Recipients
Personal data may be shared, limited to the purposes above, with:
- Hosting and infrastructure: Cloudflare (servers, database, website, security)
- Analytics, crash reporting and advertising: Google (Firebase Analytics, Crashlytics, Performance Monitoring, AdMob)
- Purchase management: RevenueCat
- Sign-in, payments and backup: Apple and Google
- AI services: only in apps offering such features (e.g. DeepSeek in Elandra)
- Email delivery: Resend (account emails only, e.g. password reset)
- Competent public authorities: when legally required
These providers' servers may be located outside Türkiye (in the EU, the US, China and other countries). Transfers abroad are assessed separately under the conditions of KVKK Article 9. This notice or a general consent checkbox does not by itself establish a legal basis for a transfer abroad. You may ask us about transfers and the safeguards applied.
Retention and destruction
Personal data is kept for as long as the purpose requires. Account data is kept while the account is open and deleted when the account is deleted. Technical logs, analytics and support correspondence are kept according to need, service settings and legal obligations, and are then deleted, destroyed or anonymised.
Your rights under KVKK Article 11
You may apply to the data controller to:
- learn whether your personal data is processed,
- request information about the processing,
- learn the purpose of processing and whether data is used accordingly,
- know the third parties to whom data is transferred in Türkiye or abroad,
- request correction of incomplete or inaccurate data,
- request deletion or destruction under the conditions of KVKK Article 7,
- request that corrections, deletions or destruction be notified to recipients,
- object to a result against you arising solely from automated analysis,
- claim compensation for damage caused by unlawful processing.
How to apply
Send your request, if possible from the email address registered in the app, to destek@simurgapps.com. State your name, the app concerned and your request clearly; never send passwords or card details. Other application methods provided by law remain available.
Requests are resolved as soon as possible and within 30 days at the latest, free of charge. If processing requires an additional cost, the fee set by the Personal Data Protection Board may apply. If your request is rejected, the answer is insufficient or not given in time, you may file a complaint with the Personal Data Protection Board.