Privacy Policy (GDPR / KVKK Information) (EN)
At Web Her Yerde ("we", "us", "our"), we value the privacy of our users. This Privacy Policy explains what personal data is collected through our mobile applications, games, and websites (together, the "Services"), how it is used, with whom it may be shared, and what rights you have regarding your data.
1. Data Controller
The data controller responsible for your personal data is:
- Name: Burak Kılıç (Web Her Yerde)
- Address: Bayraklı, 35000 İzmir, Türkiye
- Email: [email protected]
- Website: www.webheryerde.com
2. Scope of This Policy
This Privacy Policy applies to all mobile applications, games, and websites currently published or operated by Web Her Yerde, as well as any future application, game, or website we publish that links to this Privacy Policy. Where a specific app or website has materially different data practices, a supplementary or dedicated policy may be provided within that product; in the absence of such a policy, this document governs.
3. Categories of Data We Collect
Depending on which Service you use and the features you use within it, we may collect:
- Account and profile data: name, email address, username, avatar/profile picture, and authentication identifiers, where a Service offers registration, login, or community features.
- User-generated content: notes, tasks, to-do items, exam/study data, community questions and answers, group messages, and similar content you voluntarily create or share within the app.
- Device and technical data: device model, operating system and version, unique device/advertising identifiers, IP address, language and locale settings, and crash/diagnostic logs.
- Usage data: screens viewed, features used, session length, in-app interactions, and general usage statistics.
- Approximate location data: derived from your IP address or device settings, primarily used for ad personalization and analytics, where enabled and where you have not opted out.
- Push notification tokens: a device identifier used to deliver notifications to your device.
- Cookies and similar technologies: on our websites (see Section 6 below).
For Services that do not require an account, session and usage data is stored locally on your device by default and is not transmitted to us except through the analytics and advertising services described below, where enabled.
4. Third-Party Services We Use
Our Services may actively integrate the following third-party services, each of which may independently collect and process data under its own privacy policy. We encourage you to review these policies as well:
- Firebase (Google LLC): including Firebase Analytics, Firebase Cloud Messaging (FCM), Firebase Crashlytics, Firebase Authentication, and Firebase Realtime Database/Firestore — used for usage analytics, push notifications, crash and performance reporting, and, where applicable, account authentication and storage of user-generated content. See Firebase Privacy Policy.
- Google Analytics: used on our websites and, via Firebase, within our apps, to analyze visitor/user behavior and usage statistics. See Google Privacy Policy.
- Google AdMob: used to display and personalize in-app advertising, and may collect device and advertising identifiers. See AdMob Privacy & Terms.
- Google AdSense: used to display advertising on our websites. See Google Ads Technologies Policy.
- Google Ads: used for advertising campaigns and conversion measurement, which may involve cookies or mobile ad identifiers. See Google Ads Technologies Policy.
- Meta (Facebook) Pixel / SDK: used on our websites and/or within apps for advertising measurement and audience targeting. See Meta Privacy Policy.
- Google Play Games Services: used to synchronize achievements, leaderboards, and saved game progress where applicable. See Google Privacy Policy.
Not every Service uses every third-party tool listed above; the specific set used depends on the app or website in question. Where required by applicable law (e.g. in the EEA/UK), advertising and non-essential analytics tools are only activated after you provide consent through an in-app or on-site consent mechanism, where such a mechanism is implemented.
5. Cookies and Similar Technologies (Websites)
Our websites use cookies and similar technologies (such as local storage and pixels) to operate correctly, remember preferences, and measure and personalize advertising. We use the following categories of cookies:
- Strictly necessary cookies: required for core site functionality (e.g. login sessions, security, load balancing).
- Analytics/performance cookies: such as Google Analytics, used to understand how visitors use our site.
- Advertising/marketing cookies: such as those set by Google Ads, AdSense, and the Meta Pixel, used to measure and personalize ads and track conversions.
Where required by law, we request your consent to non-essential cookies via a cookie banner before they are activated. You can manage or withdraw cookie consent at any time through your browser settings or, where available, our cookie preference tool. You may also opt out of personalized advertising using Google Ad Settings and the Your Online Choices / Digital Advertising Alliance opt-out tools.
Where an app or game operates, or links to, a companion website (for example, for account management, community features, downloads, or customer support), that website may publish its own separate Terms of Use / Terms of Service, covering matters such as acceptable use, account rules, liability, disclaimers, and intellectual property. Those terms apply independently to your use of that website, and we encourage you to review them in addition to this Privacy Policy.
6. Purposes of Processing
- To provide, operate, and maintain the core functionality of our apps, games, and websites.
- To create and manage user accounts and enable community/social features (where offered).
- To analyze app/website performance, diagnose and fix bugs and crashes.
- To display and personalize advertisements and measure their effectiveness.
- To record in-app/in-game achievements, scores, and leaderboard standings.
- To send push notifications (e.g. reminders, community replies, group messages).
- To analyze user behavior in order to improve the user experience.
- To comply with legal obligations and enforce our terms of use.
7. Legal Basis for Processing (GDPR)
Where the GDPR applies, we rely on the following legal bases under Article 6 GDPR: (a) your consent (e.g. for cookies, personalized advertising, and push notifications); (b) performance of a contract (e.g. providing account and community features you have signed up for); (c) our legitimate interests (e.g. securing our Services, basic analytics, and preventing fraud), balanced against your rights; and (d) compliance with a legal obligation, where applicable.
8. Data Sharing and International Transfers
We do not sell your personal data. We share data with the third-party service providers listed in Section 4 solely so they can perform analytics, advertising, crash reporting, messaging, or authentication services on our behalf or in their own capacity as independent controllers (e.g. for ad networks). These providers may process and store data on servers located outside your country of residence, including in the United States, relying on mechanisms such as Standard Contractual Clauses or other legally recognized transfer safeguards.
9. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, including the duration of your account or app usage, plus any additional period required to comply with legal obligations, resolve disputes, or enforce our agreements. User-generated content and account data are deleted or anonymized upon a verified deletion request or account closure, subject to any legal retention requirements. Analytics and advertising identifiers are retained according to the relevant third-party provider's own retention policy.
10. User Rights
Depending on your location, and in particular under the GDPR, you have the right to:
- Request access to the personal data we (or our processors) hold about you;
- Request correction of inaccurate or incomplete data;
- Request erasure ("right to be forgotten") of your data;
- Request restriction of, or object to, certain processing;
- Request data portability;
- Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal; and
- Lodge a complaint with your local data protection supervisory authority.
You can exercise these rights directly with the relevant third-party service providers where the data is processed by them independently (e.g. Google, Meta account/ad settings), or by contacting us directly at [email protected], and we will assist you or forward your request as appropriate.
11. Children's Privacy
Our apps and games are intended for a general audience and are not specifically directed at children under the age of 13 (or a higher age of consent where required by local law, e.g. 16 in some EU member states, or under 18 as noted for general audience classification). We do not knowingly collect personal data from children beyond what is necessary for basic, non-personalized functionality. If you believe a child has provided us with personal data without appropriate consent, please contact us at [email protected] so we can delete it.
12. Data Security
We apply reasonable technical and organizational measures designed to protect your data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our Services, the third-party tools we use, or applicable law. The "last updated" date below indicates when this Policy was last revised. Material changes will be communicated through the app or on this page where appropriate.
14. Contact Information
For any questions about this Privacy Policy or your data, please contact us at: [email protected]