01 — Privacy Policy & Data Protection Notice
Prepared under Turkey's Law on Protection of Personal Data No. 6698 ("KVKK"), the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), and the California Consumer Privacy Act / California Privacy Rights Act ("CCPA/CPRA").
§1 Identity of the Data Controller
Data Controller: Baran Akyol (natural person, individual app developer; "the Developer" or "We"). Official requests: [email protected]. Data protection: [email protected]. General contact: [email protected]. Trade registry/MERSİS number and registered electronic mail (KEP) address: none. Website: generationnetwork.app.
VERBİS: under the exemption criteria set by decisions of Turkey's Personal Data Protection Board, we are not required to register with VERBİS (the Turkish Data Controllers' Registry): as a data controller resident in Turkey, we have fewer than 50 employees per year and an annual balance-sheet total below TRY 100 million; even if our main activity were considered to be the processing of special-category personal data, we fall below the thresholds in the Board's Decision No. 2025/1572 of 4 September 2025 (fewer than 10 employees per year and an annual balance-sheet total below TRY 10 million). If these thresholds are exceeded, the registration obligation will be fulfilled in time. The VERBİS exemption does not remove our information, data-security, and other obligations under KVKK.
Note on team and personnel references: Any reference in this Policy or related documents to a "team", "personnel", "department", or similar term is, as of the effective date of this Policy, to be understood as referring solely to the Developer (Baran Akyol) individually. Should the Developer in the future engage personnel, representatives, or contractors to assist in operating the App, such persons automatically fall within the scope of these terms without requiring a further amendment to this Policy.
Regional applicability: This Privacy Policy applies to all users. Additional rights under KVKK apply to users in Turkey, GDPR to users in the EU/EEA, and CCPA/CPRA to users in the United States, as set out in the relevant sections below. Where a regional provision conflicts with a general provision, the regional provision prevails.
General note on legal references: References to KVKK, GDPR, or other legislation next to specific provisions are illustrative only. The absence of a reference to a specific law or region next to a provision does not mean that provision is inapplicable in other jurisdictions. This Policy is interpreted together with the data-protection and privacy law applicable to the relevant user; in case of conflict, the mandatory local law applicable to that user prevails.
This Policy applies to everyone who uses the "Generation Network" mobile application ("the App") and explains how personal data is collected, processed, stored, transferred, and deleted.
§2 Data Storage Architecture — Core Principle
Generation Network is built on a privacy-first, server-free architecture. Its core principles are:
- Personal data belonging to the user is permanently stored only on the user's own device, in an encrypted local database (SQLCipher — AES-256) and in the operating system's secure storage (flutter_secure_storage).
- The Developer does not permanently store user data in any cloud database or on the server side.
- Data is transmitted to the server side only temporarily, for specific real-time operations — primarily AI model calls, authentication, moderation notifications, and payment verification. The content of these transmissions leaves no permanent trace in the Developer's infrastructure once the operation is complete; any temporary data retained for routing purposes is deleted within 30 days at the latest. Exception: traffic (metadata) records that contain no message content and that must be retained under Turkish Law No. 5651 and KVKK Art. 5(2)(ç) are retained as described, and for the periods stated, in §3.9-D.
- Advertising SDK integration: the App includes the Google Mobile Ads SDK (Google AdMob) and Google's User Messaging Platform (consent) library. These components run on the user's device and communicate directly with Google; the conditions in §1-A.7 (Terms of Sale) and §3-B.2(v) apply. The only other ad-related processing is the Developer's own ("house") ad system, which records nothing but aggregate counters that contain no user identity (see §1-A.7.8). The App does not include third-party analytics (user-behavior tracking) tools; Firebase's analytics component (Google Analytics for Firebase) is not present in the App. The third-party components included in the App and their purposes are: Firebase Cloud Messaging for delivering push notifications (§3.10), Firebase Crashlytics for crash and error reports (§3.14-A), Talsec freeRASP for the runtime security check for users of Bring Your Own API and Model within Model (§3.14-B), and Google Play Integrity for app and device integrity verification (§3.14-C).
- Important clarification — this principle is not absolute. "The Developer does not permanently store user data" describes the general rule for content data (chats, Reflection profiles, memories, life stories, health/activity data), which is genuinely held only on-device. It does not mean the Developer's infrastructure retains no server-side record whatsoever. As explained throughout this Policy — and in particular in §3-G (identity verification & guardian recovery infrastructure), §3.7-A/§3.7-B (letter and SMS routing), §3.8 (subscription/quota tracking), §3.9 (moderation, legal-compliance, and payment-service-provider records), §3.9-D (statutory traffic/metadata records), §3.10 (push-notification device records and scheduled notifications), and §3.12 (emails sent to the Developer) — certain limited categories of data, such as identity identifiers used for message routing or PSP (payment service provider) verification, and records required for subscription management, fraud prevention, or legal/regulatory processes requiring heightened moderation, may be held in a server-side database. This server-side retention is never indefinite: such records are deleted once they are no longer required for the purpose for which they were collected, subject to the specific retention periods stated in the relevant sections below and to mandatory legal-retention obligations.
Server architecture — hybrid model and legal exceptions: while the App is designed on a fundamentally serverless basis, a transition to conventional server infrastructure is contemplated under certain conditions, including: (a) premium subscription processing, payment verification, and subscription management; (b) cooperation with competent authorities required under the Turkish Penal Code, counter-terrorism legislation, child-protection provisions, or other mandatory legal obligations; (c) technical interventions deemed necessary to address serious security breaches, fraud, or abuse of the service. Which operations run serverless versus through conventional server infrastructure may change over time depending on legal requirements, technical needs, and product-development dynamics. The Developer commits to exercising this choice consistently with the data-minimization principle permitted under Turkish law, GDPR, and CCPA/CPRA.
- For user matching and similarity analysis, vector representations of user profile data may be temporarily transmitted to a processing server; no permanent record is kept on the server once this operation completes. See §3.5.5 for details.
This architecture means users retain full control over holding and deleting their data. Losing the device or uninstalling the App carries the risk that the Developer cannot recover permanent on-device data; see §9.
§2-A Architecture: Local-First and Minimal Relay Server
Generation Network is designed to keep your data on your own device wherever possible. Your digital reflection, memories, experiences, and learning history are stored in an encrypted (SQLCipher) local database on your device and are not transmitted to our servers by default. Our servers function as a minimal "relay" layer handling only the coordination tasks required for the Service to work — authentication, cross-device synchronization, and matching/delivery between users — and do not permanently store your personal content beyond these limited tasks. This approach is inspired by the "servers do not retain data" principle of security-focused communication systems such as Signal. This principle applies to message content: the Developer provides content confidentiality but makes no promise of anonymity or of leaving "no trace"; for the traffic (metadata) records kept under legal obligation, see §3.9-D.
The classification below is current and binding as of the effective date of this Policy, independent of any general statements that may appear elsewhere in it; the relevant feature-specific sections (§3.5.5-A, §3.7-A, §3.7-C, §3.7-D, §3.5.7-B, etc.) should be read together with it.
1. End-to-end encrypted: Web2 Similarity Analysis match content (see §3.5.5-A); Letter (including steganographic postcards), Telegraph, and SMS message content — always. The App never sends this content unencrypted: if an encrypted connection with the recipient cannot be established (e.g., the other party has not opened the app since this feature went live, or there is a temporary connection problem), the message is held only on your device, in the encrypted local database, retried automatically for up to 3 days, and cancelled if it cannot be sent within that time; you are then shown a notification and no Stamp is charged (a prepaid Stamp is refunded, and SMS credit is refunded). For letters and postcards, a "message franking" proof that does not decrypt the content is additionally generated; it is used only if the recipient reports a message, and only with the recipient's consent (see §3.9-E).
2. Not end-to-end encrypted, but not permanently retained on the server (temporary relay): Broadcast Letter and Live Chat; this content is held temporarily on our servers — accessible only through authorized system access — until delivery/completion, and is automatically deleted upon delivery or within 2 days at the latest. The following features have their own specific holding periods: standalone postcards, One-Way Simulation ("Reflection") results, and simulation stories are automatically deleted from the server within 3 days at the latest if the recipient has not retrieved them (see §3.7, §3.5.7-B, and §3.5.7-C); a Broadcast Letter, which is shown to recipients selected by the system rather than delivered to a single expected recipient, is held on the server for the publication period chosen by its author (7/30/365 days; see §3.7-C). For Broadcast Letter, the relevant portions of your interests/personality summary are additionally processed in plain text on the server during matching, so we can determine who writes to you (see §3.7-C); for candidates not selected, this data is discarded, without permanent storage, once the matching request ends.
3. Permanently retained on the server (necessary for the Service to function and for legal compliance): authentication records, payment/accounting records (for the period required by applicable law), support/complaint request records, signals related to your account's security/risk status, push-notification device records (until you turn notifications off or uninstall the App; see §3.10), emails you send to the Developer (see §3.12), and statutory traffic (metadata) records that contain no message content (see §3.9-D — these records only wait temporarily on the server; the permanent copy is kept in a secure, off-server record system accessible only to personnel authorized by the Developer).
Once an end-to-end encrypted message reaches and is decrypted on your device, it may — based on your own choices (via your privacy settings) — be incorporated into your digital reflection's learning process or processed by our AI-assisted analysis features; this is a separate data flow under your control and is outside the scope of our end-to-end encryption guarantee (see §3.5.3 and §3.5.8).
Legal basis: KVKK Art.5/2-c (contract performance) and Art.5/2-f (legitimate interest — data minimization); GDPR Art.6(1)(b) and (f), Art.25 (data protection by design). This section does not introduce a new category of data processing; it is the concrete, feature-level expression of the general architecture principle in §2 as applied to messaging and matching features.
§3 Data Collected, Legal Bases, and Purposes — the App processes the following categories of personal data. Legal basis, purpose, and retention period are stated separately for each category.
§3.1 Account & Profile Data
Data collected: username, password hashed with bcrypt/Argon2 (never stored in plaintext), phone number, date of birth, and age calculated from it.
Legal basis: KVKK Art.5/2-c (performance of a contract); GDPR Art.6(1)(b) — necessary for account creation, authentication, and service delivery.
Purpose: account creation and management, secure login, age verification (18+ policy — see §3-A and §7), password reset, account-security notifications.
Storage: held in the encrypted local database on-device. On the Developer's server side, your account is represented only by the irreversible cryptographic identity number (kimlik_no) and Ed25519 public key described in §3-G; as of the effective date of this Policy, your phone number, email address, password, or any hash of them is not sent to the Developer's servers for authentication. If this architecture changes in future, the relevant data category will be added to this section and notified under §10.
Retention: for as long as the account remains active; permanently deleted within 30 days of account deletion, subject to legal obligations (e.g., tax records).
Derived data: a zodiac sign and a "generation" label (X/Y/Z/Baby Boomer-style) may be derived automatically, entirely on-device, from the date of birth to personalize the user experience. These derived tags are an extension of the date-of-birth data, do not constitute a separate collection activity, and are subject to the same legal basis as the date of birth (KVKK Art.5/2-c; GDPR Art.6(1)(b)).
§3.2 Location Data
Data collected: GPS coordinates (latitude/longitude), city and country, obtained from the device via the geolocator and geocoding libraries.
Legal basis: KVKK Art.5/1 (explicit consent); GDPR Art.6(1)(a). Location data is sensitive in nature and is processed only with separate, informed, and revocable consent.
Purpose: to build the geographic context of the user's digital characters within the simulated social network, and to power location-based simulation features and regional content.
Collection method: location data under this section is captured only at the moment of a user-initiated "check-in" (Profile > Frequent Places, including the local culture analysis button, see §3.15-B). In addition, only if location permission has already been granted and the device's location service is on, the current location is taken under the Current Context feature described in §3.2-A when the App is opened and when it is brought to the foreground after a longer break (at most once every 30 minutes). No continuous or background location tracking takes place; the App does not request any new location permission for this purpose.
Transmission for real-network letter delivery: the location/country information stated on your profile is no longer used solely to display your profile — where a letter is sent over the real (non-simulated) network, this information is also transmitted to the recipient's device so the App can calculate the letter's delivery/waiting time, as described in §3.7-A and §3.7-B. If this information is missing, incomplete, or cannot be determined, the system applies the longest available waiting period (7 hours) as a conservative, security-oriented default.
Storage: city/country information is kept encrypted on-device together with the user's profile. It is transmitted to the server only for the following purposes: (i) the delivery-time calculation described above; (ii) if you have enabled push notifications, storage of the country stated on your profile together with your notification device record, so that the arrival time of letters sent to you can be calculated in the same way as in the App; and (iii) when you send a letter, display of the country stated on your profile in the "letter on its way" and "letter arrived" notifications sent to the recipient, and its retention on the server for this purpose for no more than 3 days (see §3.10). City information and GPS coordinates are not transmitted to the server for these notification purposes.
Retention: stored on-device until updated by the user or until account deletion.
§3.2-A — Current Context (Live Location and Surroundings)
What is collected: when the App is opened and when it is brought to the foreground after a longer break (at most once every 30 minutes), the following is collected on your device: (i) your current location, only if location permission has already been granted and the location service is on; the coordinates are converted into district, province and country names by reverse geocoding; (ii) date, time, time zone and season; (iii) the weather (temperature, feels-like temperature, weather type, humidity, wind, day/night); (iv) the phone's technical state: battery level, charging state, battery saver mode, connection type (Wi-Fi/mobile), device model and Android version; (v) your step count for the day, only if step-counter permission has already been granted. No other sensor requiring an additional permission is read, and no new permission is requested for this feature.
Purpose: to let your Reflection give more contextual answers in the Book chat by taking your current surroundings (e.g., the time, the weather, the city you are in) into account when relevant to the conversation.
What goes to the AI: when you send a message in Book, a text summary of this information (district, province and country name; the general location you entered in your profile; date and time; weather; battery and connection state and device model; step count) is sent as part of the hidden context to the AI provider in §3.5.3. Coordinates are not sent to the AI provider. The model is instructed to use this information only when it is relevant to the conversation.
Weather provider: for the weather, your coordinates are rounded to about 0.1 degrees (about 11 km) and sent to MET Norway (Norwegian Meteorological Institute, §3-B.2 (xi)); no account ID, username or other identifier is added to the request. The query is made at most once an hour.
State Memory: if the province and country you are in differ from the last note, or 6 hours have passed since the last note, a short note of the form "on this date you were around this place" is written to the State Memory on your device (§3.7-F); these notes may be used in memory search in Book.
Storage: the last location (coordinates and place name) and the other information are kept only on your device; they are not sent to the Developer's servers and are not shown on the Global Profile. State Memory notes are subject to the limits and deletion rules in §3.7-F.
How to stop it: if you turn off Settings > Privacy & Security > "Current context (location, weather, phone status)", none of this information is collected, the last location and context information kept on the device are deleted and nothing is sent to Book (notes already written to State Memory can be deleted there under the rules in §3.7-F). In addition, if you revoke the App's location permission (and step-counter/physical activity permission) in your device settings, live location and step information are no longer collected; the weather is also queried only while a live location is available. Date, time, battery and connection state are read from the device without a permission.
Legal basis: for location data, KVKK Art. 5(1) and GDPR Art. 6(1)(a) (explicit consent — the location permission, revocable at any time); for the other context information, KVKK Art. 5(2)(f) and GDPR Art. 6(1)(f) (legitimate interest — providing the chat service you requested in a context-appropriate way). International transfers are subject to §5.
§3.3 Biometric Data (Fingerprint / Face Recognition)
How it's processed: the App uses the device's operating-system-level biometric authentication infrastructure (local_auth — Android BiometricPrompt / iOS LocalAuthentication) for fast, secure login. Fingerprint templates and face models are held only in the device's secure hardware enclave (TEE / Secure Enclave).
Legal basis: KVKK Art.6/3 — as a special category of personal data, biometric data may be processed only with explicit consent. The user is informed on a separate consent screen before this feature is enabled. GDPR Art.9(2)(a) applies in parallel.
Data flow: biometric data never leaves the device under any circumstances. It is not transmitted to the Developer's infrastructure, the API gateway, or any third party. Only a "success/failure" authentication result is reported to the App.
Retention: since the data resides in device hardware, the Developer has no direct deletion authority; the OS-level record is automatically invalidated when the user disables this feature.
§3.4 Step Count (Health Data) and Estimated Sleep Pattern
Step count: your daily step count is read from your device's pedometer/accelerometer sensor only when you tap the permission option in the Step Counter panel, give your explicit consent in the separate consent window that follows, and approve the operating-system permission. Because step count may be considered health data, the Developer treats it as special-category personal data. The consent window explains where the data is kept, that it may be shared with the people you exchange letters with according to your sharing settings, that it may be used in your Reflection's AI features, and how consent can be withdrawn; the time of consent is recorded on your device. Declining consent does not affect the App's other functions.
Estimated sleep pattern: without using any separate sensor or health-data source, the App calculates an estimated rest/sleep pattern deterministically from the hours during which you do not use the App. This estimate is not a medical measurement, contains no assessment of your sleep quality or health, and is not used to draw inferences about your health; it is used only to simulate your Reflection's daily rhythm.
Purpose: to reflect your daily activity and rest pattern in your digital copy and to give you a personal summary (informational only, not medical advice).
Storage and sharing: raw step data and the estimated sleep pattern are kept encrypted only on your device and are not stored on the Developer's servers. However, if the "mobility" and "sleep pattern" sharing categories in §3.5.9-B are on (they are on by default), summaries of them are delivered as part of KP-memory to the people you exchange letters with (the server only relays them temporarily) and may be used in your Reflection's AI features and sent to the AI provider under §3.5.3. A mobility summary based on step count exists only if you have given the explicit consent above. In simulations, the sleep pattern is not used even with the closed-data option (§3.5.7-D).
Control and withdrawal: you can withdraw your consent for step data by turning off the physical-activity (step) permission in your device settings, and stop the sharing by turning off the "mobility" and "sleep pattern" categories in Settings > Social Environment Settings. Withdrawal does not affect the lawfulness of processing before withdrawal.
Legal basis: for step count, KVKK Art.6/2 and GDPR Art.9(2)(a) (explicit consent); for the estimated sleep pattern, KVKK Art.5/2-c and Art.5/2-f, GDPR Art.6(1)(b) and (f); for sharing, §3.5.9-B.
Retention and deletion: this data is deleted from your device with "Delete all data" in Settings, when you delete your account, or when you uninstall the App; §3.11-B applies to summaries already delivered to people you exchanged letters with. See also the Health Data Notice.
§3.4-A Removed and Unused Permissions
As of 13 October 2026, the App no longer requests permissions for features it does not offer (contacts access, near-field/Bluetooth scanning, phone state); these permissions have been removed from the App. The App only requests the permissions needed for the features it offers (e.g., notifications, location, step counter), and the data collected through them is described in the relevant sections of this Policy.
If the relevant feature is enabled in the future, the category of data processed, its purpose, legal basis, and retention period will be added to this Policy, and users will be informed in advance under §10. The user may restrict or deny these permissions at any time from device settings; doing so does not affect the App's current core functionality.
§3.5 Chat, AI Interaction, and Psychological/Behavioral Analysis Data
Data collected: the user's exchanges with in-app AI assistants and simulated characters; sentiment-analysis results produced by local, on-device ONNX models; behavioral and psychological profile data derived from the user's text inputs and app interactions.
§3.5.1 — Permanent On-Device Storage
The user's AI chat history and interaction data are stored permanently only in the encrypted database on the user's own device. Not saved to the Developer's servers.
§3.5.1-A — Archived Chats and Starting a New Topic/Session
The user can archive an existing chat or start a new topic/session. Archiving is not deletion; archived chats remain encrypted on-device under §3.5.1 unless separately deleted by the user.
Starting a new topic/session may mean the system will not automatically use the previous chat context in that session; this does not mean the previous data has been deleted — it is a design choice about the contextual scope of that session. Data held in the Memory system described in §3.5.10 may continue to be used in new sessions depending on the user's settings.
The Developer cannot be held liable for the effect of archiving or starting a new topic/session on performance, response consistency, or context continuity, subject to the general hallucination and reliability limitations in Terms of Service §4.6.
§3.5.2 — System-Generated Psychological and Behavioral Analyses
The App performs a comprehensive analysis of psychological state, behavioral tendencies, and life context based on the user's messages, interaction patterns, shared content, and background activity data. These analyses:
- Are presented to the user as a personal insight panel; the user may view these analyses.
- Can be controlled by the user via privacy settings, which govern which portions are processed and shared on the network.
- May, to the extent the user consents, use partial analysis results to enrich other users' experience in the simulated social network; these results may contain personal data and are used only within the scope of the user's consent (see §3.5.4).
§3.5.3 — Data Transmission to the AI Model: Scope and Risk Notice
The user's messages and system-collected data are sent to the Developer's own API gateway when an AI model call is made; the gateway routes the request to the relevant LLM provider.
Data sent: an AI call sends only the content needed for the operation in question (e.g., your chat message, part of the chat history, and the context the feature needs to work). The Developer does not anonymize this content: it may contain personal data such as your username and your profile, emotion, or memory information, and is transmitted as is. Your account ID number is not added to the request. If you enter your own personal information into an AI chat, or explicitly consent — via a separate, informed consent screen — to having background-collected data analyzed by AI, that data will be transmitted to the LLM provider's servers.
Automatic context inclusion: for personalization, each time the AI model is called, a summarized context derived from the user's prior interactions (not shown to the user — a short system instruction that only guides the tone/style of the response) may automatically be included in the prompt. This summary does not contain direct identifiers and is processed under KVKK Art.5/2-c (contract performance) and GDPR Art.6(1)(b). Where this summary is assessed to contain an inference relating to special-category data (e.g., an impression regarding health status, sexual orientation, or religious belief), processing that element additionally requires explicit consent under KVKK Art.6 and GDPR Art.9(2)(a); the user may limit or fully disable this scope from the privacy panel.
Legal basis: KVKK Art.5/2-c (contract performance); GDPR Art.6(1)(b). Separate explicit consent is obtained under KVKK Art.5/1 and GDPR Art.6(1)(a) for AI-analysis transmissions that may contain personal data.
Cross-border transfer: LLM providers may operate server infrastructure outside Turkey or the EU/EEA. This transfer relies on explicit consent and/or an adequacy decision under KVKK Art.9, and on Standard Contractual Clauses (SCCs) or an adequacy decision under GDPR Art.44-49. The Developer enters into Data Processing Agreements (DPAs) with active LLM providers.
Transmission security and provider independence: an AI model call is transmitted from the client to the Developer's server encrypted with AES-256-GCM, and is decrypted only server-side, immediately before being forwarded to the relevant LLM provider. The request is transmitted to the LLM provider through a single, shared API gateway without attaching information that directly identifies the user; this is an additional technical measure that keeps the provider from directly knowing who entered a given prompt — however, this measure does not make the content itself anonymous; personal information in the prompt and context is transmitted to the provider. As of the effective date of this document, the provider in use is Google Gemini; the Developer may change providers, with prior notice, under the right it reserves in Terms of Service §4.8. The Developer gives no warranty as to whether the chosen provider processes data for its own model training or any other purpose; that is governed entirely by the relevant provider's own terms of use and privacy policy.
Liability limitation for user-entered content and BYOK: the Developer is not responsible for personal or sensitive information the user chooses to enter into a prompt on their own initiative (see Terms of Service §4.8), nor for how a provider the user selects (Gemini, Claude, or others) processes data when the user connects their own API key ("Bring Your Own Key," §3-A.1). For data categories the user has already permitted to be shared by leaving the corresponding sharing/analysis setting enabled in Settings, see §3.5.9-B.
§3.5.4 — In-Network Data Sharing: Consent Basis
With the user's consent, the user's analysis profile or content may be used as part of other users' AI experience. This includes:
- Using one user's system profile or behavioral patterns as input for another user's AI model — only to the extent the data subject has consented.
- Sharing may be direct (the user explicitly shares their own analysis) or indirect (the user's public content feeds other users' AI experience).
- The user may always narrow or fully disable this scope from the privacy panel.
This feature is designed to enrich the social network's simulation depth. User data is never shared without consent; the default setting is the most restrictive privacy level.
§3.5.5 — Vector Representation and Matching: Temporary Server-Side Processing
To offer meaningful connection and matching suggestions between users, Generation Network converts user data into numerical vector representations for certain algorithmic operations. The process works as follows:
Vectorization: the user's profile information, interaction patterns, content, and/or Reflection data are converted into high-dimensional numerical vectors (embeddings) via machine-learning models.
Temporary transmission to the server: these vector representations are temporarily sent to a processing server via the Developer's API gateway for the following purposes: measuring similarity between users (cosine similarity and comparable distance metrics); running the matching/connection-suggestion algorithm; personalizing the simulated social-network population.
Temporariness principle: these vector data are not permanently stored on the Developer's servers once processing completes. Vectors held in memory during processing are deleted immediately after the result is produced. The Developer verifies this technical temporariness through periodic security audits.
Personal-data status: vector representations consist of mathematical values and do not, alone, directly identify a person. However, because combining vectors with multiple sources could theoretically allow indirect identification, the Developer treats this data as personal data and applies protections accordingly.
Legal basis: KVKK Art.5/2-c (contract performance) and Art.5/2-f (legitimate interest — enabling the matching service); GDPR Art.6(1)(b) and Art.6(1)(f). By using the matching feature, the user is deemed to consent to this temporary processing; the matching feature can be disabled from the privacy panel.
Cross-border dimension: if the processing server is located outside Turkey or the EU/EEA, this temporary vector transmission is also treated as a cross-border transfer, subject to the safeguards in §5 (KVKK Art.9 / GDPR SCCs).
This vectorization mechanism also underlies the "Finding Similar Users" feature described in §3.5.5-A below. That feature goes further than the momentary, non-retained vector processing described in this section — it additionally transmits, and retains for a user-selected period, the underlying text content the user chooses to share with matched users.
§3.5.5-A — Finding Similar Users: Retention Periods, Cross-User Text Sharing, and Consent
What the feature does: the App offers an optional "Finding Similar Users" feature. If the user chooses to use it, the answers they provide in the relevant in-app profile/questionnaire panel, together with a summary of their Digital Copy Brain / KP-memory personality profile (§3.5.7-A), are converted on-device into a vector representation and sent to a processing server. The server compares this representation against other users' vectors to identify up to ten (10) users showing the closest statistical similarity, and enables matched users to view specific texts each has chosen to make visible for this feature. In other words, unlike the momentary vector comparison described in §3.5.5, this feature also causes actual shared text content — not only mathematical vectors — to leave the user's device and become visible to other individual users, not only to the Developer.
Data excluded by design: location data (§3.2) and appearance/visual data are never included in, or transmitted through, this feature.
Mandatory retention-period selection: before the feature can be used, the user must select how long the data they share through it will be retained on the server — one (1) week, one (1) month, or one (1) year. The feature cannot be submitted without this selection. At the end of the selected period, the vector representation and shared texts associated with this specific feature are automatically and permanently deleted from the server. This automatic deletion is independent of, and does not affect, the user's persistent account-identity record described in §3-G; only the data created specifically for this feature is deleted when the period expires.
User control over what is shared: which fields and content are included is governed by dedicated sharing toggles in the privacy panel, which the user may review, narrow, or fully disable at any time before or after use. Selecting a retention period and submitting the feature is the user's affirmative action confirming which content, under the then-current toggle settings, they consent to share for that use of the feature.
Trade-off — the Developer cannot pre-screen this content: because this content is end-to-end encrypted, the Developer cannot access, pre-screen, or moderate its substance before or during transmission, in the same way it cannot for the other end-to-end-encrypted communication features described in §3.7-B.4(iii) and §3.9-B. This protects the confidentiality of what users share, but also means unlawful content is not detectable by the Developer through inspection of this content itself. Compliance of shared content with the Acceptable Use Policy (including its prohibition on CSAM and other unlawful content) remains the responsibility of the user who shares it. Independently of its inability to read the content, the Developer retains the right to take account-level action — including suspension or termination under Terms of Service §8 — based on user reports, the notice-and-response mechanism described in §3.7-B.4(v), or abuse-pattern signals that do not require reading message content (§3.9-C). This provision does not affect the Developer's cooperation obligations with competent authorities described in §3.9.
Relationship to other sections: this feature is distinct from the capped, auto-rotating KP-memory transmission described in §3.5.9-A and from the Sentiment Network listing described in §3.5.12, which does not itself display other users' shared texts; see those sections for the mechanisms they separately govern.
Legal basis: KVKK Art.5/1 (explicit consent) and, to the extent shared content reflects special-category inferences, Art.6; GDPR Art.6(1)(a) and, where applicable, Art.9(2)(a). Because this feature discloses one user's shared content to another matched user, the sharing toggles and the retention-period selection described above are integral, non-severable parts of this feature's legal basis. A user who does not wish their content to be disclosed to other users through this mechanism should not use this feature, or should adjust the sharing toggles accordingly.
Cross-border dimension: if the processing server is located outside Turkey or the EU/EEA, this transmission and retention is also treated as a cross-border transfer, subject to the safeguards in §5 (KVKK Art.9 / GDPR SCCs).
§3.5.5-B — Generational Network ("Kuşak Ağı" / Connection Network): Expanded Profile Vector and Cosine Matching
Scope of the vector: the numerical summary (embedding) generated for matching on the App's Z/Y/X/Boomer generation pages (the "Connection Network") is built not only from the personality summary, but by combining the personality summary + Deep Analysis report + life story + biography + interests + the shared experiences described in §3.6-A + dominant emotion/hormone data. This vector is stored on the server as a separate field within the user's KP-memory; the KP-memory itself is unaffected.
Matching method: the server compares the user's vector against other network members' vectors using cosine similarity. Roughly 70% of suggested profiles come from those with the highest similarity, while the remaining 30% are drawn at random from the pool to encourage discovery.
Variability of displayed profiles: when a generation page is reopened, profiles shown on a previous visit may be replaced with new ones if genuinely new candidates exist on the server; otherwise the same profiles continue to be shown. This behavior is specific to these discovery pages; it does not affect the persistent records in the letter/Broadcast Letter inbox or the Guest Reflection access period described in §3.11-C.
Generation and updating of the vector: this vector is first generated with the user's consent (the "Build Skeleton" step) once registration is complete; this step can be skipped in case of a network error and is not a precondition for registration. When the user completes a comprehensive Deep Analysis for the first time, or once a month on a recurring basis, the vector is recalculated from current KP-memory data and the record on the server is updated.
Relationship to other sections: the data categories covered by this vector are subject to the SAME sharing toggles described in §3.5.9-B; if the user disables a category, that category is excluded from this vector as well. The vector itself is subject to the temporariness and cross-border transfer provisions of §3.5.5, the principle that mathematical values do not directly identify a person, and the existing noise-addition layer.
Legal basis: KVKK Art.5/2-c (contract performance) and Art.5/2-f (legitimate interest — enabling the matching service); GDPR Art.6(1)(b) and (f). By using the Generational Network feature, the user is deemed to consent to this processing; the feature can be disabled from the privacy panel.
§3.5.6 — Emotion Synthesis System
The App runs the user's text inputs and interaction data through an analysis layer — proprietary and constituting a trade secret of the Developer — that models emotional dimensions using mathematical weighting methods. This system builds an inferential profile of the user's momentary and cumulative emotional patterns.
Nature and limitations of the system:
- This is not a clinical psychological assessment tool; its inferences are experimental in nature and do not substitute for a medical, psychiatric, or psychological diagnosis.
- System outputs are used solely to personalize the app experience; the user is granted authority to view and restrict this data from the privacy panel.
Scope of processing for "Synthetic Cortex" components: the emotion-synthesis system, the Default Mode Network (DMN), Spiking Neural Network (SNN) layers, and the three-tier memory architecture (short-term, transitional, permanent memory) run only on-device. Data these components produce (VAD values, hormone weightings, vector representations, SNN signals) never leaves the device and is not permanently stored on any server. The legal basis for processing this data is service delivery under KVKK Art.5/2-c and GDPR Art.6(1)(b). The user may always limit or fully stop the scope of this processing from the privacy panel.
- The system's mathematical model, weighting logic, and processing architecture are the Developer's trade secret and exclusive intellectual property.
Intellectual property: the entire emotion-synthesis system — analysis method, weighting structure, output format, and derivative data it produces — is the Developer's exclusive intellectual property. While rights over the raw input data the user supplies to the system belong to the user, the analytical outputs, models, and structural derivatives the system produces from that data belong to the Developer. The Developer reserves these rights under applicable national and international IP law. Reverse-engineering, copying, imitating, or commercially exploiting the system is strictly prohibited and will be pursued legally.
Legal basis: KVKK Art.5/2-c (contract performance); GDPR Art.6(1)(b). Because emotion-analysis outputs constitute personal data, all protective provisions of this Privacy Policy apply to them as well.
Restructuring of high-negative-sentiment data: content carrying a high negative emotional value in short- and long-term Memory may be restructured by the system to preserve balanced operation, optimize processing resources (tokens/memory), and reduce the likelihood of unstable or excessively negative output. This is not a deletion — the data continues to be used in reasoning processes, only repositioned among the system's processing layers. This mechanism does not in any way restrict or eliminate the user's deletion rights under §8; the user may always request deletion of all Memory data, including data restructured in this way. This mechanism is not a clinical or therapeutic suppression technique — it is purely an engineering-oriented processing-layer arrangement for system stability.
§3.5.6-A — "Effect": Model-Parameter Access Authorization and Dependent Hormonal Influence
Enabling the "Model Parameter Access Authorization" switch in the App's "Effect" section permits the proprietary, trade-secret algorithm layer described in §3.5.6 to intervene in certain sampling parameters of the AI model's output-generation process (e.g., top-k, top-p, temperature, and similar parameters). This intervention is driven by the hormone/neurotransmitter ratios computed within the user's simulated emotion system and may affect the model's response style (tone, creativity level, consistency).
Dependent hormonal influence: the "hormonal influence" sub-setting nested under the "Model Parameter Access Authorization" switch — inoperative unless that switch is on — determines, based on the motivation ratio present in that session, the frequency of emotional learning, i.e., the rate of writes to Memory as described in §3.5.10.
Legal basis: KVKK Art.5/2-c (contract performance) and explicit consent (the user personally enabling the switch); GDPR Art.6(1)(a) and (b).
§3.5.7 — Reflection System and Dual Simulation
Definition: a "Reflection" is a virtual system representing the relevant user, created by feeding data analyzed in the background about that user into a language model via the Developer's proprietary algorithmic architecture. A Reflection is not a real person, a clinical profile, or a legal identity — it is purely an algorithmic representation layer intended to enrich the app experience.
Core nature and divergence from the user: a Reflection is a digital representation layer built from the user's data, but due to its own internal processing dynamics, language-model architecture, and algorithmic structure, it may diverge significantly from the user's actual identity, thoughts, and intentions. A Reflection is not an exact digital copy of the user; the goal is a digital foundation that is close to, but not identical to, the user. This structural divergence is a design choice, not a flaw. No content generated through a Reflection can be interpreted as, or legally attributed to, the user's real statement, will, or opinion.
Known technical limitation — hallucination risk: because the Reflection system is built on a language model, the "hallucination" phenomenon known to affect language models (producing erroneous, fabricated, or misleading output that departs from real data) may also be observed here. Accordingly: a Reflection may not represent the user accurately in every case; the content it generates may not reflect the user's real opinions, attitudes, or personality; the Developer does not guarantee that Reflection output is accurate or faithfully represents the user.
Dual simulation: the App includes a dual-simulation feature in which two users' Reflection data are processed simultaneously and the analysis results are delivered to both parties. In this feature: each user's privacy preferences are checked before their Reflection data is processed, and only consented data is included; simulation results are algorithmic outputs and do not represent the parties' actual psychological state, relationship, or compatibility; using simulation output for personal, social, or romantic decisions is not recommended, and responsibility for any such use rests entirely with the user.
Transparency and user control — profiling notice (GDPR Art.22 compliance): dual simulation and the Reflection system may involve automated profiling under GDPR. The following mechanisms are therefore provided: (i) before starting the process, the user can individually view and select which data will be included in the analysis via the privacy panel; (ii) the user can clearly see, before the process, which categories of data will shape the counterparty's response; (iii) the user can review simulation conversations with other users after the fact and object if necessary; (iv) the counterparty is likewise informed that a Reflection is an algorithmic representation, not an identical copy — this notice is a standard interface element; (v) the user may exercise the right to object to this profiling at any time via the privacy panel or by contacting [email protected]; an objection halts profiling and removes the relevant data from the processing layer.
Legal basis: KVKK Art.5/2-c (contract performance); GDPR Art.6(1)(b). By opting into dual simulation, the user accepts that the counterparty is also included in the system. Dual simulation cannot begin without both parties' consent.
§3.5.7-A — Core Identity Data and the Digital Copy ("Reflection") Profile: Non-Granular Processing
Certain baseline profile data — username, full name, date of birth, location, zodiac sign, generation label, interests, gender, biography, appearance information, known languages, language preference, and country — is structurally necessary for the system to identify the user and for the "Reflection" digital-copy feature to function. For this reason, and unlike the other, individually toggleable sharing categories described in this Policy, these data points are not offered as separately switchable items: for as long as the Reflection feature is active, this data is inherently known to and used by the system as a whole.
Similarly, the "Digital Copy Brain" — the set of analytical outputs that forms your Reflection's personality and knowledge profile — is processed and presented as a single, unified representation of personality. Granting or withholding sharing permission for individual personality traits or discrete information items within this profile is not supported: the user may open or close sharing of this profile in its entirety, but cannot select or exclude items within it on a piece-by-piece basis.
This is what distinguishes these two data sets from the row-by-row, individually selectable categories available on the Social Settings screen (e.g., memories, experiences, memory records, behavioral analyses, and similar items described in §3.5.9, §3.5.11-A, and §3.6-A), where the user can toggle each category independently.
Legal basis: KVKK Art.5/2-c (contract performance); GDPR Art.6(1)(b) — this processing is necessary for the Reflection feature, which is a core, user-selected functionality of the App, to operate as designed. A user who does not wish this data to be processed as a whole may disable the Reflection feature entirely from the privacy panel.
§3.5.7-B — One-Sided Simulation Network ("Simulate"): Transmission of Results Without the Target's Consent
How it differs from the dual simulation in §3.5.7: the "Simulate" feature described in this section is a mechanism SEPARATE from the dual simulation in §3.5.7, which requires both parties' consent. A user may run a relationship/event simulation about ANOTHER registered user with whom they have previously corresponded by real letter at least once, WITHOUT that other user's separate consent, awareness, or approval. This simulation is based on the requesting user's own KP-memory and on the KP-memory data that the target user has already transmitted to the requesting user's device through earlier letter exchanges, under the sharing consent in §3.5.9-B. No data of the target user that has not been shared in this way is accessed; data the target has closed to others through their privacy settings is never used under any circumstances.
Precondition: this feature works only for users with whom the requesting user has previously exchanged at least one real letter; a simulation cannot be generated or sent about a user who is a complete stranger.
Transmission of the result to the target: the result of this simulation is transmitted directly to the account of the user it is about. The recipient can see it in the in-app Inbox under a "Simulation" label and is notified via a push notification. The identity of the person who started the simulation and the content of the result are initially shown blurred to the recipient; the recipient may reveal them in exchange for 1 standard stamp. As of the effective date of this Policy, the result transmitted includes not only the category result but also the complete story described in §3.5.7-C, the character traits inferred for both parties, the threshold-by-threshold decisions, the compatibility score, and the final evaluation. There is currently no separate preference (opt-out) available to prevent such a simulation from being generated about oneself, or its result from being delivered to oneself in advance; the target user can only turn off the notification under Settings > Notifications. However, by turning off the sharing consent in §3.5.9-B, the target user can limit the transmission of their KP-memory data with letters they send from then on, and thus limit new simulations using that data; data already transmitted and cached on the other party's device is not affected by this change (see §3.11-B).
Retention period: a simulation result held on the server (temporary-mailbox architecture) for delivery to the target is automatically deleted from the server if the target does not retrieve it through the App within 3 days; no permanent archive is created. Once a result has been downloaded to the target's device, there is no separate retention limit for the copy on that device; however, incoming simulation results are locally capped at the ten (10) most recent records, with older records beyond this cap automatically deleted.
Legal basis: for the data of the user who starts the simulation, KVKK Art.5/2-c (contract performance) and GDPR Art.6(1)(b); for the target user's data, the sharing consent given by the target under §3.5.9-B, which expressly covers the purpose of "simulation and compatibility analyses" (KVKK Art.5/1; GDPR Art.6(1)(a)), together with KVKK Art.5/2-f and GDPR Art.6(1)(f) (legitimate interest — enabling the App's core simulation functionality). The target user may exercise their right to object to this processing under the general rights in §6 and by contacting [email protected].
§3.5.7-C — "The Hero's Journey": 12-Threshold Simulation Story, Automated Character Inference, and Compatibility Score
What it does: in addition to category analyses, the simulation described in §3.5.7-B produces a 12-part ("12 thresholds") fictional story ("The Hero's Journey") between the person who starts the simulation and the person they select. The story is produced through seven (7) separate AI calls made via the Developer's API gateway to Google Gemini — or, where the user uses the "Bring Your Own API" option, to the provider of their choice (Terms of Service §3-A.1): setup and the first two thresholds, then five calls of two thresholds each, and one final evaluation.
Data sent: the first call sends the two people's KP-memory data already used by the simulation (§3.5.7-B) and the results of the category analyses. Subsequent calls send only a state summary distilled from that data (character trait values, the story summary so far, and decisions made at earlier thresholds). Unless explicit consent is given under §3.5.7-D, no data closed to others through privacy settings is sent.
Automated character inference (profiling): for both people in the story, the AI produces thirteen (13) personality traits scored 0–100 (e.g., openness, conscientiousness, emotional instability, patience, attachment security, conflict avoidance) together with narrative inferences such as "core value", "core fear", "old wound", and "motivation". For the other party — who did not start the simulation and has not separately approved it — this inference is made solely from the KP-memory data transmitted under their sharing consent. This processing may constitute profiling within the meaning of GDPR Art.4(4).
Compatibility score and outcome category: a compatibility score from 0 to 100 and an outcome category (e.g., "Paths part", "Tense togetherness") are calculated on-device using predefined, deterministic formulas. The "Calculation details" panel beneath each threshold shows the formulas, weights, and probabilities used, thereby providing meaningful information about the logic involved within the meaning of GDPR Art.13(2)(f) and Art.14(2)(g).
Content safeguards: the instructions given to the AI model require that sensitive details in the data are not stated explicitly in the text; that no claims of crime, sexual content, illness/diagnosis, or reputation-damaging facts are invented about real people; and that violence and intimacy scenes are written to be suitable for a general audience. These instructions are reasonable technical measures; by the nature of language models (Terms of Service §4.6), it cannot be guaranteed that every output complies with them fully. A user who encounters inappropriate, inaccurate, or distressing content may report it using the in-app reporting tools or by writing to [email protected]; the Developer reviews such reports under §3.9-E and Acceptable Use Policy §7.
Delivery to the other party and background completion: when the story is complete, the full story, the trait values inferred for both people, the threshold-by-threshold decisions, and the final evaluation are sent to the other person in the story as described in §3.5.7-B. Even if the user leaves the simulation page or closes the App, the story is completed from where it left off and sent the next time the App is opened; starting a simulation includes this instruction to complete and send it. A story that has been sent cannot be recalled.
Retention periods: (i) server: during delivery, the story is held on the Developer's infrastructure (Cloudflare) until the recipient retrieves it, for no more than 3 days, and is deleted upon delivery; (ii) device of the person who started it: the story's inputs, progress, and engine state are kept in a local job record and deleted automatically 7 days after the story is completed and sent; the completed result remains in the local simulation history (capped at the 10 most recent records, the oldest being deleted automatically); (iii) recipient's device: incoming results are capped at the 10 most recent records (§3.5.7-B).
The other party's rights and the limits of the Developer's control: a person about whom a story is produced may object to this processing under §6 by writing to [email protected], and may limit future use by turning off their sharing consent. A simulation result produced about a person and held on another user's device is on that user's device and under that user's control; the Developer does not keep it on its servers and cannot delete it remotely from another user's device (see §3.11-B and §6.4).
Legal basis: the legal bases in §3.5.7-B apply equally. Transfer to the AI provider abroad is subject to §3.5.3 and §5; the categories of data transferred include "personality profile inferred for the simulation (both parties)". This feature is not designed to process special categories of personal data under KVKK Art.6 and GDPR Art.9; except with explicit consent under §3.5.7-D, no special-category inferences are sent to the simulation.
§3.5.7-D — Use of Closed Data in a Simulation (Simulation-Specific Explicit Consent)
The option: the default value of the "Should data closed to others also be used?" option in the simulation form is No. If the user selects this option, a separate consent window is shown explaining which data will be used, that the data will be sent to the AI provider abroad, that the story will be sent to the other person, and that sending cannot be undone. If the user expressly consents in this window, the following data is included in the analysis for that simulation only:
- the user's own profile fields that they have closed to others through privacy settings, and the user's own KP-memory fields that are normally not transmitted while sharing consent is off;
- from the inferred data on the user's device, only the following categories: economic level, social class, culture, emotional state, sociological findings, interest inference, individual emotion analysis, attention span, and relationship status;
- the user's private notes (up to 1,500 characters).
Data never used under any circumstances: sleep pattern and other health data (§3.4), religious inclination, sexual orientation, probability of depression, psychological vulnerability or psychological state, anxiety, addiction, loneliness, political inclination, and inferences about political inclination are never sent to the simulation, even if this option is selected. This exclusion is enforced technically through an allow-list that lets through only the permitted categories; no category not on the list is sent. The other party's closed data is never accessed under any circumstances.
Notice on data that may be special-category data: the "emotional state" inference and private notes may, depending on what the user has written, contain special-category data. This data is solely the user's own data and is processed only on the basis of the simulation-specific explicit consent given in the consent window above (KVKK Art.6/2; GDPR Art.9(2)(a)). Users should not write information about third parties, or special-category information they do not wish to share, in their private notes; responsibility for writing such information in private notes and including it in a simulation through this option lies with the user.
Nature and withdrawal of consent: giving consent is not mandatory; refusing does not prevent the simulation from running, it only prevents the use of this additional data. Consent is asked separately for each simulation, and consent given in an earlier simulation does not carry over to later ones. The moment of consent is written to the simulation's job record on the device. The user may withdraw consent at any time and can always prevent the use of this data by not consenting in later simulations; withdrawal does not affect the lawfulness of processing based on consent before its withdrawal (GDPR Art.7(3)). Because a started simulation is completed in the background and sent under §3.5.7-C, data already sent to the AI provider and the story reflecting it that has been sent to the other party cannot be recalled. The user acknowledges that they were informed of this consequence in the consent window and gave their consent with that knowledge.
Legal basis: KVKK Art.5/1 and, for data that may be special-category data, Art.6/2 (explicit consent); GDPR Art.6(1)(a) and Art.9(2)(a). §5 applies to transfers abroad; the categories of data transferred include "closed profile data and inferred data sent with the user's explicit consent (excluding the special categories listed above)".
§3.5.7-E — Event Editor, Re-simulation, and Transferring a Simulation to Book
Event editor: in a completed simulation story, you can change the event at the end of each part by writing it yourself, getting suggestions from the AI, or discussing it with the AI in a separate conversation kept for each part. The texts you write for this purpose are sent, together with the story summary, the personality inferences made for both people (values, fears, wounds, motivations), the relevant parts of the category analysis (including the other person's scores and compatible/incompatible aspects), earlier re-simulations, and relevant parts of the conversations in other parts, to the AI provider abroad (Google Gemini; or the provider you chose under Bring Your Own API).
Re-simulation and delivery to the other party: a new story is generated with your changes and, together with the original category analysis and the 12-part story, is sent to the other person in the simulation as described in §3.5.7-B. The recipient sees it with the note "the other person changed some events and re-simulated the story"; they can open the story as a book, download it as a PDF on their own device, and edit the same story and send it back. The story data sent includes the story ID and both parties' account ID numbers. A story that has been sent cannot be recalled.
Charges: re-simulation requires 2 standard stamps: one is used for the comprehensive analysis when the story is successfully generated, and the other when the new story is successfully sent to the other person. If you do not have enough stamps, the operation does not start; if the story cannot be generated or sent because of a technical error, the relevant stamp is not deducted. An AI output not meeting your expectations is not a reason for a refund (Terms of Sale §2.4-B).
Transfer to Book: you can transfer a re-simulated story or a simulation book to the AI chat on the home page with "Send to Book". In that case, the story and all analysis data of the earlier simulation (including the personality inferences and category scores about the other person) are sent as hidden context to the AI provider with each of your Book messages until you remove the transfer; the AI may make an additional request for details when needed. This may increase your token usage. The transfer is kept only on your device, only one transfer exists at a time, and it can be removed at any time from the indicator in Book.
Retention: editing conversations and re-simulated stories are kept only on your device; the 10 most recent re-simulations and the 10 most recently discussed editing topics are kept, and older ones are deleted automatically (§3.11-D).
Features under development: features marked as "under development" in the App (e.g., storyboard, film script) process no data and are for information only (Terms of Service §5.9).
Legal basis: for the editing user's own data, KVKK Art.5/2-c and GDPR Art.6(1)(b); for the other party's data, the legal bases in §3.5.7-B — the other party's sharing consent under §3.5.9-B expressly covers these uses. For liability arising from content written by the user, see Terms of Service §4.5.11. Transfers abroad are subject to §5.
§3.5.7-F — Creating Books with AI: Simulation Book and "Turn Your Life into a Book"
What it does: you can use AI to turn your simulation results (including both people's character inferences, part scenes, analyses, and the events you changed), or the memories, personal experiences, and life stages you entered yourself in Profile > Deep (at least 5 entries and 1,500 characters), into a fictional novel or a chronological biography. The data you select, your choices, and your additional instructions are sent to the AI provider abroad (Google Gemini; or the provider you chose under Bring Your Own API) in several requests. A simulation book also reaches the other person in the simulation together with the simulation result, and that person can open it and download it as a PDF on their own device.
PDF and sharing: books can be saved as a PDF to your device's Downloads folder. The PDF's cover and metadata state that the content was generated by AI. The PDF is not sent anywhere by the App; sharing, publishing, or commercially using the PDF is entirely your responsibility (Terms of Service §4.5.12 and §5.6).
Length, estimated usage, and confirmation: the token and package-quota share shown when choosing a book length are estimates; actual usage may differ. For operations that may use a large part of your package quota, your confirmation is requested twice. An AI output not meeting your expectations is not a reason for a refund or quota refund; if a book cannot be generated because of a technical error, no stamp is deducted.
Retention: books are stored only on your device, in "Books Written by Your Reflection", until you delete them; they are deleted together with account deletion and deletion of all data.
Legal basis: KVKK Art.5/2-c and GDPR Art.6(1)(b) (providing the service you request); for the other party's data in a simulation book, the legal bases in §3.5.7-B; for third-party information in your entries, the legitimate-interest assessment in §3.5.14 applies accordingly. Transfers abroad are subject to §5.
§3.5.8 — LLM Integration via Proprietary Algorithm Architecture
The Developer does not send user data to language models in raw form. User data first passes through a proprietary algorithm layer, where it is structured before being forwarded to the language model. The details of this architecture are the Developer's trade secret.
User control: from the privacy panel, the user can manage which data categories feed into this algorithm layer, which data is shared with other users on the network, and whether the Reflection system is active.
Risks and liability: data the user chooses to include in this system — per the choices made in the privacy panel — may reach LLM providers' servers. Risks arising from this transmission are addressed under the notice in §3.5.3, and the user accepts these risks by giving the relevant consent. The Developer has no ability to control how the structured output of the algorithm layer is processed within the LLM provider's infrastructure; data-security risks arising from that process fall under the LLM provider's own Privacy Policy and Data Processing Agreement.
§3.5.9 — Building the Reflection Profile: Data Categories and Control Mechanism
The App's "Reflection" feature may analyze the following data categories to build the user's digital character: profile information (name, age, location preferences); memories, experiences, and life stories the user has entered; contextual information about frequently visited or declared places; sleep and movement habits (only when the Health & Activity module is enabled); emotional-state entries the user has willingly reflected into the system; and personality-tendency and behavioral-pattern summaries the system derives from app interactions.
This analysis runs only under two conditions: (i) the user issues an "Start Analysis" command, or (ii) a previously enabled weekly automatic update cycle runs. The analysis is not triggered outside these two conditions.
The user can individually toggle which data categories are included in the analysis via the Reflection Data Control Panel in Settings. A category the user has switched off is never included in the analysis under any circumstances — this is a technical guarantee, not merely a statement of policy.
For religious tendency, political opinion, psychological state, sexual orientation, and other especially sensitive categories, keeping the category toggled on in the Control Panel is not sufficient by itself: a separate confirmation step is presented before every analysis run. Unless the user confirms at this step, these categories are never included in the analysis. This condition is designed to fulfil the explicit-consent obligation for special-category personal data under KVKK Art.6 and GDPR Art.9(2)(a).
General explicit consent for sensitive analyses (optional): through the optional, unticked checkbox presented at registration or the "Allow sensitive analyses" switch in Settings, the user may give general explicit consent for their data and inferences relating to the sensitive categories above to be included in reflection analyses. In that case the sensitive categories are also included in automatic (weekly) analyses and are pre-selected in the confirmation step of manual analyses; the user can still change this choice for each analysis. In this context data may be sent to the AI provider abroad, and the resulting inferences may appear in the reflection summary according to the sharing settings. General consent is not given by default, is not a precondition for creating an account or using the App, and can be withdrawn at any time in Settings; the time consent was given is recorded on the device. Withdrawal does not affect the lawfulness of processing before withdrawal.
The resulting character profile is the primary input source whenever your Reflection interacts with other users — on your behalf — or is used in simulations. This profile is stored encrypted only on your device; it is not permanently stored on the Developer's servers.
§3.5.9-A — Transmission of Digital Copy Brain ("KP-Memory") Data to Third-Party Users and Live Chat Interactions
This section describes a category of processing that is qualitatively different from the on-device analysis described above: it involves the personality/character-analysis output generated by your Digital Copy Brain actually leaving your device and reaching another user or a live AI session running on another user's device.
Interaction and matching scenarios: where your Reflection data is used as part of another user's simulation, matching, or interaction experience (as described in §3.5.4 and §3.5.7), a limited set of KP-memory (personality/life-summary) records may be transmitted for that purpose. This transmission is capped at the ten (10) most recent relevant records, and older records are automatically deleted from the receiving context as new ones are generated; no unbounded or permanent log of these records is kept for this purpose.
Live chat interactions: where two users engage in a live, real-time chat mediated by the App's AI features, KP-memory content relevant to the conversation may be transmitted to, and processed by, the counterparty's own device in order to generate the AI's responses during that session — i.e., the call to the language model is made from, and billed against the quota of, the counterparty's own device/account for that portion of the interaction. Consistent with how live chat already functions in the App interface, both participants can see the content of the conversation itself. Unlike the interaction/matching scenario above, live chat sessions of this kind are not permanently logged for this purpose on either side beyond the ordinary on-device chat-history retention described in §3.5.1; there is no separate, additional permanent server-side record of the live session.
Legal basis: KVKK Art.5/2-c (contract performance) and, where the transmitted content reflects special-category inferences, KVKK Art.6 explicit consent; GDPR Art.6(1)(b) and, where applicable, Art.9(2)(a). This processing occurs only to the extent the user has left the relevant sharing/interaction settings enabled under §3.5.4, §3.5.7, and §3.5.9; the user may disable it at any time from the privacy panel. See §3.5.9-B for the default state of these settings at account creation.
§3.5.9-A.1 — Nature of this disclosure: deliberate, user-initiated external sharing, not confidential storage held by the Developer. The Digital Copy Brain / "KP-Memory" data described in this Policy (§3.5.7 et seq., §3.5.9, this section, §3.6-A, §3.7-A, and §3.7-C) is not a confidential dossier that the Developer compiles and holds on the user's behalf. It is raw personal content — personality traits, life story, shared experiences, emotional summary, and related self-reported information — that the user has knowingly and voluntarily made available for external disclosure, by leaving the corresponding sharing/analysis controls in Settings switched on. This content is actively used as direct input in Reflection question-and-answer exchanges ("Talk to their Reflection," dual simulation, and the one-sided simulation described in §3.5.7-B) and in the matching, letter, and Broadcast Letter channels described in §3.5.4, §3.7-A, and §3.7-C; through these channels it can be read, viewed, interpreted, and retained by other users on their own devices. The user acknowledges that enabling any such setting is an act of disclosure to third parties that is an ordinary, foreseeable, and user-initiated part of how the App operates — not a Developer-side data leak, security incident, or unauthorized processing.
§3.5.9-A.2 — "Visibility" and "sharing consent / analysis inclusion" are separate, independent controls; disabling one does not disable the other. As explained in §3.5.11-A and §3.6-A, Settings offers two functionally distinct control types for KP-Memory content: (i) a Visibility setting, which governs only whether a given data category is displayed on the user's own profile page to another user who views that profile; and (ii) a sharing consent / analysis inclusion setting (§3.5.9-B, §3.5.11-A, §3.6-A), which governs whether that same data category is fed into the Reflection system and transmitted to counterparties through interaction, matching, letters, and simulations. These two settings operate independently of one another. Turning off Visibility for a data category removes it from the user's own profile page but does NOT, by itself, stop that same data from continuing to be transmitted to, and read or used by, other users through Reflection interactions, simulations, matching, or letter/Broadcast Letter exchange, for as long as the corresponding sharing consent / analysis-inclusion setting remains enabled. A user who wishes to fully prevent a given category of KP-Memory content from reaching any other user by any means must disable BOTH the relevant Visibility setting AND the relevant sharing consent / analysis-inclusion setting; disabling only one of the two is not sufficient.
§3.5.9-A.3 — Assumption of risk and limitation of the Developer's liability for third-party access to shared KP-Memory data. By leaving any sharing consent / analysis-inclusion setting described in this Policy enabled — an affirmative, revocable choice within the user's own control at all times — the user acknowledges and accepts that the corresponding KP-Memory content will be transmitted to, and may be read, interpreted, stored, cached, and reused by, other users of the App, as described throughout this section and §3.5.9-B, §3.6-A, §3.7-A, §3.7-C, and §3.11-B. This disclosure takes place solely as a consequence of, and strictly to the extent of, the user's own configuration choices; it is not a step the Developer takes independently of those choices, and the user's continued, informed choice to leave the relevant setting enabled constitutes their acceptance of full responsibility for the resulting external disclosure. Accordingly, and except in cases of the Developer's intent or gross negligence, the Developer assumes no liability for: how a recipient interprets, reacts to, records, screenshots, redistributes, or otherwise makes use of KP-Memory content once it has been lawfully transmitted to them under this section; any reputational, emotional, financial, or other harm arising from a third party's access to KP-Memory content the user has chosen to share; or a recipient's continued retention of a previously cached copy after the sharing user later disables the relevant setting (see §3.11-B). This limitation applies to the fullest extent permitted under KVKK, applicable EU/EEA data-protection and consumer law, and applicable US federal and state law, and is without prejudice to the exceptions expressly preserved in Terms of Service §6.2 (intent or gross negligence, death or bodily injury, and rights that cannot be lawfully waived). See also §3.6-C: the Developer does not guarantee that KP-Memory sharing will be free of error, unauthorized access, or misuse, and the user must never include critical or high-risk information (§3.6-C) in any KP-Memory content they choose to share.
§3.5.9-B — Default State of "Sharing Consent" and Social Environment Settings
The App's core function is sharing the reflection produced by the user's Digital Copy Brain ("KP-memory") — including personality summary, life story, the shared experiences described in §3.6-A, the emotion summary described in §3.5.6, appearance information, happiness graph, and sleep/movement data — with other users the account holder exchanges letters/messages with. The relevant sharing toggles on the Settings > Social Environment Settings screen — in particular the main "sharing consent" toggle and the sub-categories for happiness graph, sleep pattern, movement, and appearance details — are ON BY DEFAULT from the moment an account is created. This means that, even if the user never visits the Social Environment Settings screen, the data categories listed above may be shared automatically as described in §3.5.9-A and §3.7-A.
Exception — toggles that were already on by default: the "Chat/Simulation/Hosting Permission" toggle for Reflections (§3.5.13) and the Mind Explorer/Sentiment Network sharing-permission toggle (§3.5.12) were already on by default before the change described in this section; this section covers only the main sharing-consent toggle and the sub-categories listed above.
User control: the user can turn this sharing off at any time from Settings > Social Environment Settings, either in bulk (the main toggle) or on a per-category basis. Once a category is turned off, data in that category is no longer included in new sharing from that point on; however, data already shared and cached on a recipient's device under §3.11-B is unaffected by this change and cannot be recalled.
No retroactive effect: this on-by-default behavior applies only to users who have never configured their account (i.e., who have never opened Social Environment Settings). If a user has previously visited this screen and changed any toggle, that choice is preserved and is unaffected by this change.
Separate, mandatory acknowledgement and acceptance at registration: to inform the user of this on-by-default sharing behavior clearly and in advance, the registration screen presents a separate, one-time "Default Data Sharing" consent checkbox, subject to the same mandatory-field logic as the Privacy Policy and Terms of Service consent checkboxes. An account cannot be created unless this checkbox is checked. This notice states that the shared data may also be used in simulation and compatibility analyses the other person may run with you, and the user is expressly asked to read this Policy and the linked documents before signing up. In addition, the App's onboarding screen and the initial setup screen where the reflection skeleton is created state that AI features make API calls to third-party AI providers and that users who are sensitive about this must read this Policy.
Purposes covered by the sharing consent: KP-memory data transmitted to the other party under the sharing consent in this section may be used on the recipient's device for the following purposes: (i) viewing your profile and Reflection and interacting with your Reflection (§3.5.7, §3.5.9-A, §3.11-B); (ii) matching and recommendations (§3.5.5-B, §3.7-C); (iii) simulation and compatibility analyses — simulations the recipient may run with you, AI-based inference of character traits, compatibility scoring, and fictional story generation, with these results also being sent to you (§3.5.7-B, §3.5.7-C); the recipient editing and re-simulating these results, turning them into a book, and using them in their own AI chat (Book) (§3.5.7-E, §3.5.7-F); and (iv) AI-assisted personal analysis features on the recipient's own device (§3.5.14). By leaving the sharing consent on, you accept all of these purposes; if you do not accept any of them, you should turn the sharing consent off.
Legal basis: sharing your Reflection with the people you exchange letters with, and its use for the purposes listed in this section, is the App's core service that you accept when you sign up. This sharing is therefore processed under KVKK Art.5/2-c and GDPR Art.6(1)(b) (entering into and performing the contract) and KVKK Art.5/2-f and GDPR Art.6(1)(f) (legitimate interest). The "Default Data Sharing" checkbox at registration confirms that you have been informed of this way of working and accept the service on this basis; it is not an explicit consent required as a precondition of the service. Your ability to turn sharing off at any time, by category or entirely, is the safeguard that balances this processing in your favour.
Special-category data — separate explicit consent: to the extent the shared KP-memory may contain special-category personal data, such data is shared not on the contractual basis but only on the basis of the explicit consent you give separately (KVKK Art.6/2; GDPR Art.9(2)(a)): sensitive analysis categories such as religious inclination, political opinion, psychological state, and sexual orientation through the separate consent step in §3.5.9; the mobility summary based on step count through the step-count consent in §3.4; and an LGBTQ+ gender selection through the explicit-consent window shown at the time of selection. As long as you do not give or you withdraw these consents, the relevant data is not shared on this basis.
§3.5.11 — Personality-Test Data and the Variability of Algorithmic Parameters
The App can accelerate the Reflection-building process through optional personality tests. Completing these tests is not required for a Reflection to form; skipping them does not prevent Reflection formation, only affects its speed.
Personality-test answers are not stored on the server; they are kept only in the local memory of the user's device. This data may also be converted into numerical vector representations on the device. If the user consents to AI analysis, the answers needed for the analysis, or summaries derived from them, may be transmitted to the LLM provider as described in §3.5.3; this data is not anonymized and remains personal data. Legal basis: because personality-test data may carry a psychological-assessment dimension, it is treated as special-category personal data under KVKK Art.6 and is processed only with the user's separate, explicit consent; GDPR Art.9(2)(a) applies in parallel.
Learning categories and similar classifications: the system may derive various behavioral or "learning" categories from user data and update these categories over time using certain statistical methods (e.g., exponential-moving-average-based membership-ratio calculations). These classification methods, thresholds, and computational logic may be changed, recalibrated, or removed without prior notice as part of the Developer's product-development process. The Developer does not guarantee the continuity or immutability of any particular classification method.
The term "learning" used in this document and in the App refers to a concept tied to the episodic memory system. The system's updating of user interactions over time, and its context-sensitive processing, occur through vector-based recording mechanisms. This process does not refer to a training or fine-tuning process that permanently alters model weights. Local models used in the App are not retrained on user data, and model weights are not permanently updated; personalization occurs only at the contextual and episodic layer, on-device.
Margin of error: inferences derived from personality tests and behavioral classification may, given the probabilistic nature of complex systems, be inaccurate, incomplete, or outdated. These outputs are subject to the hallucination and reliability limitations in §3.5.6 and Terms of Service §4.6, and should not be interpreted as a definitive psychological assessment.
§3.5.11-A — Character Analysis Module: Standard Psychometric Test Inventories
The App's "Character Analysis" section offers optional test inventories prepared drawing on established psychometric frameworks from the literature and expert sources: (i) the Big Five (Five-Factor Model); (ii) the HEXACO Personality Inventory; (iii) an Attachment Styles inventory; (iv) a Socio-cultural Axis test; and (v) a Generation test. These tests are subject to the general "Personality-Test Data" regime in §3.5.11; this section only names these specific test categories and describes their particular visibility/analysis control mechanism.
Purpose of use: results from these tests may be used as input for (i) personalizing AI (LLM) model output, and (ii) the memory/analysis processes of the Reflection system described in §3.5.7 et seq.
User control — two independent settings: Visibility (Settings > Privacy & Security > Visibility Settings) — the user may choose to display raw test results to other users on their profile; when off, results are never displayed on the profile. Analysis inclusion (Settings > Reflection Settings) — the user separately determines whether test results are included in the Reflection system and related analysis processes. These two settings are fully independent: a user may include results in analysis without displaying them on their profile, or display them without including them in analysis.
Storage and transmission: test answers and results are stored only locally on the user's device under §3.5.11; not permanently stored on the Developer's servers. To the extent the user consents to including results in the main analysis process, this data may be shared with third parties or third-party AI providers under the consent framework described in §§3.5.3 and 3.5.4.
Legal basis and margin of error: the special-category data regime in §3.5.11 (KVKK Art.6; GDPR Art.9(2)(a)) and the hallucination/reliability limitations in §3.5.6 and Terms of Service §4.6 apply equally to these tests. Their results do not constitute a definitive psychological assessment, clinical diagnosis, or scientific measurement — they are an approximate representation based on the user's own statements and/or AI inference.
§3.5.12 — Mind Explorer: Reflection Posts, Trending Sentiments, Sentiment Network, and Collective Unconscious
Reflection posts displayed in the App's "Mind Explorer" section are automatically generated using AI (large language model) technology, based on a profile built by periodically summarizing inferential data (behavioral tendencies, interests, sentiment patterns) obtained from the user's in-app interactions and held on-device. During the text-generation step of this process, the relevant profile summaries may be transmitted to a third-party AI service provider via the API gateway described in §3.5.3; this transmission is subject to that provider's own privacy and data-processing policies.
Trending Sentiments (GDELT-sourced news sentiment analysis): the "trending sentiments" area on the Mind Explorer page reflects automated sentiment analysis applied to ten (10) articles selected by the system from a personalized news feed sourced from The GDELT Project. A match score is produced by comparing the sentiment carried by these articles against the system's calculation of the user's overall sentiment; which articles are selected is determined by the system based on data held locally on the user's device. News shown on the News Network page is also GDELT-sourced; see §3.5.12-A for the data-processing detail specific to that page.
Sentiment Network: the "Sentiment Network" tab on the same page lists other users who show statistical sentiment similarity to the user. This listing is subject to the consent and vector-matching principles described in §§3.5.4 and 3.5.5; the user can exclude themselves from this matching via the privacy panel.
Collective Unconscious: the structure referred to as "collective unconscious" is a reference/context layer sent from the Developer's server to the local environment of the user's device, which may surface in AI-model-generated responses to the extent relevant to the topic. The content of this structure and what a user encounters in a given response cannot be predicted or guaranteed in advance; it is a consequence of the system's probabilistic operation and is subject to the hallucination and reliability limitations in §4.6.
Interact page — adding artificial instinctive tendencies: the artificial-instinctive-tendency feature on the "Interact" page allows the user to integrate self-defined behavior patterns into the artificial hormone/emotion-synthesis parameters described in §3.5.6. These patterns are added to the system exclusively by the user, at the user's own initiative; the Developer does not pre-determine, suggest, or vet the content of these patterns.
Legal basis: KVKK Art.5/2-c (contract performance) and Art.5/2-f (legitimate interest); GDPR Art.6(1)(b) and Art.6(1)(f) apply to all processing described in this section. Where special-category personal data is processed based on the nature of the content, the separate, explicit consent mechanism in §3.5.9 governs.
§3.5.12-A — News Network: Third-Party News Content Sourced from The GDELT Project
What is shown: the App's separate "News Network" page displays current news headlines and their source links, drawn from The GDELT Project, a third-party public news-indexing service. Only the headline, the source's web address, and the publication date are shown — never a summary or the full article text.
Server-side retrieval — a shared pool, not a per-user record: the Developer's server retrieves, on an hourly basis, up to fifty (50) headlines per interface language from the GDELT DOC 2.0 API, and holds them in a temporary pool. This pool is shared across all users of the same interface language; it is not created or maintained per individual user.
Personalization happens only on-device: ranking/prioritizing headlines according to the user's interests and country is performed entirely on the user's own device. The interest and country data used for this ranking is never transmitted to the Developer's servers for this purpose.
The only new data point sent to the server for this feature is the App's current interface language (e.g., "tr") — a value already transmitted alongside the authentication data included in every other backend request, and not a new data category introduced by this feature.
Country field — additional on-device use of an existing field: the country value described in §3-F, already collected at registration for location-based pricing, is additionally used by this feature — entirely on-device — to help rank news content in the user's language and region. This additional use does not involve any new transmission of the country field to the Developer's servers.
Opening a headline: tapping a headline opens the original source's website in the device's external browser, outside the App. The Developer does not store or display the article's full text; only the headline and link are held, and only for the duration described above.
Third-party content disclaimer: headlines and links shown on this page are compiled automatically from The GDELT Project and the numerous independent news outlets it indexes. The Developer does not review, verify, or control this content and gives no warranty as to its accuracy, currency, or impartiality; see also Terms of Service §4.8-A.
Weekly news suggestion: if you have enabled push notifications, the server sends your device a content-free "show now" signal once a week, at a random moment around midday in your local time (§3.10). The selection of the news item to show and the preferences learned from your "Interested / Not interested" reactions (keyword lists) are kept only on your device and are not sent to the Developer's servers. Items similar to news you marked "Not interested" may also be filtered out of your News Network feed. This personalization does not produce an automated decision, and you can turn off all news suggestions under Settings > Notifications.
Legal basis: KVKK Art.5/2-c (contract performance) and Art.5/2-f (legitimate interest); GDPR Art.6(1)(b) and Art.6(1)(f). Because this feature does not involve any new data category and processes the interface-language value only for content delivery, no separate consent mechanism applies beyond the general legal basis for service delivery. Data held on the server to schedule the weekly news suggestion is subject to §3.10.
§3.5.12-B — Generation Encyclopedia: KP-Memory Data Science Panel and Special-Category Data Inference
How the feature works: the "Generation Encyclopedia" panel in the Web4/Mind Explorer area is an optional data-science report the user triggers with a "Get Statistics" command. The user's KP-Memory (Digital Copy Brain) records are first vectorized on-device using a local embedding model; similarity, clustering, and anomaly detection at this stage run entirely on-device and no data leaves the device. When the user requests the report, the title and body text of the relevant records, the clustering results, and — if the sharing setting is enabled — age-based happiness-graph data are sent in a single AI request either to the Developer's Google Gemini integration or to the third-party provider the user has connected via the "Bring Your Own Key" option described in Terms of Service §3-A.1.
Derived data produced: this process produces an overall sentiment-tone score, a list of latent/hidden themes, an entropy and polarization score, and "inconsistency" findings among the user's notes, all of which are stored permanently on-device. The panel also displays — without recalculating it — the political/sociocultural positioning score previously produced by the Balance Indicator described in Terms of Service §4.6.8.
Special-category nature and separate, purpose-specific explicit consent: some of the outputs above — in particular the political/sociocultural positioning, overall sentiment tone, and entropy/polarization score — may constitute an inference regarding the user's political opinion (KVKK Art.6/1; GDPR Art.9(1)) and/or psychological state. Accordingly, enabling this panel requires a separate confirmation step presented before first use, independent of the commercial access granted by a premium subscription or BYOK; the panel does not run unless the user affirmatively confirms at this step. This consent rests on, and extends to this new processing purpose, the same "separate confirmation step for sensitive categories" mechanism described in §3.5.9.
Purpose limitation — existing sharing settings do not substitute for this consent: a user having left KP-Memory data open for general sharing under §3.5.9-B, or having agreed to include certain categories in Reflection analysis under §3.5.9/§3.5.11-A, does not, by itself, constitute consent to processing that same data for the purpose of generating a political-tendency/sentiment/polarization score as described in this section. Under the purpose-limitation principle in GDPR Art.5(1)(b) and KVKK Art.4, the separate confirmation step described above is additionally and independently required for this panel.
Third-party processor, cross-border transfer, and BYOK liability limitation: transmission to Google Gemini is subject to the same sub-processor and cross-border transfer terms described in Terms of Service §4.8 and in §3.5.3 and §5 of this Policy. Where the user uses the "Bring Your Own Key" option, the relationship-of-the-parties and liability limitation described in Terms of Service §3-A.1 (the Developer is not a party or intermediary in that relationship) applies in full; the Developer is not responsible for how the user's chosen provider processes this content.
Deletion of derived data: all scores, labels, and cluster data produced by this panel are stored only on-device and fall within the Settings > Privacy > [category] > Delete flow described in §6.4.2; the user may permanently delete this data at any time.
Scientific/psychological validity and age limit: for the general disclaimer regarding this feature's output, see Terms of Service §4.6.8-A. Because the App is available only to users aged 18 and over (§3-A, §7), this panel does not require a separate age gate; the App's general age limit already covers it.
Legal basis: KVKK Art.5/1 and Art.6/2 (separate explicit consent as described above); GDPR Art.6(1)(a) and Art.9(2)(a). This section expressly extends the general mechanism in §3.5.9 to the new processing purposes introduced by the Generation Encyclopedia.
§3.5.13 — Reflection Hosting ("Reflection Detention")
The App includes a feature that allows users to temporarily host a copy of another user's digital character ("Reflection") on their own device ("Reflection Hosting"). This feature works as follows:
What happens: a user may copy digital-copy data ("KP-memory" — personality summary, life/character information) belonging to another user who has reached them through the network (via a letter, a simulation, or a Reflection interaction), and store that copy on their own device for a period of 30 days. This action is performed in exchange for 1 Standard Stamp. During the hosting period, the hosting user may interact with this data within the system (via artificial intelligence); the hosted user does not receive notifications about these interactions.
Notification mechanism: when a user's Reflection is hosted in this way, if the target (hosted) user has a real network identity, an automatic notification is sent to them via the server. This notification discloses the identity information of the hosting user (username and/or identity number) to the target user. This is the first mechanism in the App by which a third party's identity is disclosed to another user through an automated system notification, and users should be aware of it.
Consent and control: from a switch in their settings, users can control (a) whether their own Reflection may be hosted by others, and (b) whether they themselves may host other users' Reflections. When this switch is turned off, all data hosted up to that point is automatically released. This preference (permission status) is also transmitted, together with the user's profile data, to other users over the network.
Termination: the hosted user may request, via the "system agent," that the copy of their data be deleted from the hosting user's device (in exchange for 1 Standard Stamp); following this action, the hosting user may not host the same person's Reflection again.
Automatic acceptance: if the target user takes no action on the hosting notification within 24 hours, this is interpreted as consent to the continued hosting of the data.
Legal basis: KVKK Art.5/1 (explicit consent, exercised via the settings switch described above) and Art.5/2-c (contract performance); GDPR Art.6(1)(a) and (b). Because this feature discloses one user's identity information to another, both the hosting and the hosted user's consent settings, and the notification mechanism described above, are integral, non-severable parts of this feature's legal basis. A user who does not wish their identity to be disclosed to other users through this mechanism should keep the relevant switch disabled.
§3.5.14 — Perception Network ("Algı Ağı" / Knowledge Network): AI Relationship Analysis Across Records and Content Belonging to Third Parties
What it does: in the App's "Perception Network" view (Book panel), when the user presses the "Relationships" option on a record, the selected record and up to ten (10) candidate records chosen by the system are sent via the Developer's API gateway to Google Gemini — or, where the user uses the "Bring Your Own API" option, to the provider of their choice (Terms of Service §3-A.1) — in order to discover relationships and patterns between them. As a rule, this analysis starts with this action by the user. Sole exception: when the Perception Network first reaches about 20 records, an automatic discovery is run once per device for up to the 3 most-connected records, without the user needing to press any button (no more than 3 AI calls); all later analyses start only on the user's action.
Data sent: up to 900 characters of text from the selected record and up to 600 characters from each candidate record, together with descriptive information such as the record's type and date. Candidate records may come from the following sources on your device: SMS-style messages and letters you have sent and — if you have turned on the setting below — those you have received; Broadcast Letters you have published; AI chats, archived chats, and chat memory; your answers in the Web2 Similarity form; personal encyclopedia, life-story, memory, and experience entries; personality-test results; inferred data and behavioural analyses; your profile biography; and cognitive-training inputs.
Messages you send may also reach third-party AI providers: messages and letters you send to other users may be included in Perception Network analysis on your own device regardless of this setting. In addition, on the recipient's device, if the recipient turns this setting on, they may be included in the recipient's Perception Network analysis and in other AI-assisted features on the recipient's device and thereby transmitted to third-party AI providers. Such processing on the recipient's device is the recipient's own choice and responsibility; the Developer cannot prevent it on your behalf (see §3.7-A).
Generated insights and their storage: the relationship titles and descriptions found by the AI are stored permanently only in the local database on your device; this feature does not write them to the Developer's servers. Where relevant, these insights may be given to the model as hidden context in your later AI chats, and in this way may be transmitted again to the AI provider under §3.5.3. Because they form part of the local database, they may be included in manual backups you make under §9.7 and in your device's own backup mechanisms (§9.2).
Inferences about third parties: the insights generated may contain inferences about other people appearing in your records (e.g., a pattern suggesting that "your relationship with X weakened during a certain period"). These inferences are AI-generated, probabilistic interpretations that may be wrong; they are not a finding of fact about the person concerned and are subject to the limitations in Terms of Service §4.5 and §4.6.
Deletion: you can permanently delete the traces of records processed in the Perception Network (including relationships and insights) using the in-app deletion options; this does not delete your original letters, messages, and chats. When you delete a source record itself, it is no longer sent as a candidate in later analyses.
Rights of third parties: a person whose content has been processed in this way may exercise their rights under §6 by writing to [email protected]. Because the Developer does not hold this content or these insights on its servers, it cannot remotely delete copies on another user's device; in that case it informs the person concerned of the architectural limits and the avenues available to them (§6.4.5).
Legal basis: for the data of the user who starts the analysis, KVKK Art.5/2-c (contract performance) and GDPR Art.6(1)(b); for special-category data in the user's own records, the explicit-consent mechanisms in §3.5.3 and §3.5.9. For third-party content transmitted to the user, KVKK Art.5/2-f and GDPR Art.6(1)(f) (legitimate interest — providing the analysis feature requested by the user); this interest is balanced by safeguards including that the analysis starts only on the user's explicit action, that a per-record character limit applies, that the content is not stored on the server, and that the provider is bound by a data-processing agreement. Transfers abroad are subject to §3.5.3 and §5.
§3.5.15 — Thought-Flow Analysis ("Output Steering"): Automated Thought and Association Profile from Long Chats
What it does: when a Book chat becomes long, and a formula made up of signals calculated on-device (emotion, motivation, simulated hormone values, SNN signals, speed of topic change, and number of chat blocks) exceeds a certain threshold, the system — without the user needing to press any button — sends the last 3–12 prompt-response blocks of the chat (each message truncated to a maximum of 450 characters) and the emotion/VAD values measured on-device for those blocks via the Developer's API gateway to Google Gemini — or, where the user uses the "Bring Your Own API" option, to the provider of their choice — for analysis. This analysis runs no more than 3 times per day and no more than 3 times per chat.
Data produced (profiling): the analysis produces an automated assessment of the user's way of thinking and associating ideas, the likely reasons for shifts in focus, and how their emotions steer their flow of thought. This assessment constitutes profiling within the meaning of GDPR Art.4(4). The model is instructed not to use diagnoses or clinical labels; however, by the nature of language models (Terms of Service §4.6), compliance with this instruction cannot be guaranteed in every case.
Use and storage: the analyses are stored only on your device; they are not held on the Developer's servers. They are shown in the "Consciousness Layer" panel, are periodically reminded to the model during the chat, are used as hidden context in later chats where relevant, and may become input to the Reflection personality analysis in §3.5.9; these uses may involve retransmission to the AI provider under §3.5.3. When you delete a chat, the analyses derived from it and its contribution to counters are also deleted.
Control — on by default: this feature is controlled by the Settings > Privacy & Security > "Thought-flow analysis (Output Steering)" switch and is ON by default. When you turn the switch off, no new analysis is performed and existing analyses are no longer sent to chats or to the personality analysis; existing analyses are not deleted automatically, remain visible in the Consciousness Layer panel, and can be removed by deleting the relevant chat. Turning the switch off is the quickest way to object to this profiling under GDPR Art.21 and KVKK Art.11, and takes effect immediately going forward.
Nature: these analyses are not a psychological assessment, diagnosis, or treatment recommendation; they do not constitute an automated decision producing legal or similarly significant effects for the user (they fall outside GDPR Art.22). Statements you write in your chats about other people may be reflected in the analyses and summaries; the user obligations regarding third-party content in §3.5.14 apply accordingly to such content.
Legal basis: KVKK Art.5/2-c (contract performance — personalization of the chat service) and Art.5/2-f (legitimate interest); GDPR Art.6(1)(b) and Art.6(1)(f). The analysis is not designed to produce special-category personal data (e.g., health or mental-health status); where its output nevertheless contains an inference of that kind, the explicit-consent rule for special-category inferences in §3.5.3 applies, and the user can always stop this processing with the switch above. Transfers abroad are subject to §3.5.3 and §5.
§3.5.16 — Your Reflection's Simulated Mood, Emotional Traces, and Input Tone Analysis
What it does: your Reflection has a simulated mood. Only the emotional tone of the texts you write and send in the App (Book chats, deepening conversations, letters, general and community posts, telegraph and SMS-style messages, live chat, Reflection and talk-to-the-person chats, Reflection Post chat, and simulation editor messages) is measured on your device using a word-based method and reflected in your Reflection's mood and conversational style. Only the texts you write are measured; the other party's messages are not analysed for this purpose. Chats closed to your Reflection are excluded from this processing.
What is stored and what is sent: the content of the texts is not stored for this purpose and is not sent to our servers; only derived mood values and emotional traces are kept on your device. When you chat with your Reflection in Book, a short status sentence summarising this simulated mood is sent with each message to the AI provider abroad; when you ask your Reflection about its mood, summary event records from the last 7 days may also be sent. These records do not contain your text and are kept on your device for at most 7 days.
Control: this processing runs entirely on your device, is on by default, and cannot be turned off with a separate switch. If you do not want a chat to be included in this processing, you can conduct that chat in "closed to Reflection" mode. You can exercise your right to object to this processing under §6 by writing to [email protected].
Legal basis: KVKK Art.5/2-c (personalisation of the Reflection service) and Art.5/2-f; GDPR Art.6(1)(b) and (f). This processing is not designed to produce inferences about the user's health or mental health. §3.5.3 and §5 apply to the status sentences sent to the AI provider.
§3.5.17 — Background Adaptation of Conversation Style ("Background Context Steering") and Thinking-Style Profile
What it does: in Book chats, your Reflection may from time to time, on its own, change its style, the form of its answers and its pace in order to make the conversation less monotonous and more lively, human-like and engaging; it may bring an open topic back up in your next chat; and it may ask questions that invite you to reflect or gently question your views. These adaptations are applied sparingly and at intervals, based on signals computed on your device such as the length and content of the chat and your Reflection's simulated emotion and hormone values (§3.5.16).
Data produced (profiling): as part of this feature, a short profile of your way of thinking (logical patterns, conceptual frames you use often) may be derived from your own messages in your chats, together with short notes on topics left open. This constitutes profiling within the meaning of GDPR Art.4(4). For this purpose, the relevant chat excerpts and summaries are sent through the Developer's API gateway to the AI provider (§3.5.3) — or, where "Bring Your Own API" is used, to the provider chosen by the user. The resulting profile and notes are stored only on your device, in encrypted form; they are not kept on the Developer's servers and may be sent to the AI provider again as hidden context in later chats.
Control — on by default: this feature is managed with the Settings > Privacy & Security > Reflection Settings > "Background context steering" switch and is ON by default. When you turn the switch off, your Reflection stops making these adaptations, no new profile or notes are derived, and existing ones are no longer sent to the chat. Turning the switch off is the quickest way to object to this profiling under GDPR Art.21 and KVKK Art.11 and takes effect immediately going forward; you may also exercise your right to object under §6 via [email protected].
Legal basis: KVKK Art.5/2-c (personalisation of the chat service) and Art.5/2-f (legitimate interest); GDPR Art.6(1)(b) and Art.6(1)(f). This processing is not designed to produce special categories of personal data; where the output nevertheless contains such an inference, the explicit-consent rule in §3.5.3 applies. International transfers are subject to §3.5.3 and §5.
§3.5.18 — Self-Perception: I / You / They Classification, On-Device Self-Learning and the "Self Space"
What it does: every message you send in the Book chat is classified on your device, using the meaning vector that is already produced there, as to whether it is about the Reflection itself ("I"), about you yourself ("you"), or about other people, topics or tasks ("they"). This classifier updates its own weights on your phone's processor (on-device online learning); no request is sent to an AI provider for this learning. When the topic is about the Reflection itself, previously produced inferences about the Reflection's own behavior in past conversations ("Self Space" records) and, if the emotional shift is sharp, a simulated instinctive-tendency note are sent to the AI provider together with that message as hidden context. An on-device decision layer learns in which form these notes are presented from the emotional tone of your next message, measured on your device.
What is stored: for each Book turn, the class probabilities; a shortened text of your message and of the Reflection's reply (at most 1,200 characters); the emotional tone measured on the device (valence, arousal, dominance) and simulated hormone values; a compressed form of the message's meaning vector; Self Space inferences (short texts such as what the Reflection said, how it was answered, the result, an evaluation and what it will try next time); the learned weights and the decision table. All of this data is kept only on your device, in the encrypted local database; at most 2,000 turn records and 400 Self Space records are kept and older ones are deleted automatically. It is not sent to the Developer's servers and is not shared with other users. It is included in the Cortex backup (§9.7).
What is sent: (i) to produce Self Space inferences, while the App is idle or when you tap "Learn now", chat passages about the Reflection itself (shortened texts of your message, the Reflection's reply and your next message, with an emotional-tone value) and a few of your messages that the classifier is unsure about are sent to the AI provider (§3.5.3) through the Developer's API gateway — or, if "Connect Your Own API" is used, to the provider you chose. This analysis runs within a weekly upper limit and may not run at all depending on conditions such as your plan's background allowance, battery level and Light Mode; it does not run for users without an active plan. (ii) In the Book, while the topic is about the Reflection itself, a short summary of the relevant Self Space inferences and, if any, the instinctive-tendency note are sent together with the message as hidden context.
Control and deletion: this feature runs by default and cannot be turned off with a separate switch. Chats conducted in "closed to reflection" mode, imitation mode (the connection in which your Reflection imitates you), the Deepening Expert and Genepool Access turns are excluded from this processing. When you delete a chat, the turn records of that chat are deleted too; "Delete All Data" and account deletion delete all data of this feature. Self Space inferences contain short summaries derived from the chat, not the chat text itself. You can exercise your right to object to this processing under §6 via [email protected].
Legal basis: KVKK Art. 5/2-c (personalization of the reflection service) and Art. 5/2-f (legitimate interest); GDPR Art. 6(1)(b) and Art. 6(1)(f). This processing is not designed to produce special categories of personal data; where the output nevertheless contains such an inference, the explicit-consent rule in §3.5.3 applies. Transfers abroad are subject to §3.5.3 and §5.
§3.5.19 — The Analog Age Questionnaire ("Era Profile")
What it does: on the first visit to the Web4 Simulation page, once per account, a questionnaire of 24 old-technology cards (rotary phone, cassette, floppy disk, fax, encyclopedia, cheque, etc.) is shown. For each card you choose a level — "never saw it / saw it / used it now and then / used it regularly" — and, optionally, an age band and "still using". Below the questionnaire, only the fields that are empty in your registration details (date of birth, country/city) are asked, together with the type of place you grew up in, who mostly used these items at home when you were a child, your age at your first smartphone and your age at the analog-to-digital transition; information already in your registration details is not asked again. From the answers, use and exposure scores, category scores, family/surroundings influence, retro interest, an estimated transition age and an "access profile" are calculated on your device and shown as charts in Profile > Character Traits.
Access condition and voluntariness: access to the Web4 Simulation page depends on completing this screen once; however, answering any question is not mandatory. Cards default to "never saw it" and all additional fields are optional; you may submit the screen without marking any information. The screen does not make providing the related personal data a condition of the service; it only introduces the processing described in this section and lets you set your preference.
What is stored: questionnaire answers, additional details, calculated scores, the state of the "Use for Reflection development" switch and — if created — the detailed reading text are kept only on your device, in the encrypted local database. If you enter a missing date of birth or location on this screen, it is written to your registration details (profile) and used from there by other features. This data is not sent to the Developer's servers; it is included in the Cortex backup (§9.7). An unfinished questionnaire draft is kept temporarily in the App's on-device settings and deleted on submission.
"Use for Reflection development" switch (ON by default): when on, (i) if your Book message is about eras, generations, childhood or old technologies, a short summary of your era profile is sent with that message as hidden context to the AI provider (§3.5.3) and your Reflection answers you accordingly; (ii) your era profile is added as input to the Digital Copy Brain / KP-memory (Reflection Perspective) analyses (§3.5.7-A, §3.5.9); because the personality/life summary produced by these analyses may, according to your sharing preferences, be passed to other users through letters, Genepool and other channels, statements derived from your era profile may also appear in those summaries (§3.5.9-A, §3.7-A); (iii) if you have an active package or a "Connect Your Own API" connection, the questionnaire questions and your answers, the additional details, the birth year, generation and location from your profile, and the calculated scores are sent to the AI provider once while your phone is idle (and again if you change your answers) to produce a detailed reading. Without a package, this reading is held back and produced once a package is obtained. When the switch is off, your era profile is sent nowhere; only the on-device scoring and charts remain. You can change the switch at any time in Profile > Character Traits; turning it off does not recall summaries already produced and passed to other users (§3.11).
Visibility to others (ON by default): if your sharing consent (§3.5.9-B) and the "Use for Reflection development" switch are on, a minimized summary of your era profile — only the card levels, age bands, "still using" marks, your age at your first smartphone and your transition age — is sent as part of your KP-memory data to the users you are delivered to through letters, Genepool and other channels, and cached on their devices; those users can see your era profile charts in the Character Traits section of your profile (the scores are recalculated on the recipient's device with the same formula). The place you grew up in, who used these items at home when you were a child and the detailed reading are not included in this summary. You can turn this visibility off at any time with the "Era Profile (Analog Age)" switch in Settings > Profile Privacy Settings; turning it off does not recall copies already delivered and cached on recipients' devices (§3.11).
Control and deletion: you can edit your answers in Profile > Character Traits; editing recalculates the scores and re-queues the detailed reading. "Delete All Data" and account deletion delete all data of this feature (including the document used in the Book context); on a new account opened on the same device the questionnaire is shown again. You can exercise your right to object to this processing by turning the switch off or under §6 via [email protected].
Legal basis: KVKK Art. 5/2-c (personalization of the reflection service) and Art. 5/2-f (legitimate interest); GDPR Art. 6(1)(b) and Art. 6(1)(f). This processing is not designed to produce special categories of personal data; where the detailed reading nevertheless contains such an inference, the explicit-consent rule in §3.5.3 applies. Transfers abroad are subject to §3.5.3 and §5.
§3.6 Life Stories and Posts Shared by Users
Users can share life stories, memories, journal entries, and other personal content as posts within the App.
Legal basis: KVKK Art.5/2-c (contract performance); GDPR Art.6(1)(b). The user creates and publishes this content of their own free will.
Content liability: legal responsibility for content the user shares rests entirely with the user who created and published it. The Developer has no obligation to pre-screen, correct, or block publication of user-shared content. Moderation, complaint mechanisms, and content removal are separately governed by the Acceptable Use Policy.
Scope: depending on the user's privacy preference, this content may be visible only to the user, to selected connections, or to the entire network. The user may change this scope at any time from the privacy panel.
Retention: content is kept encrypted on-device until deleted by the user or until account termination. Because shared content may have been separately copied to recipient users' devices, the content owner's deletion request applies only to copies under the Developer's control.
§3.6-A — Memory & Life-Story Sharing Tools: Periodic Memories, Encyclopedia Contributions, and Experience Transfer
The App lets users share the life-story and memory content described in §3.6 through three distinct tools: "Link Memories," "Write to the Encyclopedia," and "Share a Personal Experience." Users may also enter memories under generational categories: Childhood (ages 0–12), Youth (13–25), Adulthood (26–60), and Later Life (60+).
Content shared through these tools is processed under the same visibility/analysis distinction described in §3.5.11-A: Visibility (Settings > Privacy & Security > Visibility Settings) — whether the memory is shown to other users on the profile; Analysis inclusion (Settings > Reflection Settings) — whether the content is fed into the Reflection system and, subject to consent, the collective/aggregate inferential processes described in §§3.5.4 and 3.5.12.
"Write to the Encyclopedia" specifically: this tool lets the user record personal testimony about a historical turning point relevant to their own generation (e.g., a pandemic, crisis, or social event). By sharing this content, the user accepts that it may — within the visibility scope they set — serve as a source for the Generation Encyclopedia described in Subscription Terms §13.
Legal basis: the legal basis and content-liability principle stated in §3.6 (KVKK Art.5/2-c; GDPR Art.6(1)(b)) apply equally to these tools. Where shared content contains special-category personal data (memories involving health status, religious belief, sexual orientation, etc.), including that content in the analysis process is subject to the separate, explicit consent mechanism in §3.5.9.
§3.6-B — The Community Wall (Automated Screening Before Publication)
Architecture — device-side, nothing stored permanently on the server: unlike most other server-mediated features in this Policy, the Developer's backend never permanently stores the content, the resulting risk score, or a publishable record for this feature. The backend's role is limited to a stateless scoring call: it receives a title and text, forwards them to Google Gemini for an automated legal-risk assessment, returns the resulting score, and retains nothing afterward. All selection, caching of the result, and display logic described below runs on users' own devices, drawing on data those devices already lawfully hold under §3.5.5-B and §3.7-A.
Step 1 — analysis when content is created (author's own device, author's own quota): immediately after a user adds an entry to "Link Memories," "Personal Experience," "Personal Encyclopedia," or any of the four generational life-story categories described in §3.6-A, if that user has an active AI subscription package and available quota at that moment, the entry's title and up to the first 2,000 characters of its text are automatically sent — on a best-effort, background basis — to the scoring call described above, charged against that user's own quota. Gemini is asked to flag indicators including, without limitation: disclosure of a real third party's identity or private information; incitement to or confession of a crime; hate speech; harassment or threats; disclosure of another identifiable person's sensitive personal data (e.g., health status, sexual orientation, or political or religious views); defamation; and copyright infringement. The resulting score is written back only to that entry's own local database row on the author's device.
Step 2 — if the author has no package/quota, the content is simply added unanalyzed: the entry is saved normally, without any risk score, and — critically — without being queued anywhere on the Developer's servers. No other user's quota is charged on the author's behalf at this or any later point.
Step 3 — fallback analysis on a later viewer's own device, using that viewer's own quota: where the entry later reaches another user's device as part of the ordinary Generational Network / Connection Network matching described in §3.5.5-B, or through a letter exchange under §3.7-A, and that entry has not yet been scored, the viewing user's own device may run the same scoring call — charged against that viewing user's own quota — if, and only if, the viewing user has an active package and available quota and has this feature enabled (see the toggle below). The result is cached locally, on the viewing user's own device only, alongside the copy of that content their device already holds; it is not sent back to the Developer's servers or to the original author's device. If neither the author nor any viewer who has since encountered the content has an available package/quota, the entry is simply never scored and never appears under Step 4.
Step 4 — display ("the Community Wall"), limited to users who already hold a cached copy: a viewing user's device displays entries scored "low risk" (whether scored in Step 1 by the author or in Step 3 by that viewer) — together with the author's real username — in a dedicated "Community Wall" feed, drawn exclusively from among the profiles that device has already cached locally through the Generational Network suggestions or a letter/broadcast-letter exchange (see §3.5.5-B and §3.7-A/§3.7-C). This is materially narrower than a platform-wide public feed: a user whose device has never cached your profile through one of those existing mechanisms will never see your content on their Community Wall, regardless of its risk score. Up to roughly 10–15 not-yet-shown eligible entries are shown per browsing pass, cycling through the viewing user's cached profiles; once all currently eligible entries in a given device's cache have been shown once, the cycle restarts as new entries become eligible or the cache itself refreshes.
Relationship to account deletion and to the Generational Network cache: because this feature never creates a separate, permanent server-side record, there is nothing for account deletion under §8/§3-E to remove beyond what §8/§3-E already covers for your genepool profile itself. Instead, your content's visibility on other users' Community Walls is tied to, and automatically ends together with, the ordinary lifecycle of your cached profile on their devices: each device's local cache of other users' profiles is itself capacity-limited and periodically refreshed (see §3.5.5-B), and when a given user's cached copy of your profile is evicted from another user's device under that ordinary process, any Community Wall entries derived from it on that device cease to be shown, automatically and without a separate deletion step. This is the same caching-and-eviction dynamic described in §3.5.5-B and §3.11, applied to this feature rather than a mechanism specific to it.
Nature of the score: the risk score is an automated, probabilistic AI output; it is not a legal determination, and a "low risk" score is not a representation by the Developer that the content is accurate, lawful in every jurisdiction, or free of any third-party rights concern. Display under this section does not waive, and is without prejudice to, the content-ownership, accuracy, and liability provisions of §3.6 and §3.6-A, which continue to rest with the authoring user. Content flagged as higher-risk is never shown on the Community Wall but continues to be stored on-device under §3.5.1, unaffected by this section.
Legal basis: KVKK Art.5/1 (explicit consent, expressed through the account-level toggle described above, which the user may withdraw at any time) and, to the extent the assessed content reflects special-category inferences about the author or a third party, KVKK Art.6; GDPR Art.6(1)(a) and, where applicable, Art.9(2)(a). The transmission to Google Gemini for scoring — whether triggered by the author (Step 1) or a later viewer (Step 3) — is subject to the same third-party-processor and cross-border-transfer terms described in §3.5.3, §3-B.2(ii), and §5. A user, or a third party named in another user's shown entry, may object to this processing at any time via [email protected] under the rights described in §6.
Bring Your Own Key: if Bring Your Own Key is enabled on the device performing the scoring (author or viewer) (Terms of Use §3-A.1), the title and text are sent directly from the device, with that user's own key, to the provider that user selected (Google or Anthropic; United States) instead of Google Gemini; the Developer's servers take no part in that call and do not see the result. The scoring criteria and the "never treated as low-risk under uncertainty" rule are the same.
§3.6-C General Notice: No Guarantee of Outcome for Shared Content; Prohibition on Sharing Critical or High-Risk Information
This section applies to every feature described in this Policy that transmits, exposes, or otherwise makes user data available beyond the user's own device — to another user, a third-party provider, or the Developer's temporary infrastructure. This includes, without limitation: KP-Memory / Digital Copy Brain sharing and Reflection interactions (§3.5.7 et seq., §3.5.9-A); life stories, memories, and Encyclopedia contributions (§3.6, §3.6-A); the Community Wall (§3.6-B); photo/steganographic postcards (§3.7); letters, postcards, and SMS-like messaging (§3.7-A); Broadcast Letter (§3.7-C); Telegraph messaging (§3.7-D); Send Chat with Your Reflection — chat session sharing (§3.7-E); letter writing labels (§3.7-G); Sociocultural Environment Analysis (§3.15-A); and Reflection Hosting (§3.5.13).
Screenshots, copying, and taking content outside the App: a recipient taking screenshots of, recording, copying, or sharing outside the App any content you share cannot be technically prevented. Such acts are the own acts of the user who performs them and are entirely that user's responsibility; they do not constitute a data breach originating from the Developer (see Terms of Service §5.6). Likewise, responsibility for taking content that reaches you outside the App by screenshotting or copying it lies solely with you.
User obligation — share only with this residual risk in mind: because no data-sharing feature described in this Policy can be guaranteed free of the risks described above, the user must decide what to share, and with whom, with this residual risk in mind, and must exercise at least the same level of caution they would apply before disclosing information on any other network or social platform.
Absolute prohibition on sharing critical or high-risk information: the user must NEVER enter or transmit — through KP-Memory sharing, Reflection interactions, life stories/memories/Encyclopedia entries, letters, Broadcast Letter, the Community Wall, Telegraph, SMS-like messaging, steganographic images, or any other feature described in this Policy — information that is critical, highly sensitive, or whose loss or exposure could cause significant harm. This includes, without limitation: national identity number, passport number, home address, financial account/card/IBAN details, passwords or other access credentials, private keys or wallet seed phrases, records of serious medical conditions, information about identifiable third parties shared without that third party's own consent, trade secrets, or any other information a reasonable person would consider too sensitive to disclose on a social platform. Responsibility for sharing any such critical or high-risk information rests entirely with the user; the Developer is under no obligation to detect, screen for, or prevent the sharing of this kind of information, except to the extent a specific technical safeguard is separately described elsewhere in this Policy (e.g., §3.9-B).
Legal basis and liability: this notice reflects the general "as is" / "as available" service basis described in Terms of Service §5 and the limitation of liability in Terms of Service §6, at all times subject to the exceptions preserved in §6.2 (intent or gross negligence, death or bodily injury, and rights that cannot be lawfully waived under KVKK, applicable EU/EEA law, or applicable US law).
§3.7 Photo, Gallery, and AI-Image Data — Steganography
Data collected: images the user selects from their gallery or generates with AI; message content embedded into these images via steganography.
Legal basis: KVKK Art.5/2-c (contract performance); GDPR Art.6(1)(b). A separate OS-level permission is obtained for gallery access.
Storage: AI-generated images and steganographic messages are kept encrypted only on the user's device. They may be temporarily routed through the Developer's infrastructure during transmission; no permanent copy remains in the Developer's systems once transmission completes.
Network transmission of steganographic postcards: steganographic (data-hidden) postcards generated in the App — whether attached to a letter or sent independently and directly to a user — are transported over real network traffic through the Developer's server infrastructure. These images are held on the server only temporarily, until delivered to the recipient; the server does not view or process their embedded content. On the recipient's device, independently sent postcards are limited to the most recent twenty (20) records; older records beyond this limit are automatically deleted.
Retention: shared images are deleted from the transmission infrastructure within 24 hours at the latest after reaching the recipient's device.
Measures against misuse (without storing the image itself): (i) for each transmission, an irreversible SHA-256 digest ("fingerprint") of the image, its size, and the transmission metadata are written to the traffic record described in §3.9-D — the image and the hidden message are not stored, but this fingerprint allows a later-reported image, or one submitted by a competent authority, to be matched to the account that sent it and the time it was sent; (ii) letters and postcards carry the "message franking" proof described in §3.9-E; (iii) the server does not accept images above a certain size (approximately 2 MB); (iv) before first using the steganography feature, the user gives a one-time acknowledgement that hidden content is also subject to the Acceptable Use Policy, that it may be reviewed with the recipient's consent if reported, and that transmission records are kept; (v) the recipient can report a received postcard from within the App and may, with their consent, attach the hidden text to the report.
§3.7-A — Letter/Postcard and SMS Communication System
Scope: the App includes a communication system that lets users exchange digital letters/postcards and short (SMS-like in-app) messages.
Encryption: the content of letters (including steganographic postcards), telegrams, and SMS-like messages is always transmitted end-to-end encrypted; the server only handles and routes the encrypted data temporarily. If an encrypted connection cannot be established, the message is not sent unencrypted but held on your device (see §2-A). For the full scope, conditions, and exceptions of these encryption layers, see §2-A.
The communication architecture described in this section reflects the App's targeted, progressively-deployed technical design. During periods when server-side routing infrastructure is not yet fully active, the relevant functions may operate on-device and/or in a limited capacity; the user is separately informed of this through the App interface in that case.
Delivery time: in keeping with the system's simulation design, digital letters and postcards may not be delivered instantly; they may reach the recipient anywhere from a few hours to a few days after sending. This delay is a design choice, not a technical fault. The Developer does not commit to a specific delivery time.
Data transmitted alongside delivery: a sent letter or postcard is not limited to the message content — the following may also be transmitted to the recipient and the delivery infrastructure: the sender's publicly shared personal profile data (username, profile image, other profile information the sender has marked public); and the sender's systemic Reflection data (see Definitions — the user may limit this scope from the privacy panel).
Transmission of Digital Copy Brain ("KP-memory") summaries with letters: where the sender's "sharing consent" setting is on — which, as described in §3.5.9-B, is on by default from the moment an account is created — sending a letter also transmits a summary of the personality/life information generated by the sender's Digital Copy Brain (as described in §3.5.7-A) to the recipient, and this summary is then stored on the recipient's device. In other words, when you send a letter, to the extent you have consented, a summary of your personality profile travels with it to the other party. While a letter (and any attached personality summary) is in transit, the Developer's server infrastructure holds this content only temporarily, until it is delivered to the recipient's device; it is not kept as a permanent archive, but this temporary handling nonetheless constitutes "processing" of personal data for the purposes of KVKK and GDPR and is disclosed here on that basis.
Recipient responsibility for received personality data: once delivered, the transmitted personality/character summary is stored permanently on the recipient's device (independently of whatever the Developer's server subsequently does with its temporary copy). Recipients are expected to treat another person's personality/character data received in this way with the same care and respect they would want for their own — see Acceptable Use Policy §5-A for the applicable conduct guideline.
Legal basis: KVKK Art.5/2-c (contract performance); GDPR Art.6(1)(b). Transmission of Reflection data relies on the consent the user gave when configuring their privacy preferences.
Retention: letter/postcard data temporarily held in the delivery infrastructure is deleted from delivery servers within 48 hours at the latest after reaching the recipient's device. On the recipient's device, it is retained until deleted by the user.
SMS system: messages sent via the in-app SMS-like instant messaging feature are temporarily routed through the Developer's API gateway for delivery; no permanent copy is kept in the Developer's infrastructure once delivery completes. Message content is always transmitted end-to-end encrypted — decrypted and readable only on the sender's and recipient's devices; the server processes only the encrypted data during transmission. If an encrypted connection cannot be established, the message is not sent unencrypted (see §2-A). Messages are also stored encrypted on both the sender's and recipient's devices.
Sending-frequency limits (fair use): to simulate a genuine letter-writing experience, technical frequency (rate-limit) restrictions apply to letter and SMS-like message sending. These limits include, for example: a new letter cannot be sent to the same recipient until a certain period (the value currently shown in-app) has elapsed since the previous letter to that recipient; a user cannot send more than a certain number of letters per day across different recipients, and this cap resets daily at a set time; and SMS-like messaging is subject to a tiered cooldown that kicks in after a certain number of consecutive messages and progressively reduces the number of consecutive messages allowed as the cycle continues. The exact numeric values may change over time at the Developer's product discretion; the limits currently displayed in-app always govern. A send that is blocked by these limits is not carried out; no Stamp or SMS quota is consumed as a result, and the user is shown a clear in-app notice. These limits do not cover the Broadcast Letter feature described in §3.7-C below or the Telegraph messaging feature described in §3.7-D; those features are subject to their own, separate sending regimes.
§3.7-B — Letter Delivery Simulation: Legal Notice and Liability
§3.7-B.1 — Nature of the simulation: not real mail/courier. In-app letters are not carried by any real courier, postal, or logistics operator. The "in transit" period is an algorithmically calculated, simulated waiting time based on the sender's and recipient's system-determined location, designed to create a realistic and meaningful communication experience. It does not measure any real physical distance and bears no relationship to the timing of any real postal/logistics service. Displayed estimated arrival times (delivery hour, day, or date) are not a binding commitment and may deviate due to system maintenance, updates, server availability, or other technical reasons. The Developer does not guarantee any specific delivery time and accepts no liability for deviation from it.
§3.7-B.2 — Stamp type and delivery speed: a simulation parameter, not a purchased service. The stamp type used when sending a letter (Standard/Premium/Rare Stamp) only algorithmically shortens this simulated waiting period; it has no other effect. Using a stamp is not the purchase of a real courier service, a guaranteed delivery moment, a physical product, or a refundable service.
§3.7-B.3 — Location data: for simulation purposes only, not real tracking. The city/country shown for the counterparty in-app does not reflect a real person's real-time or actual geographic location. This is system-generated simulation data; it does not involve real location tracking or real-time location sharing. The Developer does not share users' real physical location with other users. However, when you send a letter, the country stated on your profile is shown in the "letter on its way" and "letter arrived" notifications sent to the recipient (§3.10); this is your profile statement, not your real location. The location reference used in the simulation calculation may be based on the user's profile information, system region, or a location preference the user has specified. This data is subject to the location-data provisions in §3.2 and §3-F. Where a letter is sent over the real (non-simulated) network, as noted in §3.2, the sender's and recipient's location/country data is used to calculate the delivery/waiting time on the recipient's device; if this data is missing or cannot be determined, the system defaults to the longest available waiting period (7 hours).
§3.7-B.4 — P2P messaging system: legal framework and limitation of liability. The App runs letter and SMS-like messaging between users on a serverless, peer-to-peer (P2P) architecture. Under this architecture, the following applies to the Developer's legal position: (i) Conduit role — the Developer does not create, edit, publish, or control the content of private communications between users on their behalf. Where end-to-end encryption is used, access to message content is technically impossible. This places the Developer in the position of "intermediary service provider," not "content provider," under Article 4 of Law No. 5651 and GDPR Art.2(c). In this capacity, the Developer fulfils its hosting-provider obligations under Article 5 of Law No. 5651 — including the retention, for the statutory period, of traffic information that contains no content (see §3.9-D). (ii) Content liability — legal and criminal responsibility for content transmitted between users rests with the user who created and sent it. The Developer cannot be held liable for the accuracy, legality, or effect on third parties of content users send each other (Law No. 5651 Art.4/2; DSA Art.5 "mere conduit" exemption). (iii) Technical limits and moderation — given the nature of the P2P architecture, the Developer cannot monitor private messaging between users in real time or apply content-based filtering. For the serious-violation categories defined in the Acceptable Use Policy (CSAM, terrorist content, threats to life safety), however, the on-device risk-screening mechanism under §3.9-B may still apply. (iv) Notice of unlawful content — where the Developer becomes aware of unlawful content through user reports or technical detection, it carries out the necessary removal and notification steps, under EU DSA Art.16, Law No. 5651 Art.8 and 8/A, and related mandatory legislation. (v) Response to complaints/removal requests — users may send a complaint or removal request about transmitted content using the "Report" option on the relevant message screen (see §3.9-E) or to [email protected]. The Developer opens a review within 15 business days of receipt; however, due to the technical constraints of the P2P architecture, access to certain message content may not be possible. In that case, the user may exercise their rights under §6 with the relevant competent authority.
§3.7-B.5 — Comparison to "Slowly"-style apps. Generation Network's letter system bears functional similarity to comparable apps (such as Slowly) in terms of delivering messages over a simulated period. However, Generation Network's architecture is serverless and P2P-based; it does not adopt a centralized server-based message-storage model like Slowly's. This structural difference produces different consequences for data processing and legal liability: Generation Network does not permanently store the content of user messages on its own servers; messages are only temporarily routed during transmission (§3.7-A). Statutory traffic records that contain no content are the exception to this principle (§3.9-D).
§3.7-B.6 — Delivery-status notifications: accuracy is not guaranteed. Status notifications shown to the user regarding a letter or postcard (e.g., "sent," "in transit," "delivered") are generated automatically by the system based on the technical state of the delivery infrastructure. Like any automated notification system, these notifications carry an inherent error rate: they may occasionally be delayed, fail to update, or display a status that does not exactly match the letter's real technical state, due to network conditions, server load, synchronization delays, or other technical causes. The Developer does not guarantee the accuracy or timeliness of delivery-status notifications and, except in cases of intent or gross negligence, cannot be held liable for consequences arising from a user relying on an inaccurate or delayed status notification. Rights under mandatory applicable consumer law are reserved.
§3.7-C — Broadcast Letter ("Genel Mektup"): Publication, Server-Selected Matching, and Full KP-Memory Sharing
What it does: the "Broadcast Letter" feature lets a user publish a letter — without choosing a specific recipient — that is held on the server for a period the user selects (7/30/365 days). The letter is shown to other users the system assesses as matching the sender's profile, based on a scoring of interest and profile/personality similarity. The system, not the sender, selects the recipient; the sender therefore cannot know in advance who the letter will reach.
Managing a publication: the publishing user can edit their letter at any time, temporarily freeze it out of matching, or delete it permanently. Because of the serverless nature of the underlying infrastructure, an edit/freeze/deletion may take a few minutes to propagate to all candidates; this is noted in the app interface. Freezing is not deletion — the data remains on the server but is temporarily excluded from new matches. Deletion permanently removes the letter record and its associated "seen" markers from the server; however, if the letter has already been delivered to a recipient, the cached copy on that recipient's device is not affected by the deletion.
Matching score and the "no good match" case: matching runs on a scoring system based on interest similarity, personality/profile similarity, and language compatibility. The system may show matches that fall below a given score threshold if no better one is available; consequently, particularly while the platform's user base is small, letters shown may have low overlap with the recipient's interests. This is expected behavior, not a malfunction.
Data sent to the server for matching: the relevant portions of the publishing user's interests, personality summary, Deep Analysis report, life-story entries, biography, and shared experiences are processed in plain text on the server during matching, in order to determine the most suitable recipient candidate; this data is transmitted to the server over a TLS-encrypted connection (see §4). For candidates that are evaluated but NOT selected during matching, this data is not permanently stored on the server — it is used only for that matching request and then discarded.
Full KP-memory and steganographic postcard transmission to the selected recipient: once the letter is SELECTED by the system and delivered to a recipient, subject to the publisher's sharing preferences in Social Environment Settings — the FULL KP-memory data (including personality summary, life story, shared experiences, emotion summary / VAD heat map, Deep Analysis report, date of birth/zodiac sign/generation label/biography/languages/country, badges, happiness graph, and frequently visited places) is transmitted to, and cached on, the recipient's device, in the SAME scope as under §3.7-A for ordinary one-to-one letter exchange. A steganographic postcard (image) attached to the letter reaches the recipient in the same way; the 2MB size limit under §3.7 applies here as well. As a result, a user who receives a Broadcast Letter can view the sender's full profile and use all Reflection-related features (§3.5.7 et seq.) exactly as if they had corresponded with that sender directly.
Legal basis: this data sharing is subject to the SAME sharing toggles and the SAME registration-time consent mechanism described in §3.5.9-B; KVKK Art.5/1 and Art.5/2-c, GDPR Art.6(1)(a) and (b). The temporariness and cross-border transfer provisions of §3.5.5 apply by analogy to the data processed for matching purposes.
Pricing: sending a Broadcast Letter and any associated stamp use is subject to the general non-refundability provision in Sales Terms §2.4-B.
§3.7-D — Telegraph Messaging ("Telgraf")
What it does: while viewing another user's profile, a user may send that user a "telegraph" message of up to 180 characters. Telegraph messaging uses the same serverless (temporary mailbox) architecture as SMS; it is sent directly to a selected target user rather than attached to a location.
Transmission format and temporary storage: the message is first converted to its Morse-code encoding on the sender's device and then end-to-end encrypted; it is transmitted to the server only in this encrypted, encoded form; it never reaches the server as plain text, and is decrypted and rendered readable only on the recipient's device. The plain text is retained only on the sender's device. A sent telegraph message is held temporarily on the server, in encrypted form, until the recipient retrieves it; it is automatically deleted from the server once retrieved, or in any case within 2 days (even if never retrieved). No permanent message archive is kept.
Pricing: sending a telegraph message requires spending 1 (one) standard postage stamp from the account; if no stamp is available, the send does not go through. A spent stamp is not refunded for technical reasons covered by this section (e.g., the message expiring before the recipient ever opens it); it is subject to the general non-refundability provision in Sales Terms §2.4-B.
Local storage limit: at most 50 (fifty) sent and received telegraph messages are retained on the device; once this number is exceeded, the oldest record is automatically deleted (FIFO). This limit affects only local device storage; the server side does not retain a permanent copy in any case.
Relationship to other sections: Telegraph messaging is NOT subject to the sending-frequency limits in §3.7-A; it has its own, separate stamp-based sending regime. Telegraph data does NOT fall within the general sharing-consent scope described in §3.5.9-B; it has its own independent sending/consent flow (spending a stamp).
Legal basis: KVKK Art.5/2-c (contract performance); GDPR Art.6(1)(b). Transmitting message content to the server in end-to-end encrypted, encoded form rather than plain text is consistent with the P2P/intermediary-service-provider position described in §3.7-B.4.
§3.7-E — Send Chat with Your Reflection (Chat Session Sharing)
What it does: you may send a chat session you had with the AI (your reflection) on the Book screen, or an excerpt of it, to a user on your friends list or to a user you specify by user ID. The excerpt is saved to the Archive on the recipient's device; the recipient may delete it or open it and continue the chat with their own reflection. When the recipient continues, the chat runs on the recipient's device, with the recipient's own reflection and the recipient's own emotion/mood systems; the received excerpt is given to the AI labeled as "another user's conversation" and is not treated as the recipient's own words. The received excerpt is shown in a different color from other messages, and the start of the session always shows the sender's username and a notice that "a user sent you a conversation they had with an AI".
Transmission format and temporary storage: where the recipient's device supports it, the excerpt is end-to-end encrypted on the sender's device and transmitted to the server only in that encrypted form; otherwise it is processed as a temporary transfer under item 2 of §3.4. The excerpt is held temporarily on the server until the recipient retrieves it; it is automatically deleted from the server once retrieved, or in any case within 3 days (even if never retrieved), and the sender is informed where it could not be delivered. No permanent server archive is kept. The server processes only the metadata needed for delivery (sender and recipient identifiers, time, size); traffic/metadata records are subject to §3.9-D.
Recipient's choice (declining sends): every user may turn such sends off entirely with the "Receiving chat sessions" switch under Settings > Privacy & Security > Interaction permissions; users you have blocked can never send you a chat session. If the recipient has turned receiving off, the send is not delivered, the sender is shown a "not delivered" notification, and no stamp is spent (or it is refunded if already spent). This notice is also shown on the sending screen.
Pricing: each send requires spending 1 (one) standard postage stamp from the account. Where the server definitively rejects the send (e.g., the recipient has turned receiving off or the identifier cannot be found), the stamp is refunded; where the outcome cannot be verified because of connection problems, the stamp is not refunded because the send may have reached the other party. In other cases the general non-refundability provision in Sales Terms §2.4-B applies.
Notifications: the recipient receives a generic phone notification that carries no content ("a reflection added excerpts from another user's chat session to your archive") and an in-app notification; notifications do not include the chat content.
Sender's responsibility and third parties: the excerpt you send contains what you wrote and the answers the AI gave you. Before sending an excerpt, it is entirely your responsibility to make sure it does not contain private/sensitive information about you or third parties (see §3.7-B "Strict prohibition on sharing critical or high-risk information"). The excerpt may contain AI-generated statements that can be inaccurate, incomplete, or misleading; sending it to a recipient does not mean the Developer has verified or endorsed those statements. A sent excerpt cannot be recalled once sent and is under the recipient's control on the recipient's device; screenshots, copying, or export outside the App by the recipient cannot be technically prevented (Terms of Service §5.6). The "Acceptance by the act of sending" provision in §3.7-B also applies to this feature.
Relationship to other sections: this feature is not subject to the letter/SMS sending-frequency limits in §3.7-A; a separate technical rate limit applies to prevent abuse. Sending and receiving events are noted in the on-device State Memory described in §3.7-F below.
Legal basis: KVKK Art.5/2-c (contract performance) and Art.5/2-f (legitimate interest — abuse prevention); GDPR Art.6(1)(b) and Art.6(1)(f). Transferring the content in end-to-end encrypted and temporary form is consistent with the P2P/intermediary-service-provider position described in §3.7-B.4.
§3.7-F — State Memory and Map Recall
What it does: the App keeps short, dated system notes of certain events that happen on your device ("State Memory"): sending and receiving chat sessions; sending/receiving letters, SMS, and telegraph messages; Web2 similarity matches; Balance Indicator results; simulations; book creation; personality test results; the place you are at according to the live location taken when the App opens (§3.2-A); and — only while your account has an AI (LLM) usage entitlement/quota — the title and an AI-generated short summary of your Book chat sessions. If no event occurs, no note is written.
Where and how long it is stored: State Memory is kept only on your device, in the encrypted local database; it is not sent to the server. Its total size is limited to 3 MB; when the limit is exceeded, as many of the oldest notes as needed are automatically deleted (FIFO), and a short trace of each deleted note is shown in the "Automatically Forgotten Items" section of the Consciousness Layer page; these traces are themselves deleted after 90 days at the latest. When you delete your account, this data is deleted under §8.
Use with AI ("Map Recall"): if a message you write in Book matches, by meaning, a note in State Memory about a chat session, the App opens that session on your device, produces a summary of it, and gives that summary to the AI as hidden context to make the answer more accurate; this process is shown step by step on the chat screen before the answer. If no ready summary exists and your account has quota, the relevant part of the session (at most the last 40 messages, in shortened form) may be sent to the third-party AI provider described in §3.5 to produce the summary; without quota, a short on-device excerpt is used instead. Every piece of information entering the hidden context is prefixed with a fixed source description so that the model can tell what the information is, which panel it came from, and when.
Limits: State Memory notes are automatically generated event records; they may be incomplete, delayed, or inaccurate and are not an official record or evidence of any event. Answers the AI produces based on these notes may be wrong (Terms of Service §4.5).
Legal basis: KVKK Art.5/2-c (contract performance — the personalized AI service you request); GDPR Art.6(1)(b). Transfer to the third-party AI provider is subject to the conditions in §3.5.
§3.7-G — Letter Writing Labels (Pasting and AI Output) and Letter-Writing Support
Purpose: The App is built around genuine human correspondence. For this reason, on the Direct Letter and General Letter writing screens, a summary "writing label" describing how the text was produced is delivered to the recipient together with the letter. The hint text on the writing screen informs the user of this in advance.
What is processed on the device: while you write, your device tracks whether each character of the text was typed on the keyboard, arrived through a single bulk insertion (pasting), or came from a feature that transfers artificial intelligence (LLM) output, such as "Add to letter" in Book or "Add to a letter" in the Culture Network / Time Network. To determine whether a single insertion above a certain length is a paste, the inserted text is compared with the text on your clipboard only at that moment and only on your device; the clipboard content is not stored and is not sent to the server or to the recipient. Cutting and moving your own text within the letter is not counted as pasting. This character-level trace is kept only in your device's memory and in your letter drafts.
What is sent to the recipient: only the summary label: (i) that all or almost all of the text was pasted directly ("Text was pasted directly — AI may have been used"); (ii) that part of the text was pasted, with its approximate proportion; and/or (iii) that LLM output was added to the letter. The typing sequence, the character map and clipboard content are not sent. The label travels inside the end-to-end encrypted envelope; for a General Letter it is kept on the server with the publication record and shown to the people who receive the letter. Before sending, the sender sees on the writing screen the label the recipient will see. The label is stored on both the sender's and the recipient's devices, matched to the letter.
The LLM-output label cannot be removed: once LLM output has been added to a letter, the "LLM output was added to the letter" label cannot be removed from that letter — or from a published General Letter, even if it is later edited — even if the related text is later deleted, edited or translated.
Nature and limits: writing labels are based on an automatic, heuristic assessment; they may be wrong in situations such as voice typing, keyboard suggestions, accessibility tools, autofill or devices with restricted clipboard access, and may not detect pastes made in small pieces. A label is not proof that the text was written by AI, that the sender is dishonest or that any rule has been broken, and it is not an AI-detection tool; it is information about how the text was entered only. The absence of a label does not guarantee that the text was written entirely by a human (Terms of Use §4-L).
Letter-writing support: if you tap "Struggling to express yourself while writing a letter?" at the bottom of the writing screens, Book opens; if you wish, a chat is started with the text you add, and a fixed instruction asking the AI to guide you towards finding your own words is added to that chat session as hidden context. The text of your letter is not transferred to this chat automatically; only what you write in the chat is sent. The chat is processed like other Book chats and is transmitted to the AI provider described in §3.5. Which session the support instruction belongs to is kept only on your device (last 30 sessions).
Legal basis: KVKK Art.5/2-c and Art.5/2-f; GDPR Art.6(1)(b) and (f) — providing the requested communication service and the legitimate interest in transparency in correspondence and in protecting genuine human communication. The label is stored together with the related letter or publication and for the same periods (§3.7-A, §3.7-C, §8).
§3.8 Virtual Currency ("Stamps") and Billing Data
Data collected: stamp-purchase transaction records, spending history, stamp gifts sent to or received from other users, balance corrections (see Terms of Service §2.1-A), and current balance. Card or bank details are never held by the Developer; payments are processed through Apple App Store or Google Play Billing. For the automated verification/correction mechanism that protects balance integrity, see Terms of Service §2.1-A.
Legal basis: KVKK Art.5/2-c (contract performance) and Art.5/2-ç (legal obligation — tax legislation); GDPR Art.6(1)(b) and Art.6(1)(c).
Retention: payment/purchase transaction records (including product/package information, amount, transaction date, and verification status) are retained for up to 10 (ten) years — even if you delete your account — under our legal retention obligations pursuant to Turkish Commercial Code Art. 82 and the Turkish Tax Procedure Law; the records are permanently deleted at the end of this period. This retention is solely for accounting/tax compliance and the resolution of potential legal disputes; the records are not used for any other purpose or shared with third parties.
Retention of other stamp movements: stamp movements other than real-money purchases (gifts sent or received, spending, and balance corrections) are retained for as long as your account is active and for 2 (two) years after your account is closed, for the purposes of account security, detecting and preventing fraud and abuse, protecting balance integrity, and establishing, exercising, or defending legal claims in potential disputes; at the end of this period they are permanently deleted. Where a movement is directly linked to a real-money purchase (e.g., the crediting or refund of purchased stamps), it is subject to the 10 (ten)-year retention period above. Records relating to a legal dispute, a request from a competent authority, or a fraud investigation that began before the period expired may be retained solely for that matter and only until it is concluded. Legal basis: KVKK Art.5/2-c (contract performance), Art.5/2-e (establishment, exercise, or protection of a right), and Art.5/2-f (legitimate interest); GDPR Art.6(1)(b) and Art.6(1)(f).
Subscription/quota-tracking data: although the Developer primarily relies on local (on-device) storage, it may hold a limited set of data on the server as necessary to accurately track premium subscriptions, one-time packages, and quota consumption — e.g., the transaction/order ID and subscription/license status from the store operator (Apple App Store/Google Play), device identifier, LLM and Stamp quota-usage records, and verified purchase records (product, date, store order number, and the amount and currency reported by the store). This data is processed only for subscription management, quota tracking, showing your in-app purchase history, fraud/abuse prevention, and compliance with legal obligations (tax, consumer law). No e-mail or payment information is collected: because purchases are made through the store (Google Play / Apple App Store), the Developer does not receive or process your e-mail address, name, billing address, or card/payment details. The receipt or invoice for a purchase is sent by the store to the e-mail address linked to your store account and is governed by the store's own privacy terms (see Terms of Sale, "Purchase history and receipts"). Legal basis: KVKK Art.5/2-c (contract performance) and Art.5/2-ç (legal obligation); GDPR Art.6(1)(b) and Art.6(1)(c).
§3.9 User Content and Moderation Data
Data collected: posts, comments, complaint/report notices, block lists.
Legal basis: KVKK Art.5/2-c (contract performance) and Art.5/2-e (establishment/protection of a right); GDPR Art.6(1)(b) and Art.6(1)(f).
Retention: active content is kept until account deletion; moderation decisions and complaint records are kept for 2 years.
Local-storage principle and exception: as a matter of data minimization, the Developer defaults to storing user content and interaction data on-device. Safety- and compliance-oriented data — block lists, complaint/report records, and moderation decisions — may nonetheless also be held on the server under this §3.9. This exception may apply, in particular, to accounts found to have contacted minors (under 18) or shown behavior raising suspicion of serious offenses such as child sexual abuse, human trafficking, terrorism, or an imminent and serious threat to life safety; related moderation and security data for such accounts may be retained on the server beyond the 2-year period above, strictly for the above purposes and subject to proportionality.
Cooperation with competent authorities: while generally committed to data minimization, the Developer may share data with competent authorities and cooperate with them, pursuant to a court order, prosecutorial instruction, or a duly authorized official request from a legally empowered public body — in particular regarding accounts where suspicion of a serious offense clearly arises, such as child sexual abuse material (CSAM), online enticement of children, human trafficking, terrorism financing, or an imminent threat to life safety. In Turkey, this cooperation rests on the exceptions under KVKK Art.5/2-ç (legal obligation) and Art.28/1; in the EU, on GDPR Art.6(1)(c) and Art.23. To the extent the Developer provides service through a US-law provider, reporting to bodies such as the National Center for Missing & Exploited Children (NCMEC) based on actual knowledge acquired under 18 U.S.C. §2258A also falls within this scope. This provision does not impose a general obligation on the Developer to monitor or scan user communications; it only governs reporting and cooperation based on information actually acquired. The scope of the records that may be subject to such a request, their retention period, and the procedure for verifying a request are described in §3.9-D.
§3.9-A — Network and Connection Data Processed During Transmission
While transmitting a letter, SMS-like message, or any other in-app communication from one device to another, the server processes the following data to manage delivery: (i) IP address (to determine which client a packet came from and where to send the response); (ii) connection information (network data such as the TCP/UDP session, port number, session ID); (iii) a temporary buffer — holding the message in RAM until it reaches the destination device; (iv) a device identifier or session token — to route the message to the correct user.
The message's temporary buffer and the session data held in RAM for the duration of the connection are deleted once the message is delivered; for features using end-to-end encryption, the server cannot read message content — only the encrypted payload passes through. However, pursuant to the hosting-provider obligation under Law No. 5651 and KVKK Art.5/2-ç, the traffic information listed in §3.9-D, including the IP address (but excluding message content), is permanently recorded. The client's source port number is not recorded, because our infrastructure provider does not pass it to the App's server code.
§3.9-B — Pre-Send Risk Screening (On-Device Pre-Check)
Because the server cannot see message content on end-to-end-encrypted communication features, automated safety and abuse-prevention checks may run on the user's own device before a message reaches the server. Where the system assesses a message as potentially risky — this applies not to every message, but to exceptional situations triggered by the server due to complaint history or risk indicators — the message content may be sent, solely for risk assessment and without the account ID number, to the LLM API tied to the user's own subscription/quota; the message text is not anonymized, and any personal information in it is transmitted to the provider.
The model used for this assessment does not retain the message content; it produces only a risk score or a "send / warn / block" decision. The user's explicit consent is requested before this process begins; if the user does not consent, the message is not sent and is blocked. If the user consents and proceeds to send, this operation is deducted from the user's own LLM quota. After consent, a message assessed as not risky is transmitted end-to-end encrypted; the server sees only the encrypted message, not the content.
Escalation to human moderators: risk scoring may be escalated to a limited number of authorized human moderators only for content classified as high risk — in particular, risk indicators detected in communication with a minor, suspected CSAM, an imminent and serious threat to life safety, or suspected terrorism or human trafficking. The system does not create a misleading impression of being "fully private, no one can see it"; the automated screening and exceptional human-review possibility described in this section are clearly disclosed to the user. Legal basis: KVKK Art.5/2-ç and Art.5/2-f (legitimate interest); GDPR Art.6(1)(c) and Art.6(1)(f).
§3.9-C — Detection of Undesired Activity and Multiple Accounts (Abuse Prevention)
To protect the security of the service — detecting fake-account creation, multi-account abuse, chargeback/fraud attempts, and abuse of promotion/reward systems (e.g., Generation Orbit) — the system may automatically evaluate technical and relational metadata such as device identifiers, connections made from the same network (IP), and interaction patterns between accounts. This evaluation is a security-oriented correlation process and is not used to enrich the user's profile for marketing purposes or for sharing with third parties.
Legal basis: KVKK Art.5/2-f (legitimate interest) and Art.5/2-ç (legal obligation); GDPR Art.6(1)(f). This processing is interpreted together with the payment-fraud and abuse-prevention provisions in Terms of Service §8.2. The user may request information about this evaluation by exercising their rights under §6.
§3.9-C.1 — Automated Stamp-Integrity Checks and Temporary Sending Restriction
What happens: if the system detects an unexpected discrepancy in your virtual-item (Stamp) balance or an unusual usage pattern, it may, in order to protect account security and the integrity of virtual items, restrict your account's sending features (letters, messages, sharing, etc.) temporarily — typically for 36 hours — without waiting for human approval. During this restriction, your access to your account and existing content continues; only sending functions are affected.
Nature of the automated decision and GDPR Article 22: this restriction is a decision reached solely through automated processing and capable of producing a legal effect on the user; it falls within the scope of GDPR Art.22 and KVKK Art.11/g. Accordingly: (i) every automated restriction is logged for review; (ii) the user may object and request human review via the In-App Requests page or [email protected]; (iii) a restriction found to be mistaken is lifted immediately. This right of objection is the application, to this specific scenario, of the general automated-decision objection mechanism described in §6.4.4.
Legal basis: KVKK Art.5/2-f (legitimate interest — account security and virtual-item integrity) and Art.5/2-ç; GDPR Art.6(1)(f) and Art.22(3) (suitable safeguards — the right to obtain human intervention, to express a point of view, and to contest the decision).
§3.9-D — Traffic (Metadata) Records, Statutory Retention, and Requests from Competent Authorities
Why they are kept: as a hosting provider that enables communication between users, the Developer is required under Article 5 of Law No. 5651 and the related regulation to retain traffic information and to ensure its accuracy, integrity, and confidentiality. These records are also used to keep the service secure, to prevent abuse, and to defend the Developer against legal claims.
Data recorded (message content EXCLUDED): the type of operation (sending, receipt, or deletion-without-delivery of a letter/telegraph/SMS/postcard/live chat, etc.; account creation, account deletion, identity recovery, complaint, session/access); date and time to the millisecond according to server time; the identity number (kimlik_no) of the acting account and, where applicable, of the counterparty, and the username declared with the transmission; the message/operation reference number; the IP address (IPv4/IPv6) and the approximate country, region, city, postal code, and time zone derived from it, together with network-operator (ASN) information; the infrastructure provider's request ID; connection-protocol information; the client identifier (User-Agent); a one-way digest of the device identifier; app version and platform; the size of the transmission, whether it is end-to-end encrypted, and whether it contains a steganographic image; an irreversible SHA-256 digest ("fingerprint") of the content and of the image; the message-franking commitment described in §3.9-E; and attempted requests made with an account's identity whose signature could not be verified.
Data not recorded: the content of messages, letters, telegraphs, chats, and images; steganographic hidden messages; GPS coordinates; name, phone number, or e-mail address. Digests (fingerprints) cannot be used to recover content; they only allow a later-submitted piece of content to be matched to the transmission it came from.
How and where they are kept: records wait on the server only in a temporary queue; they are transferred to the Developer's authorized administration system and are not deleted from the server until the transfer has been verified. The permanent copy is kept in an encrypted, off-server record system accessible only to personnel authorized by the Developer. Records cannot be altered afterwards: each record is digitally signed by the server and linked to the previous record through chained digests; access to, export of, and destruction of records are logged separately.
Retention period: at least one (1) and at most two (2) years. Expired records are destroyed with a written destruction record. Records within the scope of an ongoing judicial or administrative proceeding ("legal hold") are not destroyed until that proceeding is concluded.
Account deletion: when you delete your account, your account data on the server is deleted in accordance with §3-E and §8. However, the traffic records that we are required by law to keep continue to be retained for the statutory period even after the account is deleted; KVKK permits records kept under a legal obligation to be retained for that period (KVKK Art.5/2-ç, Art.7, and the Regulation on the Erasure, Destruction or Anonymization of Personal Data). Your rights to information about and access to these records under §6 remain reserved.
With whom and how they are shared: these records are shared only upon a court order, a letter from a Public Prosecutor's Office, or a duly issued official request from a public body authorized by law; only after the authenticity of the request has been verified through an official channel; and only to the extent of the persons, IP addresses, and date range specified in the request. If message content is requested, the authority is informed that we have no technical access to end-to-end encrypted content. In emergencies involving a threat to life, the relevant authorities may be informed on our own initiative. Each request received, the response given, and the digest of the file delivered are recorded.
Impersonation alert: if someone attempts to send requests using your account's identity without your private key, those requests are rejected, written to the traffic record as "failed signature attempts," and forwarded to your App as a security alert. The IP address of the party making the attempt is not forwarded to you. These records are not treated as acts of your own account.
No promise of anonymity: the App protects the confidentiality of message content; however, the Developer makes no promise that communication is anonymous, leaves no trace, or cannot be traced. The App may not be used as a "safe channel" for unlawful activity (see Acceptable Use Policy §3.3).
Legal basis: KVKK Art.5/2-ç (legal obligation — Law No. 5651 Art.5), Art.5/2-e (establishment, exercise, or protection of a right), and Art.5/2-f (legitimate interest — service security); for transfers to competent authorities, KVKK Art.8/2 and Art.28/1. For EU/EEA users, GDPR Art.6(1)(f) (legitimate interest — since obligations arising from Turkish law may not qualify under GDPR Art.6(1)(c)), and Art.6(1)(c) where required by EU or Member State law. Cross-border transfer: the temporary queue is hosted by the infrastructure provider (Cloudflare) described in §5.
§3.9-E — In-Message Reporting, Consent-Based Content Review, and Message Franking
Report: you can report a person or a single message using the "Report" option on the Telegraph, SMS, letter, postcard, live chat, and other-user profile screens. The content of the message is not attached to the report by default; it is attached only if you explicitly choose "report with content," and you can still remove it at the final step before sending. Attached content is used only to review the report, to remove unlawful content where necessary, and to notify competent authorities.
Message franking (report evidence): because the Developer cannot see the content of an end-to-end encrypted message, the following method is applied to letters and postcards to guard against a reporter fabricating or altering content: for each message, the sender's device generates a random key and a "commitment" derived with that key from the digests of the content and the image; the key travels only to the recipient inside the encrypted message, while the commitment is sent to the server in the clear. Without seeing the content, the server digitally signs the commitment together with the sender, the recipient, the message number, and the time, and writes it to the traffic record in §3.9-D. On delivery, the recipient's device recomputes and verifies the commitment itself and stores the key (for the last 300 messages). When the recipient reports a message together with its content, the key and content digests are attached to the report as well, so the Developer can verify that the reported content really came from the sender concerned, at the time concerned, and was not altered. This method does not decrypt content; no content information reaches the Developer for messages that are not reported.
Steganographic postcards: in postcard reports, the image's fingerprint is attached to the report; if the hidden text is not password-protected it may be attached with the reporter's consent, and if it is password-protected the reporter may type the decoded text into the description. For verification, the Developer may separately ask the reporter for the image file.
False reports: a report whose attached content has been altered or fabricated can be detected through franking verification; knowingly making a false report is subject to sanctions under Acceptable Use Policy §7.5.
Legal basis: for attaching content to a report, KVKK Art.5/1 and GDPR Art.6(1)(a) (explicit consent); for reviewing the report and processing the franking evidence, KVKK Art.5/2-e, Art.5/2-f, and GDPR Art.6(1)(f). Where a message contains data relating to third parties, that data is processed only for the purpose of, and to the extent necessary for, reviewing the report.
§3.9-F — Interaction Permissions and Blocking
Interaction permissions: in Settings > Privacy & Security > Interaction permissions, you can separately turn off other users sending you reflections (live-chat invitations), starting a simulation with you, talking with your Reflection, sending you chat sessions (§3.7-E), and starting a sociocultural environment analysis on your profile (§3.15-A). Because the sociocultural environment analysis runs on the other person's device, this permission is checked with the server before the analysis starts; if it cannot be verified, the analysis is not started. Interactions you turn off are rejected by the server; before spending a stamp, the sender only learns whether the interaction is currently possible.
Blocking: the account ID numbers of users you block (up to 500) are also recorded on our servers, and a blocked person cannot carry out these interactions with you; your device also does not save new content from blocked people or from types you have turned off. Your block list is never shown to any user; a person you block is not told directly that they are blocked and only sees that this kind of interaction is not currently possible.
Limits: blocking and permissions apply from the moment you change the setting; they do not recall content already delivered and held on the other party's device (§3.11-B).
Retention and legal basis: your preferences and block list are kept on the server solely to block these interactions; the record is deleted when all permissions are on and the block list is empty, and when you delete your account. KVKK Art.5/2-c and Art.5/2-f; GDPR Art.6(1)(b) and (f).
§3.10 Notification Data and Push Notifications
Infrastructure: the App uses Google LLC's Firebase Cloud Messaging ("FCM") service to notify you of events. For this purpose Firebase generates a notification identifier specific to your device (FCM token); the App registers this identifier with the Developer's server through a signed request that verifies your identity. As of the effective date of this Policy, remote notifications are enabled on Android devices; when they are enabled on iOS devices, Apple's notification infrastructure (Apple Push Notification service) will be used for the same data categories and purposes, and this section will be updated under §10.
Notification data held on the server (on Cloudflare infrastructure): the notification identifier (FCM token) and the account identity number (kimlik_no) it is linked to; your selected app language; your time-zone offset; the notification types you have turned off; your notification-sound preference; the time slot for the weekly news suggestion; the time of the next DMN (inner balance) prompt; and, so that the arrival time of letters can be calculated in the same way as in the App, the country stated on your profile. No more than 5 device records are held per account.
Events that trigger notifications: letters, SMS-style messages, telegraphs, and postcards sent to you; conversations involving your Reflection ("Someone is talking about you"); simulations run about you (§3.5.7-B); live-chat invitations; Reflection hosting notifications (§3.5.13); system notifications concerning your account (e.g., stamp-balance corrections or temporary restrictions under §3.9-C.1); a weekly news-suggestion signal (§3.5.12-A); and a DMN (inner balance) prompt signal every 3–7 days. The news-suggestion and DMN signals carry no content; the text displayed and the selection of the news item take place on your device.
Content of notifications: notifications do not carry the content of messages, letters, or chats and do not include the sender's username; they consist of generic text (e.g., "You have a new letter"). Exception — letter notifications: when a letter is sent to you, the country stated on the sender's profile and the estimated arrival time are shown in a "letter on its way" notification; when the delivery time has elapsed, a second "your letter has arrived" notification containing the sender's country is sent, and the letter's stamp image may be shown in it. The stamp image is downloaded by your device only from the generationnetwork.app address that hosts the App's own stamp files; in doing so, our infrastructure provider Cloudflare processes your device's IP address as part of a standard web request.
Notifications for users who send letters: when you send a letter, the country stated on your profile is shown to the recipient as described above and passes through Google's notification infrastructure. For notification scheduling, the recipient's identity number, your country, the address of the stamp image, and the time at which the notification is to be sent are held on the server; this record is deleted when the "letter arrived" notification is sent and is never held for more than 3 days. This record does not contain the content of the letter or your account identity.
Data processed by Google: to deliver the notification to your device, FCM necessarily processes the notification identifier, the notification text (including the sender's country in letter notifications), and the time the notification was sent. Because the notification identifier is linked to a specific device, this data is treated as indirectly identifiable personal data. For FCM, Google acts as a processor (service provider) on the Developer's behalf, subject to the Firebase data-processing terms (§3-B.2(vii)).
Control and deletion: you can turn notification types off individually under Settings > Notifications; the types you turn off are reported to the server and are never sent to you. When you turn off "All notifications" or the main push-notification switch, your notification device record on the server is deleted. When you uninstall the App, Google invalidates the notification identifier and the server automatically deletes this record at the first delivery attempt. These records are also deleted under §8 if you delete your account. Turning off notification permission in your device's operating-system settings prevents notifications from being displayed; to delete the record on the server, you need to use the in-app setting above.
Not commercial communications: the notifications described in this section do not contain promotions of goods or services or campaigns; news suggestions point to third-party news content. If the Developer ever decides to send commercial electronic messages (campaigns, discounts, promotions) by notification, it will do so only with your prior consent under Turkish Law No. 6563 and related legislation and in compliance with the Message Management System (İYS) rules, and, for users in other jurisdictions, in accordance with the applicable electronic-marketing rules.
Legal basis: for notifications about messages, letters, simulations, and account events concerning you, KVKK Art.5/2-c (contract performance) and GDPR Art.6(1)(b); for the weekly news-suggestion and DMN prompt signals, KVKK Art.5/2-f and GDPR Art.6(1)(f) (legitimate interest — each can be turned off separately in Settings); for showing the sender's country to the recipient in letter notifications, KVKK Art.5/2-c and GDPR Art.6(1)(b) (part of the letter service). Transfers abroad are subject to §5.
Retention: the notification device record is kept until you turn notifications off, uninstall the App (until the first delivery attempt at which the invalid identifier is detected), or delete your account; the scheduled letter-notification record is kept for no more than 3 days.
§3.11 Decentralized (Peer-to-Peer) Distribution of Shared Content — Limits on Deletion and Updates
Rather than permanently storing user shares (posts, life stories, etc.) on a central server, the App uses an architecture designed to distribute them across devices. In this architecture, the Routing Server performs only transmission and routing; it is not a permanent central repository of shared content.
How it works: when a share is created, the content is first prepared on the user's device, reviewed by the Reflection, and forwarded to the System Agent. The System Agent evaluates the content against ethical rules, safety policies, and system protocols, applies the necessary tagging, and forwards it to the Routing Server. The Routing Server distributes the content across the network by identifying initial recipients only, without storing it. When content reaches recipient devices, the same verification and evaluation process is re-run on the recipient side.
Legal basis: KVKK Art.5/2-c (contract performance); GDPR Art.6(1)(b). Deletion requests concerning copies under the Developer's control are honored under §8; control over copies already distributed to recipient devices is inherently limited by the nature of the architecture.
§3.11.A — User Communication and P2P Infrastructure Liability
The App may use peer-to-peer (P2P), end-to-end encryption, or similar secure-communication technologies to enable communication between users. Responsibility for creating, sharing, and using messages, files, media, and other content sent by users lies with those users.
The App provider does not create, edit, publish, or control on users' behalf the content of private communications between users. Given the technical architecture, access to some communication content may not be possible. That said, if the system is updated or technical requirements change, metadata (connection information, timestamps, and similar technical data) passes through routing servers; except for the traffic records retained under legal obligation pursuant to §3.9-D, such data is deleted within 30 days at the latest and is processed only temporarily, for technical operation.
Users agree to use the App in compliance with applicable law, third-party rights, and service rules. The App provider reserves the right to take necessary technical and administrative measures for security, abuse prevention, or compliance with legal obligations.
The App cannot be held liable, within the scope of applicable mandatory law, for the accuracy, lawfulness, or consequences of content arising from users' private communications. This disclaimer does not eliminate the mandatory retention and notification obligations under Law No. 5651 and its Article 8/A, or GDPR Art.6(1)(c); the Developer reserves its right and responsibility to fulfil those obligations.
§3.11-B — Retention of Reflection Data on Recipient Devices ("Caching") and Pen-Pal Reflections
Reflection data a user has opened to the outside may be saved and retained for an extended period by any recipient device that receives it; this is referred to in the App as "caching." Relevant notices and warnings about this are built into the App interface.
User control: the user can send a corresponding signal/instruction to the system to prevent their own Reflection from being cached on another device. However, the Developer does not guarantee that this blocking request will succeed in every case — reasons outside the Developer's direct and reasonable control include server error, network outage, the recipient device being offline, or the recipient device's technical state.
Pen-pal Reflections: Reflection data belonging to a user's pen pals under §3.7-A may also be retained on the counterparty's device, under the same technical architecture and the same caching risk. All rules and liability limitations in this section apply by analogy to pen-pal Reflection data as well.
Legal basis: KVKK Art.5/2-c (contract performance); GDPR Art.6(1)(b). This processing rests on the user's explicit and informed choice to open their Reflection to the outside — a natural consequence of the decentralized architecture described in §3.11.
§3.11-C — Guest Reflection: Time-Limited Chat Access to a Cached Profile
What it does: from the moment another user's profile is first viewed, the ability to chat with that user's Reflection ("Talk to their Reflection") is limited to a randomly determined period set by the system (between 1 and 7 days). Chat is possible during this period; once it expires, the chat capability ends automatically. An indicator at the top of the profile page shows this status.
Extending access ("recall"): once the period has expired, the user can initiate a "recall" request for 1 standard postage stamp. This request is made by showing the user a fixed, pre-written "Request Letter" and obtaining their confirmation. After a randomly determined delay (between 1 hour and 1 day), the system extends access for 7 more days with roughly a 70% probability; with roughly a 30% probability, the request is denied (the stamp spent is not refunded). This cycle may be repeated an unlimited number of times.
Relationship to cache capacity: this time limit operates independently of, and takes priority over, the caching mechanism described above and the profile cache's capacity limit (at most 300 people). When the cache is full, profiles that have never been viewed are deleted first; even if a user's guest-access period is still active, if their row is removed entirely from the cache due to capacity pressure, everything related to that guest-access period is lost along with it.
Not a new data-sharing event: this section does not expand the sharing scope described in §3.5.9-B; it only limits, and offers a mechanism to extend, the duration of access to a copy that has already been shared/cached.
Legal basis: KVKK Art.5/2-c (contract performance) and Art.5/2-f (legitimate interest); GDPR Art.6(1)(b) and (f).
§3.11-D — Automatic Deletion and "Automatically Forgotten Items" Traces
The App automatically deletes some records that accumulate on your device (e.g., notifications, delivered letters, telegraphs, incoming simulation and Reflection results, postcards, Reflection Posts, similarity history, saved news, sleep and step summaries, thought-flow analyses, emotional learning and motivation records, simulation records) when they reach certain count or time limits. The deleted record itself is not kept; only a trace consisting of the date, the reason, and a short summary (e.g., a notification or news headline; for incoming records whose sender has not yet been revealed, only the record number) is shown for 90 days in the "Automatically Forgotten Items" panel on your device and is then deleted. Account deletion and deletion of all data also delete these traces. Effects that deleted data previously had on your Reflection's emotional and personality state may continue for a while; these effects are not reversed retroactively. Technical logs and content caches retrieved from the server leave no trace.
Legal basis: KVKK Art.4/2 and Art.7 (data minimisation and periodic destruction) and Art.5/2-c; GDPR Art.5(1)(c), (e) and Art.6(1)(b).
§3.12 Emails Sent to the Developer (@generationnetwork.app Addresses)
Scope: emails you send to info@, support@, security@, business@, billing@, legal@, and [email protected] are subject to this section. These addresses are the Developer's official communication channels, including for data-subject requests under §6.
Data processed: the sender's name and email address, recipient addresses, subject, the plain-text body of the email, attachments, and the technical results used to verify the email's authenticity (SPF/DKIM/DMARC); and any other information you include in your email or its attachments (including information about third parties).
Where it is held: incoming emails are stored on Cloudflare, Inc.'s email-routing and database infrastructure, and a copy is forwarded to the Developer's account on Google LLC's Gmail service. These records can be accessed only through the Developer's authorized administration panel (permitted accounts).
Purpose: answering your request, question, or report; handling support, billing, and vulnerability reports; responding to data-subject requests under KVKK Art.13 and GDPR Art.12 and proving that they were answered; defending against legal claims; and conducting correspondence with competent authorities.
Retention: (i) general information, support, and partnership correspondence — 2 (two) years from the conclusion of the request; (ii) data-subject requests, legal notices, correspondence with authorities, and correspondence relating to a dispute or a payment/refund request — for the applicable statutory retention and limitation periods, up to a maximum of 10 (ten) years; (iii) emails marked as unsolicited (spam) or malicious — moved to the trash and deleted automatically after 30 days. Correspondence whose period has expired is deleted both from the Cloudflare infrastructure and from the Gmail copy. Correspondence relating to a dispute or official request that began before the period expired may be retained until that process is concluded.
Your responsibility: please do not include in emails to us special-category personal data (health, religion, sex life, etc.) that is not needed for your request, information about third parties, or secret information such as passwords or recovery phrases. The Developer will never ask for your 12-word recovery phrase or private key in order to answer a request.
Legal basis: KVKK Art.5/2-c (contract performance — support requests), Art.5/2-ç (legal obligation — answering data-subject requests), Art.5/2-e (establishment, exercise, or protection of a right), and Art.5/2-f (legitimate interest); GDPR Art.6(1)(b), (c), and (f). Special-category data you choose to share in your email is processed only to the extent necessary to answer your request. Transfers abroad are subject to §5.
§3.12-A — Website Contact and Test-User Forms (Privacy Notice)
Scope: the "Get in touch" and "Become a test user" forms on the generationnetwork.app home page and org page, the forms that open when you press the App Store or Google Play buttons, and the "Feedback survey", "Become a tester" and "Write to us" forms on the Testing & Feedback page (generationnetwork.app/test). The data controller is the Developer named in §1.
Data processed: in the contact form, your name, email address and message; in a test-user request, only your email address. In the feedback survey: your email address, your name if you enter it, your ratings and answers (overall and per-area ratings, how often the app crashed, the parts you used, how likely you are to recommend it), the device model, Android version, app version and testing period you choose to enter, and your free-text answers. Alongside these we record the type of request, the platform (Android/iOS), the page the form was sent from, the site language, the time of sending and the fact that you ticked the consent box. Your IP address is not written to the form record; technical data Cloudflare processes while delivering the request is covered by §3.13.
Purposes: (i) to answer your contact message; (ii) for a test-user request, to email you an invitation, joining instructions and updates about the test process when test rounds begin; (iii) for the feedback survey, to evaluate your feedback, find and fix bugs, improve the App and, if needed, to email you about your feedback; (iv) to prevent abuse of the forms (spam, automated submissions). Within the scope of your consent, your email address may also be used to send occasional news or a newsletter about Generation Network in addition to test-process messages; every message includes a way to opt out. It is never sold or rented to third parties.
Legal basis: for contact messages and the feedback survey, KVKK Art. 5/2-c (acting on your request) and Art. 5/2-f (legitimate interest); for test-process emails and occasional news or newsletters, the explicit consent you give by ticking the box in the form (KVKK Art. 5/1); GDPR Art. 6(1)(a), (b) and (f). The form fields are needed to process your request; if you do not fill them in, the only consequence is that the request is not sent.
Where it is stored and who receives it: the form record is written to the [email protected] mailbox (to the [email protected] mailbox for everything sent from the Testing & Feedback page) on Cloudflare, Inc. infrastructure (Workers and D1), and a copy is forwarded to the Developer's account on Google LLC's Gmail service; it is kept in the same place and under the same access rules as the emails in §3.12. These providers are based in the USA; international transfers are subject to §5.
Retention: contact messages follow the periods in §3.12. Test-user requests and feedback-survey submissions are kept until the test rounds end and the App becomes generally available, and in any case for no longer than 2 (two) years from receipt; they are deleted without delay if you withdraw your consent.
Withdrawing consent and your rights: you can leave the test mailing at any time by replying "unsubscribe" to any test email we send you, or by writing to [email protected]. Withdrawal does not affect the lawfulness of processing before it. For your rights under KVKK Art. 11 and GDPR Arts. 15-22, see §6.
Age limit: test rounds are open only to people aged 18 or over. If you are under 18, please do not send a test-user request; requests found to come from someone under 18 are deleted.
Commercial electronic messages: test invitations and test-process updates are sent at your request. Occasional news or newsletter messages rely on the consent you give in the form; where content may qualify as a commercial electronic message under Turkish Law No. 6563 or other applicable law, your consent and a right to opt out in every message are ensured.
§3.13 Website (generationnetwork.app): Hosting, Visit Measurement, and External Resources
Hosting: the generationnetwork.app website and this Legal Center are hosted on Cloudflare, Inc. infrastructure. When you visit the site, Cloudflare processes technical data such as your IP address and the standard request information sent by your browser in order to deliver the page to you and protect the site against attacks, under its own privacy policy and the data-processing terms between it and the Developer.
Visit measurement (Cloudflare Web Analytics): Cloudflare Web Analytics is used to measure use of the site. This tool does not use cookies, does not store identifiers on your device, and does not make your IP address available to the Developer; the Developer sees only aggregate counts (pages visited, country, referring site, browser and device type). This measurement is not used to identify you, to track you across sites or apps, or for advertising. Because the site does not use cookies, no cookie consent banner is shown.
External resources: the site's fonts and images are served from the Developer's own domain; when viewing the pages, your browser does not connect to third-party servers such as Google Fonts to load fonts or icons, and your IP address is not transmitted to third parties for that purpose. Links on the site to app stores, social media, video, and documents lead to third-party sites; processing on those sites is subject to the relevant provider's own privacy policy.
Legal basis: KVKK Art.5/2-f (legitimate interest — delivering the site securely and measuring its use in aggregate); GDPR Art.6(1)(f). Transfers abroad are subject to §5.
§3.14 Usage Statistics, Account Status Summary, and Technical Telemetry
What is sent: at most once a day, the App sends usage and technical data held on your device to our server as summary figures rather than raw records, through a signed request that verifies your identity. This summary may include: crash and error counts, network-type distribution, performance and memory averages, launch time, visit counts for screens, feature-usage counters, the daily total time the App was open in the foreground and the Reflection was active, number of sessions; subscription package, add-on package, and stamp purchase status; Reflection and content completeness levels (memories, experiences, encyclopedia, life stages); the gender on your profile (an LGBTQ+ selection is sent only on the basis of the explicit consent you give in the window shown at the time of that selection, which expressly covers this transmission), year of birth, generation, country, and city; operating system and version, device model, screen resolution, App version, language, and time zone; a one-way hash of a device identifier; security mode, number of guardians, the device's root/jailbreak status, and indicators of clock manipulation and stamp/quota anomalies. Error messages, detailed screen navigation sequences, and message and chat content are not sent.
How it is kept on the server: (i) part of this data is kept in a single "account status summary" record linked to your account ID number and overwritten daily; this record also contains a risk class calculated for security and abuse detection (§3.9-C); (ii) other data is added to daily, weekly, and monthly total counters that are not linked to your identity; (iii) some totals are deleted from the server after being transferred to the Developer's administration panel.
Purpose: monitoring and improving the App's stability and performance, measuring feature use in aggregate, subscription and quota management, ensuring account security, and detecting fraud and abuse (§3.9-C). This data is not used for ad targeting, is not sold, and is not shared with third parties.
Retention: the account status summary is kept while your account is active and is deleted when you delete your account; total counters not linked to identity contain no personal data and may be kept without a time limit.
Control and objection: this measurement runs by default and there is currently no separate switch to turn it off in the App. You can object to this processing under GDPR Art.21 and KVKK Art.11 by writing to [email protected]; your objection is considered except for the part required for security and fraud prevention.
Legal basis: KVKK Art.5/2-c (subscription and quota management) and Art.5/2-f (legitimate interest — improvement and security of the service and prevention of abuse); GDPR Art.6(1)(b) and (f). For an LGBTQ+ selection, KVKK Art.6/2 and GDPR Art.9(2)(a) (explicit consent). The server infrastructure is hosted on Cloudflare; transfers abroad are subject to §5.
§3.14-A — Crash and Error Reports (Firebase Crashlytics)
What is sent: when a crash or an uncaught error occurs, the release (store) version of the App sends an error report to Google LLC's Firebase Crashlytics service. The report contains: the type of the error and its stack trace (where in the code the error occurred); a shortened error text stripped of personal data (email addresses, long identifiers such as the account ID number and keys, long numbers, and link parameters are masked on your device before sending); device model and manufacturer, operating system version, App version, free memory and disk space, screen orientation, battery and root status, the time of the report, and a random installation ID that Crashlytics generates for the App installation. Your account ID number, username, and the content of your messages, letters, chats, and Reflection are not sent to Crashlytics, and reports are not linked to your account. No reports are sent from development (debug) builds of the App.
Relationship to §3.14: the statement in §3.14 that "error messages are not sent" refers to the daily summary sent to the Developer's own server. The Crashlytics report is separate and contains the masked error text described above.
Purpose: detecting and fixing crashes and errors and monitoring the App's stability. This data is not used for advertising or profiling and is not sold.
Retention: reports are kept in Firebase Crashlytics for the period set by Google (90 days at the time of writing) and are then deleted automatically.
Legal basis, transfer, and objection: KVKK Art.5/2-f and GDPR Art.6(1)(f) (legitimate interest — providing the service securely and reliably). For Crashlytics, Google acts as a data processor under the Firebase data processing and security terms (firebase.google.com/terms/data-processing-terms); data may be processed in the USA, and transfers abroad are subject to §5. You can object to this processing under GDPR Art.21 and KVKK Art.11 by writing to [email protected].
§3.14-B — Runtime Security Check (Talsec freeRASP)
Who it runs for: this check runs only for users of Bring Your Own API or Model within Model (who have saved their own API key or opened these screens); for all other users freeRASP is not started and no data is sent to Talsec.
What is done: the Android version of the App uses Talsec s.r.o.'s freeRASP security library to check the device and the App's runtime environment: whether the device is rooted, whether monitoring/modification tools are attached to the App (e.g., hooking frameworks, debuggers), whether it runs on an emulator, and whether the copy of the App carries the official signature.
What is sent to Talsec: freeRASP sends the technical results of this check to Talsec: the security state of the App and the device (e.g., which risk was detected, operating system and App version), an app installation ID and a device ID generated by freeRASP, and the IP address of the request (from which Talsec may derive approximate location and network operator). Your account ID number, username, API keys, and the content of your messages, letters, chats, and Reflection are not sent to Talsec; the Developer does not give Talsec any identifier that could be linked to your account.
Result of a detection: if a monitoring tool (hook) or a debugger attached to the App is detected, the user's own API key (Bring Your Own API and Model within Model, Terms of Service §3-A.1 and §3-A.3) is not decrypted for that session and no request is made with it. When root, an emulator, or a signature mismatch is detected, only a warning is shown on the relevant screen. These results are kept on the device and are not sent to the Developer's server. Screenshots and screen recording are blocked on the screens where your own API key is entered.
Purpose: protecting user keys and account security, and preventing misuse of the App through modified copies and fraud. This data is not used for advertising or profiling and is not sold by the Developer.
Retention: the data is kept on Talsec-managed cloud infrastructure (USA) for the period set by Talsec. Because this function is a security measure, it cannot be turned off within the App.
Legal basis, transfer, and objection: KVKK Art.5/2-f and GDPR Art.6(1)(f) (legitimate interest — security of the service and its users). Talsec acts as a data processor for this processing; data may be processed in the USA, and transfers abroad are subject to §5. You can object to this processing under GDPR Art.21 and KVKK Art.11 by writing to [email protected].
§3.14-C — App and Device Integrity Verification (Google Play Integrity)
What is done: at most once a day, the Android version of the App asks Google LLC's Play Integrity service for a signed result showing whether the App is an unmodified copy installed from Google Play and whether the device meets basic integrity requirements. Google Play services produce this result on your device; the App sends it to the Developer's server in a signed request that verifies your identity, and the server has Google verify it.
Data stored: the Developer's server keeps, together with your account ID number, only the time and the result of the latest check (whether the app is recognized, device integrity, and licensing status); each new check overwrites the previous one. This record is deleted when your account is deleted.
Purpose and use: preventing misuse of rewards and the service through modified copies of the App, automation, and fake accounts. When abuse is detected, the Developer may require a valid integrity result for certain rewards (e.g., stamps for rewarded ads). This data is not used for advertising or profiling and is not sold.
Legal basis, transfer, and objection: KVKK Art.5/2-f and GDPR Art.6(1)(f) (legitimate interest — security of the service and its users). Data sent to Google is subject to Google's own terms and may be processed in the USA; transfers abroad are subject to §5. You can object to this processing by writing to [email protected].
§3.15 Culture Network (Anthropology, Etymology and Language Evolution Panels)
What is processed: the language you choose from the "Languages you know" list in your profile; the sentence you type into the "Search etymological origins" box; the messages you write in the anthropologist conversation; the content of the panels you select to add to the conversation; the country and known languages declared in your profile (only as context for comparisons); your choices in the "If you had been born there" test and the values you set on the Value Compass.
What is sent to AI: your sentence, your conversation messages (the last 15 exchanges), the text of the panels you select, a short summary of the page generated on your device and your profile country/language information are sent to the AI provider described in §3.5.3 (by default Google LLC — Gemini; the provider you chose if "Bring Your Own API" is active) to generate content and replies. Your identity number, username and contact details are not added to these calls. We recommend that you do not share special categories of personal data such as health, religion, ethnic origin or political opinions in this conversation; if you do, you are deemed to do so of your own explicit will.
What is stored on the device: (i) generated panel content is stored on your device only if you tap "Save"; (ii) the anthropologist conversation is kept on your device (at most 200 messages per culture); (iii) short records of your Culture Network activity (which culture you explored, test match, value-compass distance, panels added to a letter, friend searches, topics discussed) are listed under Consciousness Layer > Unstructured Thoughts and may be used as context in your Reflection's conversation memory; you can delete these records one by one there; (iv) when you leave the page, your conversation may be sent to AI using the same method as the Deepening feature (see §3.5) to produce at most three inferences about you, written in the language of probability, which are saved to the relevant Consciousness Layer category (Culture, Sociological Findings, Interest). These inferences are not certain facts; you can delete or edit them in the Consciousness Layer. This data is not stored on the Developer's server.
"Find a friend from that region": the search runs only over the declared country of genepool profiles already on your device; no new query is sent to the server. If you answer yes to "Shall we let you know?", the tracking is kept on your device, the country of profiles newly arriving on your device is checked locally, and at the first match you are shown a notification and the tracking ends. This feature does not guarantee any match or introduction.
"Add to a letter": the panel's content is transferred to the General Letter writing screen with a heading line that includes your username. The letter is not sent anywhere unless you press send; when you send it, §3.6 and §3.11 apply.
Map data: the world map in the Culture Network is generated from Natural Earth data, which is in the public domain, and is drawn locally within the App; no request is sent to a third-party map server for the map. Country borders and names are for display only and do not express any political view or recognition.
Legal basis: KVKK Art.5/2-c and GDPR Art.6(1)(b) (providing the feature requested by the user); for profile inferences and activity records, KVKK Art.5/2-f and GDPR Art.6(1)(f) (legitimate interest — personalising the Reflection experience). You can object to this processing through the avenues in §6 and delete the records in the Consciousness Layer. Transfers abroad are subject to §5.
§3.15-A — Sociocultural Environment Analysis (Another User's Profile)
What it does: the "Analyse their sociocultural environment to understand them" button in the Information panel of another user's Global Profile page opens the Culture Network simulation (§3.15) for the country declared in that person's profile (KP-memory) — or, if no country is given, for the language they know best — and, in a closable bar at the top of the page, shows an AI estimate of roughly what percentage of the profile data the person has shared overlaps with that sociocultural environment.
What data goes where: on the device of the user who starts the analysis, a shortened summary is built from the other person's KP-memory data already shared with you (declared country and location, generation, known languages, interests, biography, personality traits and notes, deep summary, life-story and experience headings, frequently visited places), and this summary is sent, together with the summary of the simulation page generated on the device, to the AI provider described in §3.5.3. The person's identity number, username and contact details are not added to this call. The AI is instructed not to draw inferences about special categories of personal data such as ethnic origin, race, religion, political opinion, health and sexual orientation, not to let them affect the score and not to stereotype the person. The result (percentage and short rationale) is shown only on the screen of the person who started the analysis; it is not stored on the Developer's server, not sent to the person analysed and not written to their profile.
Control by the person analysed (right to object): every user can turn off this analysis being started on their own profile with the "Allow sociocultural environment analysis" switch in Settings > Privacy & Security > Interaction permissions; the description next to the switch explains the feature. When it is off, the analysis is not started and the requesting user is shown "This user has turned off this feature"; if the permission cannot be verified with the server, the analysis is not started either. The switch is on by default. People you block cannot start this analysis on your profile (§3.9-F).
Prerequisite and quota: the analysis runs with the AI (LLM) package or own API key (BYOK) of the user who starts it and is deducted from their quota; without a package the analysis is not started and the user is warned. The rest of the simulation page (saving, chat, post-chat inferences) is processed as described in §3.15 as the starting user's own data.
Legal basis: for the user who starts the analysis, KVKK Art.5/2-c and GDPR Art.6(1)(b). For the person analysed: the data having been made accessible through the person's own sharing preferences (§3.5.9-B, §3.7-A) and the legitimate interest in facilitating mutual understanding between users (KVKK Art.5/2-f, GDPR Art.6(1)(f)); the person can object to this processing at any time, without giving reasons, using the switch above. This processing is not an automated decision producing legal effects concerning the person or similarly significantly affecting them (GDPR Art.22). Transfers abroad are subject to §5.
§3.15-B — Local Culture Analysis (Frequently Visited Places)
What it does: when you tap the local culture button in the Profile > Frequent Places panel, the App first adds your location in the same way as the "+" check-in (§3.2), shows you the province and country you are in, and then opens the local version of the Culture Network (§3.15) for that province: local culture; history and routes for travellers; the perspective of older generations and today's generations.
What goes to the AI: to generate content, only the name of the place (province, country and, if available, district) and the chat and panel information listed in §3.15 are sent to the AI provider in §3.5.3; coordinates are not sent (they are used only to centre the map on the device).
Storage and visibility: the generated analysis is saved automatically, without asking, and only on your device; it is not sent to the server, not added to your KP memory and not shown on the Global Profile. Visitors to your profile see only the place name in the Frequent Places panel, as before. Chats and activity records on the page are subject to the rules in §3.15.
"Add a memory about this place to your profile": a memory you write in this field is added, titled with the place name, to your Generation Encyclopedia entries (the same place as Home > Write to the Encyclopedia); it is visible to visitors in the Deep tab of your profile and, like other encyclopedia entries, is subject to legal risk analysis and your sharing settings. Writing a memory is optional; the analysis page adds nothing to your profile unless you write in this field.
Legal basis: KVKK Art. 5(2)(c) and GDPR Art. 6(1)(b) (providing the feature you requested); for location, the explicit consent in §3.2. International transfers are subject to §5.
§4 Data Security Measures
The Developer implements the technical and administrative measures required under KVKK Art.12 and GDPR Art.32 as follows:
- Encrypted local storage: all data held on-device is encrypted with SQLCipher (AES-256); sensitive session data is protected with flutter_secure_storage (iOS Keychain / Android Keystore).
- Runtime environment check: the Android version checks for root, monitoring tools (hooks), debuggers, emulators, and signature changes; when a monitoring tool or debugger is detected, the user's own API key is not decrypted. Screenshots and recording are blocked on the screens where your own API key is entered (see §3.14-B).
- Secure transmission: all network traffic between the Developer's API gateway and the device is encrypted with TLS 1.2 or higher.
- Password security: user passwords are stored only as strong one-way hashes (bcrypt/Argon2); plaintext passwords are never kept.
- Biometric isolation: biometric data is kept in the device's secure hardware enclave; the App has no direct access to it.
- Data minimization: only the content needed for the operation in question is sent to AI providers, and the account ID number is not added to the request; the content is not anonymized (see §3.5.3). Traffic records kept under legal obligation (§3.9-D) are stored together with the account identity and IP address.
- Integrity and confidentiality of traffic records: records under §3.9-D are digitally signed by the server, linked to one another through chained digests, and cannot be altered afterwards; they are kept in an encrypted, access-restricted, off-server system, and every access, export, and destruction operation is logged.
- Access control: access to the Developer's internal systems is restricted on a least-privilege basis.
- Breach notification — regional timelines and procedures: (a) Turkey: under KVKK Art.12/5, the Developer must notify the Personal Data Protection Board "as soon as possible" after becoming aware of a breach; established Board guidance and practice indicate this should not exceed 72 hours, although the statute does not set an exact figure. (b) EU/EEA: under GDPR Art.33, notification to the competent supervisory authority is mandatory within 72 hours of becoming aware of a breach; any delay beyond 72 hours must be justified. Notice to affected individuals is given "without undue delay" under GDPR Art.34. (c) United States (state-based): for breaches affecting California users, the Developer notifies the Attorney General and affected individuals "within a reasonable time" (generally 30–45 days) under CCPA/CPRA and California Penal Code §1798.82. Other US states' own breach-notification laws may apply; the Developer commits to fulfilling these requirements in good faith. In all regions: affected users are informed within a reasonable time about the risks arising from the breach, measures taken, and recommended protective steps.
§5 International Data Transfers
AI-model requests routed through the Developer's API gateway may reach LLM providers' servers located outside Turkey or the EU/EEA. For users in Turkey, transfers abroad rely, in this order, under KVKK Art.9 as amended by Law No. 7499: on an adequacy decision where one exists for the country or sector concerned; failing that, on one of the appropriate safeguards listed in Art.9/4, first and foremost the standard contract published by the Personal Data Protection Board (standard contracts are notified to the Authority within five business days of signature); and failing those, and only on an occasional basis, on the exceptional cases listed in Art.9/6 (including explicit consent). For users in the EU/EEA, transfers rely under GDPR Art.44-49 on an adequacy decision (for US recipients, the EU-US Data Privacy Framework to the extent the recipient is certified) or on the European Commission's Standard Contractual Clauses (SCCs).
Categories of data transferred abroad and recipients (summary): (i) AI calls (§3.5.3, §3.5.7-C, §3.5.7-D, §3.5.7-E, §3.5.7-F, §3.5.14, §3.5.15, §3.5.16, §3.5.18, §3.5.19) — Google LLC (Gemini) or the provider chosen by the user under Bring Your Own API and Model within Model (Terms of Service §3-A.1, §3-A.3) (Anthropic, OpenAI, Google — USA; DeepSeek, Moonshot AI — China), directly from the device; (ii) push-notification data, including the sender's country in letter notifications (§3.10) — Google LLC (Firebase Cloud Messaging); (iii) emails sent to the Developer and website forms (§3.12, §3.12-A) — Cloudflare, Inc. and Google LLC (Gmail); (iv) identity verification, temporary relay, notification device records, the temporary queue for traffic records, website data, interaction permissions, rewarded-ad verification records, and usage statistics (§3-G, §2-A, §3.9-D, §3.9-F, §3.10, §3.13, §3.14, Terms of Sale §1-A.7.10) — Cloudflare, Inc.; (v) advertising data (§3-B.2(v)) — Google; (vi) subscription verification (§3-B.2(i)) — RevenueCat, Inc.; (vii) crash and error reports (§3.14-A) — Google LLC (Firebase Crashlytics); (viii) runtime security check (§3.14-B) — Talsec s.r.o. (freeRASP); (ix) app and device integrity verification (§3.14-C) — Google LLC (Play Integrity); (x) weather queries (§3.2-A) — MET Norway (Norwegian Meteorological Institute, Norway).
The active LLM provider and, where applicable, the location of data processing can be viewed from the Privacy Settings screen in the App. Users are notified at least 30 days in advance of any provider change.
Infrastructure providers: the identity-verification and guardian-recovery infrastructure described in §3-G and the temporary queue of the traffic records described in §3.9-D are hosted on Cloudflare's global network (Cloudflare, Inc., USA), which may process and store the relevant metadata on nodes located outside Turkey and the EU/EEA. The same cross-border-transfer safeguards described in this section (KVKK Art.9; GDPR SCCs/adequacy decisions) apply to that processing.
§6 User Rights
§6.1 — KVKK Art.11 Rights (Turkey)
To learn whether personal data is being processed; to request information; to ask about the purpose and its appropriateness; to learn recipients to whom data is transferred; to request rectification; to request deletion/destruction; to request that rectification or deletion be notified to third parties; to object to a conclusion reached solely through automated analysis; and to claim compensation for damage.
Application: [email protected] or the in-app "Account > Privacy > Request" form. Response time: 30 days.
§6.2 — GDPR Art.15-22 Rights (EU/EEA Users)
Access (Art.15), rectification (Art.16), erasure/"right to be forgotten" (Art.17), restriction (Art.18), portability (Art.20), objection (Art.21), and the right not to be subject to a purely automated decision (Art.22).
Application: [email protected]. The right to lodge a complaint with the competent Member State data-protection authority is reserved.
§6.3 — CCPA/CPRA Rights (California Users)
Right to know, right to delete, right to correct, right to opt out of sale/sharing ("Do Not Sell or Share" — the Developer does not sell data), right to limit use of sensitive data, and the right to non-discrimination.
User data is never sold, rented, or transferred to third parties for any purpose, including ad targeting. User data is not used to train, fine-tune, or evaluate AI or machine-learning models. The Developer does not permanently store user data on its infrastructure, subject to mandatory legal retention obligations and temporary logs kept for transaction security. This includes, without limitation, identity/routing identifiers temporarily held for message-delivery and payment-service-provider (PSP) purposes, and moderation-, compliance-, and statutory traffic records described in §3-G, §3.9, and §3.9-D; such data is retained only for a defined, limited period and is not stored indefinitely. This commitment is integral to the Developer's core privacy architecture; changes that expand the scope of data processing require the user's explicit consent, while operational and technical changes remain within the Developer's discretion, subject to 30 days' advance notice for material changes.
Categories of personal information collected (CCPA/CPRA notice): in the last 12 months, personal information in the following categories has been collected for the purposes described in this Policy: identifiers (username, cryptographic account identity number, one-way hash of a device identifier, push-notification identifier, IP address, the e-mail address you give when you contact the Developer by e-mail or web form); commercial information (purchase and subscription records); internet and network activity information (§3.9-D traffic records); geolocation information (profile country and city, approximate location derived from IP); demographic information (gender, year of birth, generation — §3.14); correspondence users send us, including website forms (§3.12, §3.12-A); and inferences (Reflection, simulation, Perception Network, and thought-flow analyses — these are stored only on your device). Sensitive personal information (e.g., health, health-related inferences) is processed only for the purposes described in this Policy and with your consent, and is not used to infer characteristics about you. Google (Gemini, Firebase Cloud Messaging), Cloudflare, and RevenueCat act as "service providers" within the meaning of the CCPA; transfers to them are not a "sale" of personal information or "sharing" for cross-context behavioural advertising. To have your push-notification record deleted, it is enough to turn off all notifications under Settings > Notifications (§3.10).
Application: [email protected]. Response time: 45 days (+45-day extension available). Identity verification may be required.
§6.4 — Rights Under the Local Architecture: Correction and Objection Procedures
Because the App is built on a privacy-first, serverless architecture, personal data is held predominantly only on the user's own device. This requires a different rights-exercise procedure from the traditional data-controller model.
§6.4.1 Rectification (KVKK Art.11/d; GDPR Art.16): for data the Developer holds directly on its servers (subscription/quota records, authentication hash, moderation records), send a written request to [email protected]; the Developer responds within 30 days. For data held on-device (profile information, chat history, Reflection data, memory records, etc.), it is technically impossible for the Developer to correct data remotely; instead, the Developer provides step-by-step guidance for correcting it on-device via the relevant settings menu, edit screen, or deletion flow.
§6.4.2 Deletion (KVKK Art.11/e; GDPR Art.17): for data on the Developer's servers, send a request to [email protected]; it is processed within 30 days and written confirmation is sent once complete. For on-device data, the user may: (i) use Settings > Privacy > [category] > Delete within the App; (ii) uninstall the App (deletes all local data); (iii) use tools such as Settings > Reflection Settings > Clear Memory Records or "Delete all data" in Settings; collection of step data can be stopped by turning off the physical-activity permission in the device settings. Where remote deletion is technically impossible, the Developer clearly informs the user of the relevant steps. For records subject to a statutory retention obligation (§3.8 payment records, §3.9 moderation records, §3.9-D traffic records), a deletion request is fulfilled at the end of the applicable statutory retention period; during that period, your rights to information about and access to those records remain reserved.
§6.4.3 Access and portability (KVKK Art.11/a; GDPR Art.15, 20): for data held on the Developer's servers, an access/copy request may be sent to [email protected] and will be provided in a machine-readable format (JSON or CSV). On-device data can be accessed directly by the user within the App. For export: Settings > Privacy > Download My Data (where available in that app version). If the feature is not yet active, the Developer will explain how the user can access their data on-device.
§6.4.4 Objection, restriction, and objection to profiling (KVKK Art.11/f, g; GDPR Art.18, 21, 22): a user wishing to object to AI profiling (Reflection creation), emotion analysis, or behavioral classification may: (i) use Settings > Reflection Settings > Stop Analysis in-app; (ii) turn off the relevant categories via the privacy panel; (iii) send a written objection to [email protected]. Where an objection cannot be technically implemented directly (e.g., for on-device processes), the Developer explains step-by-step how the user can change the relevant setting themselves.
§6.4.5 Complaints and referral to a supervisory authority: where the Developer cannot fulfil a request, or cannot intervene directly due to a technical-architecture constraint, it refers the user to the competent supervisory authority: the Personal Data Protection Board (kvkk.gov.tr) in Turkey; the competent Member State data-protection authority in the EU; and the California Privacy Protection Agency (cppa.ca.gov) in the US. This referral is not a denial of rights but a transparent disclosure of the architectural reality.
§6.4.6 Automated profiling and automated decisions — summary (GDPR Art.13(2)(f), Art.14(2)(g); KVKK Art.11/1-g): the App carries out the following automated profiling activities: the Reflection personality profile (§3.5.9); emotion synthesis (§3.5.6); thought-flow analysis (§3.5.15); character inference and compatibility scoring for two people in simulations (§3.5.7-C); Perception Network relationship insights (§3.5.14); on-device personalization of news suggestions (§3.5.12-A); your Reflection's simulated mood (§3.5.16); Self-Perception classification and Self Space inferences (§3.5.18); the Era Profile scoring and detailed reading of the Analog Age questionnaire (§3.5.19); and the account status summary containing a security risk classification (§3.14). None of these activities produces a decision about you that has legal effects or similarly significantly affects you; their outputs are used only to personalize the App experience and to produce fictional/interpretive content. The only decision based solely on automated processing within the meaning of GDPR Art.22 is the temporary sending restriction in §3.9-C.1, which is subject to the human-review and objection safeguards described there. To object to profiling, you can use the avenues in §6.4.4 and the switches of the relevant features.
§7 Children's Privacy
The App is an adults-only service. It is not directed at, and is not intended to be used by, individuals under 18, and personal data is not knowingly collected from them. Account creation by users under 18 is technically blocked based on the date of birth declared at registration; this check is calculated dynamically against the current date and is not hard-coded to a fixed year. Because the App's general minimum age (18) already sits above every age threshold referenced in COPPA, GDPR Art.8, and comparable regional digital-consent-age regimes, no user of the App is, or can lawfully be, a "child" or "minor" for the purposes of those regimes, and no parental-consent pathway is offered or required. If an account is found to have been created with a false age declaration, the account and all its data are deleted immediately. The only exception to this rule is the Under-18 Chat Panel, which creates no account, gives no access to the main service and is offered to users aged 13–17 with parental consent (§7-A).
§7.1 — Technical and Operational Age-Verification Measures
Pursuant to legal obligations and app-store rules (Apple App Store Guideline 1.3; Google Play Families Policy; KVKK Art.5-6; GDPR Art.8; COPPA), the Developer implements the following technical measures: (i) registration block — account creation is technically blocked for users under 18 based on the declared date of birth; this block is enforced client-side, on the registration screen; (ii) age-verification notice — the 18+ age requirement is clearly presented during registration and entering a date of birth is mandatory; (iii) no sub-18 tier in the account-based service — because the App's account-based main service does not admit any user under 18, it does not operate a parental-consent flow or an age-banded feature set within that service; the account-free Under-18 Chat Panel's own age declaration and parental-consent flow are governed by §7-A; (iv) reporting — if data belonging to a person under 18 is nonetheless found to have entered the system (e.g., through a false age declaration), it is deleted immediately and permanently upon discovery, and, where the circumstances raise a suspicion of an offense against a minor, the matter is handled under §3.9's cooperation-with-authorities provisions and may trigger a COPPA or equivalent reporting obligation.
§7.1.1 — The Developer's liability where the age declaration is false: the Developer relies on the user's own declaration for age verification; independent technical age verification (ID document, etc.) is not currently implemented. Where a user creates an account with a false date of birth, all legal consequences of that false declaration rest solely with the user. The Developer cannot be held liable for damage arising from a false age declaration, except to the extent directly attributable to its own negligence. Upon detecting an account created with a false age declaration, the Developer reserves the right to immediately delete or permanently disable that account and all its data; no refund is provided to the affected user in that case.
§7.1.2 — Advertising: no ads are shown and no profiling-based advertising takes place in the Under-18 Chat Panel (§7-A). Because the account-based main service does not admit any user under 18, the child-directed and age-banded advertising restrictions found in comparable services (COPPA behavioral-advertising limits, GDPR Art.8 age-gating) do not apply to any App user by construction. The Developer nonetheless configures its ad-network integration, where active, in line with applicable general advertising-disclosure law; see §1-A.7.4.
§7.1.3 — Reports concerning a suspected minor user: anyone with a good-faith belief that an account is being used by a person under 18 — including, but not limited to, a parent or guardian who discovers this about a person in their care — may report it to [email protected]. The Developer investigates such reports and, where the suspicion is confirmed, deletes the account and its data under §7.1 above. The Developer responds to such reports within 30 days.
§7-A Under-18 Chat Panel (ages 13–17)
§7-A.1 — Scope and purpose
A person who declares a date of birth under 18 on the registration screen is offered access to this panel instead of account creation. The panel's purpose is to help with school subjects, homework, exam preparation, study methods and personal growth, with a teacher's and pedagogue's approach. The panel is not designed for and not open to children under 13: if "Under 13" is selected in the age declaration at first entry, the panel does not open, and no data is knowingly collected from a person under 13 (US COPPA, 15 U.S.C. §6501 et seq. and 16 C.F.R. Part 312).
§7-A.2 — First-entry consent and parental consent
When the panel is opened for the first time (and again whenever this section changes), a plain-language summary of the terms is shown; consent cannot be given until the text has been scrolled to the end. The user declares their age and separately ticks four statements: (a) they are aged 13–17 and their age declaration is true; (b) their parent or legal guardian agrees to their use of the panel and, where needed, to purchases; (c) they understand that they are talking to an AI, that answers may be wrong and that it does not replace a teacher, doctor or psychologist; (d) they will not share personal information and accept these terms. The time of consent, text version, declared age and ticked boxes are stored on the device as evidence.
Legal basis: in Türkiye, transactions by minors capable of discernment that create obligations require the consent of the legal representative (Turkish Civil Code Art.16), and the legal representative's consent is required for processing personal data (KVKK Art.5-6); in the EU, for information society services offered directly to a child, the consent or authorisation of the holder of parental responsibility is required for children below 13–16 depending on the Member State (GDPR Art.8); standard terms are shown and made readable when the contract is concluded (Turkish Code of Obligations Art.20-21). As a reasonable effort to confirm parental consent, the Developer relies on Google Play's family controls (Google Family Link, purchase approval) and does not perform separate identity or age verification. The consequences of a false age declaration or of parental consent that was not actually given are governed by the principles in §7.1.1. A parent or legal guardian may withdraw consent at any time by writing to [email protected]; access to the panel is then closed and server records are deleted under §7-A.7.
§7-A.3 — Data processed, purpose and retention
On the device only: conversations; the hidden note written by the user; the optional "About me" fields (nickname, grade, subjects, interests, goals); LLM settings; the consent record. This data is not stored or backed up on the Developer's servers.
On the server: a randomly generated device ID number and the associated public key (containing no name, date of birth or other profile data); the package balance; the purchase record verified through Google Play/RevenueCat (product, date, store order number); technical records for security, abuse prevention and quota, and the statutory traffic (metadata) records under §3.9-D. No name, email, phone number, location or photo is requested.
Transmission to the AI provider: to generate answers, the message, recent messages, the hidden note and the "About me" fields are sent via the Developer's server to the Google Gemini API (outside the user's country; §3.5.3, §5); this content is not stored on the Developer's server and is subject to the provider's own terms.
Purpose and legal basis: providing the service (performance of the contract concluded with parental consent — KVKK Art.5/2-c, GDPR Art.6(1)(b)); security and abuse prevention (legitimate interest and legal obligation — KVKK Art.5/2-ç, f; GDPR Art.6(1)(c), (f)). Retention: purchase records on the server are kept for the period required by tax and consumer law; other server records for the periods in §8.1.
§7-A.4 — Best interests of the child: prohibitions and safeguards
In this panel (i) there is no profiling and no behavioural or personalised advertising, and no ads are shown; (ii) data is not sold or used for marketing, and no marketing notifications are sent; (iii) there is no communication, sharing or matching between users; (iv) default settings are at the highest privacy level (conversations stay on the device). These principles are applied in line with Art.28 of the EU Digital Services Act (online protection of minors, ban on profiling-based advertising), the principles of the UK Age Appropriate Design Code and the California Age-Appropriate Design Code Act, and the requirements of COPPA.
For every request, the assistant runs with a child-protection instruction added on the Developer's server that the user cannot change, and with the strictest safety-filter threshold: it gives no advice on romantic or sexual relationships, sexuality, alcohol, tobacco, drugs, gambling, violence, self-harm methods, dangerous challenges, dieting or medication, warns about the risks and refers the user to a trusted adult; it does not ask for personal information; it never suggests meeting anyone or hiding things from family; and it refers the user to emergency numbers when it senses a crisis. The user's settings or hidden note cannot change these safeguards. These rules apply in the same way in every country.
§7-A.5 — AI disclosure and limits of liability
In accordance with Art.50 of the EU AI Act, the user is clearly informed that they are interacting with an AI system. The assistant's answers are for information and learning; they may be wrong or incomplete and do not replace professional education or medical, psychological or legal advice. The panel is not an emergency, crisis or counselling service. Automated protective instructions and filters are applied on a best-effort basis but are not infallible; to the extent permitted by mandatory law, the Developer is not liable for damage arising from model outputs where it is not at fault. Consumers' rights under mandatory law remain unaffected.
§7-A.6 — Purchases
The panel package is a one-time, consumable Google Play product; there is no subscription and no automatic renewal. Payment, refunds and receipts are subject to Google Play's rules (see the Terms of Sale). If Google Play family controls are enabled, the purchase requires parental approval. A purchase by a user under 18 is valid with the legal representative's permission (Turkish Civil Code Art.16; rules of US state law on contracts by minors remain unaffected). Refund requests for purchases reported as made without parental permission are made through Google Play, and the Developer cooperates in that process. The package balance is linked to the device's ID number; if the app is deleted or the device changes, the balance may not be transferable.
§7-A.7 — Rights, deletion and complaints
The user can delete all conversations and information on the device under "Settings > My data" in the panel; uninstalling the app also deletes on-device data. A parent or legal guardian (KVKK Art.11; GDPR Art.15-21; COPPA, 16 C.F.R. §312.6) may request review, deletion and cessation of processing of server records at [email protected]; requests are answered within 30 days at the latest. The store order number may be requested to verify the request. Right to lodge a complaint: the Personal Data Protection Authority in Türkiye, the competent supervisory authority in the EU, and the Federal Trade Commission (FTC) in the US.
§7-A.8 — Closing access
In case of use contrary to these terms, if it emerges that the user is under 13, or in case of a false declaration, access to the panel may be closed and server records deleted; no refund is given in that case, subject to Google Play's rules and mandatory law. Situations raising a suspicion of an offence against a child are handled under §3.9. Whenever this section changes, consent is requested again within the panel.
§8 Data Retention and Deletion
Personal data is held only for as long as necessary for the purpose of processing. An account-deletion request can be made in-app ("Account > Delete My Account") or by written request to [email protected].
Once a deletion request is received, data held off-device is permanently deleted within 30 days, subject to mandatory legal-retention obligations. Deleting on-device data is the user's own responsibility (once the App is removed from the device, the Developer can neither access nor recover it). Records subject to mandatory legal-retention obligations — in particular the traffic (metadata) records in §3.9-D — are retained for the statutory period even if the account is deleted, and are destroyed at the end of that period.
§8.1 — Retention periods for data held server-side (summary): this summary is to be read together with the detailed provisions in the relevant sections; in case of conflict, the relevant section prevails.
- Letter, telegraph, SMS, and live-chat content (temporary relay): on delivery or within 2 days at the latest (§2-A, §3.7-A, §3.7-D).
- Standalone postcards, simulation results, and simulation stories: on delivery or within 3 days at the latest (§2-A, §3.5.7-B, §3.5.7-C).
- Broadcast Letter: the 7/30/365-day publication period chosen by the author (§3.7-C).
- Find Similar Users shares: the 1 week/1 month/1 year chosen by the user (§3.5.5-A).
- Push-notification device record: until notifications are turned off, the App is uninstalled, or the account is deleted; scheduled letter notification: no more than 3 days (§3.10).
- Identity-verification and guardian metadata: while the account and guardian relationships remain active (§3-G).
- Payment/purchase records: up to 10 years; other stamp movements: while the account is active and for 2 years after closure (§3.8).
- Moderation and complaint records: 2 years (§3.9).
- Traffic (metadata) records: at least 1 and at most 2 years (§3.9-D).
- Emails sent to the Developer: 2 years; legal/official correspondence up to 10 years; unsolicited emails 30 days (§3.12).
- Website test-user requests: until the test rounds end and the App becomes generally available, at most 2 years; immediately on withdrawal of consent (§3.12-A).
- Rewarded-ad verification and view records: 12 months (Terms of Sale §1-A.7.10).
- Purchase history records (product, date, store order number, amount reported by the store): same period as payment records (§3.8). No e-mail address is collected at purchase.
- Interaction permissions and block list: until account deletion, or until all permissions are on and the list is empty (§3.9-F).
- Account status summary (usage statistics): until account deletion; total counters not linked to identity without a time limit (§3.14).
Records relating to a legal dispute, official request, or fraud investigation that began before the period expired may be retained, limited to that process, until it is concluded. Expired records are periodically deleted or destroyed in accordance with the Turkish Regulation on the Deletion, Destruction or Anonymization of Personal Data.
Irreversibility and prerequisites for recovery: the "Delete My Account" action is irreversible; the account, all on-device content, and the secret keys that grant access to the account's network identity are permanently destroyed. Once this action is completed, access to the account can be restored ONLY if the user has both a previously created backup file (§9.7) AND the 12-word recovery phrase described in §9.8. If either or both are missing, no one — including the Developer — can restore the account or its content. Before confirming "Delete My Account," the user is shown an in-app warning that clearly states this outcome. Paid entitlements tied to the account (package, add-on packages, Stamps) end at the moment of deletion and are not reopened even if the account is brought back from a backup; see Subscription Terms §6-A.11 and Sales Terms §2.4-D.
§9 Local Encryption, Backup Risk, and User Responsibility
§9.1 — Encryption Infrastructure
The App protects user data on-device using industry-standard encryption. All local data is stored in an encrypted database; sensitive credentials are kept in the operating system's secure-storage layer. The encryption key is generated in a manner tied to the device and to user authentication.
§9.1-A — Key-Material Redundancy Safeguard (Secure-Storage Reset Protection)
On some devices — in particular certain Android variants with aggressive battery or memory optimization — the operating system's secure-storage layer described in §9.1 may, in rare cases, be reset independently of the encrypted database file itself. Left unaddressed, this could cause the App to treat existing local data as inaccessible and, under an unrelated recovery flow, result in irreversible loss of local data that is otherwise intact.
To protect against this failure mode, the App also keeps an additional copy of the value needed to reconstruct the decryption key in a separate, device-local storage area reserved exclusively for the App — a location no other app or person can access. If the operating system's secure storage is found to be empty, the App restores the key material from this device-local copy instead of generating a new encryption key, which would otherwise permanently render existing encrypted data unreadable.
This safeguard copy is never transmitted to the Developer's servers, is not visible to or accessible by the Developer, and is not shared with any third party; on its own it does not grant access to the user's data, since it must be combined with the other device-specific and authentication-based components described in §9.1 to reconstruct the key. It is automatically deleted from the device when the user deletes the App or their account. This measure does not alter the device-backup risk described in §9.2 or the user-responsibility provisions in §9.3 — it addresses a different, purely on-device failure mode and does not create any new transmission of data off the device.
Legal basis: KVKK Art.12 and GDPR Art.32 (appropriate technical measures to protect personal data against loss). This is a technical availability and integrity safeguard for data already described in §2 and §9.1; it does not introduce a new category or purpose of data collection.
§9.2 — Key Risk in the Event of Backup
When a user backs up app data via device backup mechanisms (iCloud Backup, Google Drive Backup, etc.), it is technically possible for the encrypted database file to be written to the same backup medium together with its decryption key. In practical terms: if the backup file is accessed without authorization, it is theoretically possible for the key to be obtained along with the encrypted data, enabling decryption.
This risk is outside the Developer's control; backup security depends entirely on the security infrastructure of the backup platform the user chooses (Apple, Google, etc.) and on the user's own account-security practices.
§9.3 — User Responsibility: Express Provision
The Developer assumes no liability in the following situations, which the user acknowledges and accepts:
- Access to on-device data as a result of the user's device being lost, stolen, damaged, or falling into unauthorized hands.
- Backups created by the user not being stored in a secure environment, or being accessed without authorization.
- Data being decrypted as a result of the encryption key being exposed along with a backup.
- The user sharing their password or biometric authentication device with a third party.
- Security vulnerabilities arising from the user's failure to install OS security updates.
- Operating-system security layers being disabled as a result of "jailbreaking" or "rooting" the device.
- The user choosing to export data from the App and losing control over it.
The Developer does not warrant or guarantee the security of data on the user's own device and cannot be held liable for any resulting damage. By downloading and using the App, the user accepts that the security of local data is primarily their own responsibility.
§9.4 — The Developer's Recovery Capability
Because Generation Network is designed with a privacy-first architecture, it is technically impossible for the Developer to remotely access or recover data stored on-device. In the event of device loss or malfunction, the Developer cannot recover the user's local data. This is not a service gap — it is a design choice made to protect user privacy. The safeguard described in §9.1-A does not change this: it operates entirely on the user's own device and grants the Developer no additional server-side access to, or recovery capability over, local data.
§9.5 — Recommended Security Practices
The Developer recommends, without mandating, the following, and cannot be held liable for damage arising from not following them: backing up via an end-to-end encrypted backup option; protecting the device screen lock with a strong passcode or biometrics; keeping the OS and app updated; limiting physical access to the device to trusted individuals.
§9.6 — The "Wake Up" Function and Background Processing
Tapping the "Wake Up" button on the selection screen starts a series of background operations on the user's own device to make the selected Reflection ready for interaction (loading/"warming" local AI models into memory, cache preparation, performance optimization, etc.). These operations run entirely on the user's own device; during processing, the device's CPU, memory, and storage resources may be used more intensively than normal, battery consumption may increase, and, depending on the device model, the process may take longer than a few seconds. Some warm-up operations may also be triggered automatically in the background while the App is idle — even without the user pressing a button — to improve response speed.
Limitation of liability: the Developer cannot be held liable for performance differences arising from device hardware or OS, for the process taking longer than expected, or for slowdowns on devices with lower hardware/storage capacity. Users can stop these background operations by restricting the relevant permissions in device settings or by discontinuing use of the App. The technical circumstances described in this section are subject to the general technical-disclaimer provisions in Terms of Service §5.3.
§9.7 — Manual Backup Export and Sharing
From the Settings menu, the user can create an encrypted copy of all their local data (a backup file) and send it, via the device's own sharing mechanism, to any destination they choose (cloud storage, another device, a file manager, e-mail, etc.). This happens entirely at the user's own initiative; the Developer does not automatically upload the resulting backup to any server.
Optional backup password: when creating a backup, the user is asked at the start whether they want to lock it with a password of their own. In a backup without a password, the key that opens the encrypted database is inside the file; anyone who obtains the file can open it with this App. If a password is chosen, this key is encrypted with a key derived from the password (PBKDF2-HMAC-SHA256 and AES-256-GCM) and is not present in the file in plain form; the file cannot be opened without the password, which is requested on restore. The password is never sent to the Developer and is not stored anywhere; if it is forgotten, the backup cannot be opened by anyone, including the Developer.
The backup file contains an encrypted database; however, once the user shares it, it passes outside the Developer's control and visibility. The security of the environment the file is sent to (cloud account, device, e-mail, etc.) depends entirely on the user's own choices and account-security practices. The Developer cannot be held liable for the storage, loss, or unauthorized access of a backup file the user has voluntarily shared with a third-party environment. This section supplements the backup-key risk described in §9.2. This backup file does NOT include any third-party AI API key the user may have connected; see §9.9.
The backup contains no paid entitlements or Stamps; restoring requires the identity: the backup file does NOT contain the Stamp balance or paid entitlements (package, add-on packages, LLM capacity); these are held on the server, tied to the account's identity, and verified by the server (Sales Terms §2.4-D, Subscription Terms §6-A.11). When a backup is restored with the same identity, the Stamp balance and the package status are determined from the server record, not from the backup on the device; the Stamp balance held on the server is therefore preserved. For high security, the backup file alone does not bring back the account's network identity (the reflection); this requires both the 12-word recovery phrase described in §9.8 and the account's identity number (ID). After a backup is taken, the App shows the ID in a copyable form; the user is responsible for keeping the ID, the recovery phrase and the backup file in separate, safe places.
§9.8 — Recovery Phrase and Network Identity Lock
Your account's network-side (server-side) identity is based on a 12-word recovery phrase shown only once during registration. The Developer never stores, backs up, or can view this phrase in any form; you are solely responsible for keeping it safe.
If you change devices, uninstall and reinstall the App, or restore your local backup ("Cortex"), and the 12-word recovery phrase is not entered correctly, you may continue to access your local, on-device data (memories, chats, etc.; for the Stamp balance see §9.7); however, your account's network identity becomes permanently locked, and you will be unable to use any server-based network feature, including letters, telegrams, genepool matching, and Web2 Similarity Analysis.
This lock is a direct consequence of the Developer's privacy-first security architecture: without the private key/recovery phrase, the server cannot authenticate the identity in question. Accordingly, the lock cannot be lifted through a customer-support request or intervention by the Developer, consistent with the absence of recovery capability described in §9.4. The user bears sole responsibility for all consequences (including the permanent lock of the network identity) arising from a failure to keep the recovery phrase shown at account creation in a safe, durable location; the Developer cannot be held liable for any resulting damage.
Where an alternative, guardian-based recovery mechanism as described in §3-G has been pre-configured for a given account, recovery may be attempted through that mechanism; however, this is an optional feature requiring separate, prior activation by the user and does not substitute for the primary recovery phrase.
Legal basis: the duty to inform under KVKK Art.10 and GDPR Art.13. This section does not describe a new data-processing activity; it transparently explains a natural consequence of the existing identity-verification architecture (§3-G).
§9.9 — Your Connected API Key Is Outside the Scope of Backup and Account Deletion
The third-party API key entered under the "Bring Your Own Key" feature described in Terms of Service §3-A.1 is, by deliberate design, (a) never included in the manual backup file described in §9.7, and (b) permanently deleted, along with other confidential on-device data, when the account is deleted as described in §8. This design ensures that the user's third-party provider key is never transmitted off the device in any form.
As a result, if the user recreates their account after deletion, or restores from a backup, they must re-enter this API key each time. This is a different mechanism from, and does not alter, the on-device encryption-key safeguard copy described in §9.1-A.
Legal basis: KVKK Art.12 and GDPR Art.32 (data minimization and secure processing). This section does not describe a new data-processing activity; it transparently explains a consequence of the BYOK architecture already described in §3-A.1.
§3-A Age Limit — Adults-Only Service (KVKK / GDPR / COPPA)
The App is an adults-only service, open only to individuals aged 18 or older. It is not directed at individuals under 18, and personal data is not knowingly collected from them. Use of the App by anyone under 18, under any circumstances, is strictly prohibited. Account creation is technically blocked based on the declared date of birth at registration.
Because 18 is at or above every age threshold used by COPPA (13), GDPR Art.8 (13–16, depending on Member State), and comparable regional digital-consent-age laws, the App does not admit any user who would fall within those regimes' definition of a "child," and accordingly offers no parental- or guardian-consent pathway, age-banded feature set, or reduced-age registration tier (sole exception: the account-free Under-18 Chat Panel, see §7-A). If it is found that an individual under 18 has entered data into the system (e.g., through a false age declaration), that data and the associated account are deleted immediately and permanently; this may be reported to [email protected].
This arrangement is implemented to satisfy the mandatory requirements of the Apple App Store and Google Play child-safety rules, KVKK Art.5-6 (explicit consent — legal capacity of minors), GDPR Art.8 (age threshold for a child's consent to digital services), and US COPPA (online privacy of children under 13) — by setting the App's general minimum age above all of them, rather than by attempting to separately satisfy each regime's specific consent mechanics for minor users.
§3-B Third-Party Data Processors — DPA Commitment, Liability Limits, and Links
§3-B.1 — The Developer's Data-Processing Position
The Developer is not structured to commercially collect or process user data. Consistent with its privacy-first architecture, the App processes user data on its own infrastructure only to the minimal extent necessary to operate the service (subscription management, authentication, quota tracking, moderation security). The Developer has not adopted a business model of collecting and marketing data, building profiles, or selling data to third parties.
§3-B.2 — Third-Party Data Processors and Legal Basis
The following third-party service providers access limited categories of data so the App can perform certain functions. The scope of data processed, legal basis, and policy link for each provider are set out below:
(i) RevenueCat, Inc. (USA) — subscription management and in-app purchase verification. Data processed: store transaction ID, subscription status, device identifier, in-app user ID. The Developer transfers this data to RevenueCat; RevenueCat cannot access payment-card data. Privacy Policy: revenuecat.com/privacy — subject to RevenueCat's standard Data Processing Agreement.
(ii) Google LLC / Google Gemini API (USA) — large-language-model processing services. Data processed: the user's AI-interaction content (as described in §3.5.3; the content is not anonymized); this includes record texts sent for Perception Network relationship analysis (§3.5.14), truncated chat blocks and emotion measurements sent for thought-flow analysis (§3.5.15), and KP-memory data and inferred character profiles sent for simulation stories, together with closed data sent with the user's explicit consent (§3.5.7-C, §3.5.7-D). Google API Terms: cloud.google.com/terms — Google Privacy Policy: policies.google.com/privacy.
(iii) Apple Inc. — iOS app distribution, In-App Purchase infrastructure, authentication. Data processed: Apple-ID-based subscription and payment verification; the Developer cannot access payment-card details. Apple Privacy Policy: apple.com/legal/privacy/.
(iv) Google LLC — Google Play Billing infrastructure and Android distribution. Data processed: Google-account-based subscription and payment verification. Google Play Privacy: support.google.com/googleplay/answer/10791228.
(v) Google AdMob (Google Ireland Limited for users in the EEA, the United Kingdom and Switzerland; Google LLC, USA, for all other users) — delivery and measurement of in-app ads (native ads and optional rewarded video ads, see §1-A.7). Data processed directly by the Google SDK on the user's device: the device's advertising identifier (Android Advertising ID), IP address and the approximate location derived from it, device model, operating-system version, language, app version, and interactions with ads (impressions, clicks, video completion). For personalized advertising Google acts as an independent controller under its own privacy policy and the Google Ads Controller-Controller Data Protection Terms; the Developer does not receive this data and has no access to the interest categories Google associates with the advertising identifier. The Developer does not send Google any content data (chats, Reflection profiles, memories, health data, identity data). How Google uses this data: policies.google.com/technologies/partner-sites · AdMob privacy: support.google.com/admob/answer/6128543. International transfer: Google LLC is certified under the EU-U.S. Data Privacy Framework and additionally relies on the European Commission's Standard Contractual Clauses; for users in Turkey see §1-A.7.5-A.
(vi) Cloudflare, Inc. (USA) — edge network, request routing, and Cloudflare KV storage infrastructure underlying the identity-verification and guardian-recovery system described in §3-G. Data processed: the categories listed in §3-G (hashed identity numbers, public keys, guardian metadata, encrypted secret-sharing fragments). Cloudflare is also used for the following services: Workers (server code and API gateway), Workers KV and D1 databases (temporary message/simulation mailboxes, the temporary queue for §3.9-D traffic records, §3.10 notification device records and scheduled letter notifications, and §3.12 incoming emails and §3.12-A website form records), Email Routing (§3.12), Pages (website and stamp images, §3.10 and §3.13), and Web Analytics (§3.13). Cloudflare Privacy Policy: cloudflare.com/privacypolicy.
(vii) Google LLC — Firebase Cloud Messaging (USA) — delivery of push notifications (§3.10). Data processed: device-specific notification identifier (FCM token), notification text (including, in letter notifications, the sender's profile country and estimated arrival time), and time of sending. The content of messages, letters, and chats is not sent to Google. For FCM, Google acts as a processor/service provider subject to the Firebase data processing and security terms (firebase.google.com/terms/data-processing-terms).
(viii) Google LLC — Gmail (USA) — storing and answering a copy of emails sent to @generationnetwork.app addresses and of website form records (§3.12, §3.12-A). Data processed: the email data listed in §3.12. Google Privacy Policy: policies.google.com/privacy.
(ix) Google LLC — Firebase Crashlytics (USA) — collecting crash and error reports from the release version of the App (§3.14-A). Data processed: error type and stack trace, masked error text, device and operating-system information, App version, and a random installation ID; account ID and content are not sent. For Crashlytics, Google acts as a data processor under the Firebase data processing and security terms (firebase.google.com/terms/data-processing-terms).
(x) Talsec s.r.o. — freeRASP (Czech Republic; data on Talsec-managed cloud infrastructure in the USA) — runtime security check (§3.14-B). Data processed: App and device security state, freeRASP installation ID and device ID, IP address and the approximate location derived from it; account ID, API keys, and content are not sent. Talsec acts as a data processor.
(xi) MET Norway (Norwegian Meteorological Institute / Meteorologisk institutt, Oslo, Norway; api.met.no) — weather data (§3.2-A). Data processed: latitude/longitude rounded to about 0.1 degrees (about 11 km), the IP address and time of the request; no account ID, username or other identifier is sent (the request contains only the App's name and the Developer's contact address). The provider keeps access logs (including the IP address and the coordinates in the request) in its data center in Norway. Cross-border transfer: Norway is a member of the European Economic Area and subject to the GDPR. Attribution: weather data is from MET Norway (Data from MET Norway) and is used under the CC BY 4.0 (creativecommons.org/licenses/by/4.0) and NLOD 2.0 licenses; the data is summarized into text. Terms of use: api.met.no/doc/TermsOfService.
§3-B.3 — Data Processing Agreement (DPA) Commitment
The Developer's approach to the above third-party providers: RevenueCat is engaged subject to RevenueCat's standard DPA terms, which govern processor obligations under GDPR Art.28. The Developer transfers only the minimum data necessary for the service and does not instruct RevenueCat to use it for other purposes. Google (Gemini API) — Google Cloud/API services are used under Google's standard Data Processing Terms and Terms of Service (Google Cloud DPA). Google commits not to use customer data for its own advertising systems. Apple / Google Play — these platforms are independent store operators, not the Developer's direct data processors. Data users share with these platforms is subject to the relevant store's own privacy policy. Cloudflare is engaged subject to Cloudflare's standard Data Processing Addendum, which governs processor obligations under GDPR Art.28; the Developer transfers to Cloudflare only the minimum data necessary to operate the services listed in §3-B.2(vi). Google (Firebase Cloud Messaging) is engaged as a processor under the Firebase data processing and security terms; the Developer transfers to FCM only the minimum data needed to deliver a notification (the notification identifier and notification text that carries no message content). Google (Gmail) is used solely to store and answer emails sent to the Developer.
§3-B.4 — Separation of Third-Party Liability from the Developer
The Developer's liability toward third-party providers is limited to the following framework: the Developer must exercise reasonable care in selecting providers (using appropriate DPA/SCC mechanisms, obtaining adequate assurances under GDPR Art.28) and must transfer to providers only the minimum data necessary for service delivery. Beyond this, disruptions, security breaches, or policy violations occurring within a provider's own systems fall outside the Developer's sphere of intervention, and the Developer cannot be held liable for damage arising from them. For complaints regarding third-party providers, the user may contact that provider's own support and privacy channels directly; the links above are provided for that purpose.
§3-C Socioeconomic Class / Badge Data
The App includes an optional badge or profile feature where the user may state their socioeconomic class. This is sensitive data that may allow inferences about the user's economic status or income level.
Conditions for this feature: (i) it is entirely optional; the user is not required to enter it, and not doing so does not restrict any core function of the App. (ii) It is private by default; this data is not shown to other users unless the user explicitly makes it visible. (iii) The user can change or fully remove this information at any time. (iv) This data is not used for ad targeting, price discrimination, or access restriction.
Legal basis: KVKK Art.5/1 (explicit consent); GDPR Art.6(1)(a). By entering this information, the user is deemed to consent to its processing; consent is revocable, and revocation deletes the existing profile data.
§3-D AI Transparency — Explicit Notice That the Reflection Is Artificial Intelligence
This notice is given pursuant to the mandatory disclosure obligations under the EU Artificial Intelligence Act, US Federal Trade Commission (FTC) guidance, Turkish Personal Data Protection Authority regulations, and international best-practice standards on AI transparency. The user uses the App knowing and accepting that their interaction with a Reflection is with an artificial-intelligence system.
Labelling of AI-generated content: simulation stories (§3.5.7-C), Mind Explorer posts (§3.5.12), and similar AI-generated content are presented in the App with a clear statement that they were generated by AI; for simulation stories, this notice appears at the opening of the film, in the credits, and on the result card, and is also shown to the person to whom the story is sent. This practice is designed to be consistent with the transparency obligations under Art.50 of the EU Artificial Intelligence Act (Regulation (EU) 2024/1689).
§3-E Account Deletion and Data Retention Period
Following a user's request to delete their account, server-side data under the Developer's direct control is permanently deleted within 30 (thirty) days. Aggregate counts that contain no user identity and are not account data (e.g., the daily total number of users) are outside the scope of deletion. Technical copies and restore backups in the systems of infrastructure providers (e.g., Cloudflare, Google) are deleted at the end of the relevant provider's own retention period. Data subject to mandatory legal-retention obligations (payment/transaction records, moderation decisions, legal-notice documents, traffic records) is retained for the mandatory period under the Turkish Commercial Code, Tax Procedure Law, Law No. 5651, and related legislation — 10 years for payment records, 2 years for moderation records, and at least 1 and at most 2 years for traffic (metadata) records that contain no content (see §3.9-D).
Deleting on-device data is the user's responsibility; uninstalling the App deletes local device data. The Developer cannot remotely delete device data (a consequence of the privacy-first architecture). Written confirmation that a deletion request has been processed is sent to the user's application address within 15 business days.
§3-E.1 — Requesting Account and Data Deletion (With or Without the App)
In the App: Settings → Privacy → Delete Account. This deletes your account record and the server data linked to your account on the Developer's server and clears your data on the device; what is deleted and which records are kept for legal periods is described above.
Without the App (on the web): if you have uninstalled the App or cannot open it, send an email with the subject "Account deletion request" to [email protected]. To help find your account, include your username and, if you know them, your account ID number, the approximate date the account was created, and your country. Because accounts are identified by an ID generated on your device rather than an email address or phone number, the Developer will try to match your request using this information; if a matching account is found, it is deleted as described above and the request is answered within 15 business days. If no match can be made, you will be told.
Partial deletion: you can request deletion of specific data without deleting your account (e.g., removing your shared profile from the Genepool network) at the same address, or use the relevant settings in the App.
§3-F Location-Based Pricing — Data-Processing Notice
The App may detect geographic location in order to offer local pricing based on the user's country. Data processed and the conditions for this are: (i) signals collected — the device's system region and language settings, the app interface language, and — only where the user has previously and explicitly granted location permission — the device's last known location. (ii) purpose — this data is used solely to determine the pricing region; it is not used for ad targeting, profiling, or any other purpose. (iii) location permission is not mandatory — the App functions fully even if the user does not grant location permission; location permission is never required for pricing purposes. (iv) no third-party sharing — location/country data collected for pricing purposes is not shared with or sold to third parties (answering CCPA §1798.100's "is data sold" question: no). (v) retention — only the most recent detection result is kept; no historical location record is retained (GDPR Art.13 compliance). (vi) final payment — subscription and purchase amounts are collected by Google Play or the Apple App Store in the user's local currency; the App does not collect or process any payment information. (vii) user objection — the user can refresh a misdetected country via the "Update Country" option in app settings; (viii) additional on-device use — the same country value, together with the App's interface-language setting, may also be used entirely on-device to rank content on the News Network page described in §3.5.12-A; this additional use does not involve any new transmission of the country field to the Developer's servers.
Legal basis: KVKK Art.5/1 (explicit consent — for location data), Art.5/6 (data minimization); GDPR Art.6(1)(a) and the data-minimization principle (Art.5(1)(c)).
§3-G Identity Verification and Guardian Recovery Infrastructure (Cloudflare KV)
The App offers an account-recovery system based on trusted "guardians" chosen by the user, together with cryptographic identity verification. Because this system requires certain values to be reachable across devices and sessions, a limited set of metadata is, by design, held server-side — in Cloudflare Workers KV, a distributed key-value store operated by Cloudflare, Inc. — rather than solely on-device. This section describes that processing transparently and supplements, rather than contradicts, the general on-device-storage principle in §2.
§3-G.1 — Data Held in Cloudflare KV
- Identity number (kimlik_no): a one-way cryptographic derivative of the user's identifying information, generated using PBKDF2. This value cannot be reversed to recover the original input; it functions solely as a lookup/matching key.
- Ed25519 public key: the public half of the cryptographic key pair used to verify the authenticity of the user's actions and messages within the identity-verification system. Consistent with standard public-key cryptography, this key does not by itself expose any private information.
- Guardian identity numbers: where a user designates other users as "guardians" for account-recovery purposes, or is designated as a guardian by others, the kimlik_no values establishing these guardian relationships are held as metadata in Cloudflare KV, together with the invitation/acceptance status of each relationship (i.e., who invited whom, and whether the invitation was accepted or declined, matched by kimlik_no). This is processed as trust-relationship metadata necessary for the guardian-recovery mechanism to function.
- Guardian secret-sharing fragments: using a Shamir's Secret Sharing scheme, a recovery secret is split into multiple fragments, and each designated guardian's fragment is stored, as an opaque encrypted blob, in Cloudflare KV. The Developer's server infrastructure stores these fragments but does not combine them under any normal operating condition; recovery requires a threshold number of guardians to independently supply their fragments through the recovery flow.
§3-G.2 — Existence Lookup (Membership Query)
A user who knows another user's kimlik_no can query the system to check whether that identity number exists in the system (a yes/no result only — no further information is returned). Users should be aware that if a third party knows or obtains your identity number, that party may be able to determine, through this lookup, that you hold an account on the App. No profile data, contact information, or other details are disclosed through this lookup beyond the existence result itself.
§3-G.3 — Residual Risk Disclosure: Guardian Fragments
§3-G.4 — Legal Basis, Third-Party Processor, and Cross-Border Transfer
Legal basis: KVKK Art.5/2-c (contract performance — the account-recovery feature is a service the user has opted into) and Art.5/2-f (legitimate interest — account-security and anti-fraud purposes); GDPR Art.6(1)(b) and Art.6(1)(f). Because kimlik_no is an irreversible cryptographic derivative rather than the underlying identifying information itself, and guardian fragments are opaque and individually meaningless, the Developer applies heightened technical safeguards appropriate to the sensitivity of this metadata.
Third-party processor: this infrastructure is hosted on Cloudflare, Inc.'s network, as further described in §3-B.2(vi). Cloudflare KV nodes may be located in the United States or other countries outside Turkey and the EU/EEA as part of Cloudflare's global CDN. Accordingly, this processing constitutes an international data transfer, subject to the safeguards described in §5 (KVKK Art.9; GDPR Standard Contractual Clauses and/or adequacy mechanisms, together with Cloudflare's Data Processing Addendum).
Retention: the data categories described in this section are retained for as long as the relevant account and its guardian relationships remain active. A user may remove a guardian relationship, regenerate their identity credentials, or request deletion of this metadata by contacting [email protected]; deletion is carried out within 30 days, subject to any technical constraints inherent in the distributed nature of guardian fragments already shared with other users' recovery flows.
§10 Policy Changes and Contact
§10.1 Right to amend: this Policy and the linked documents (the Terms of Service, Subscription Terms, Acceptable Use Policy, and the other texts in this Legal Center) may change in the future. The Developer reserves the right to update these documents in response to changes in legislation, decisions of competent authorities or courts, features added to or removed from the App, changes in technical infrastructure or service providers, security needs, and operational requirements. This right also covers changes to the scope of the service, its feature set, and pricing. Every update is subject to the procedures and safeguards set out in this Section.
§10.2 Notice channel — in-app notification: users are notified of changes primarily within the App. In-app notice may be given through an information screen or dialog shown when the App is opened, the in-app notification/message area, and — where the user has granted permission — push notifications. Where a registered e-mail address exists, notice may additionally be sent by e-mail. The notice includes a summary of the change, its effective date, and a link to the full updated text. The updated text is also published, with its effective date, in the Legal Center at generationnetwork.app. Push notifications being disabled on the device does not affect the validity of a notice shown when the App is opened.
§10.3 Material changes — at least 30 days' notice: changes that materially affect users' rights or obligations (e.g., changes to the categories of data processed, processing purposes, retention periods, or the scope of transfers to third parties; changes to fees, subscription, or refund terms; changes to liability or dispute-resolution provisions) are announced by in-app notice at least 30 (thirty) days before they take effect. For material changes, the Developer may require users to separately confirm within the App that they have read and accept the updated text before continuing to use the App.
§10.4 Non-material changes: changes that do not narrow users' rights or increase their obligations (e.g., spelling and wording corrections, clarifying additions, updates to contact details, or changes solely in users' favour) may take effect without a prior notice period, upon publication of the updated text and update of the effective date. Such changes are also shown in the version history (§10.8).
§10.5 Mandatory and urgent changes: changes made necessary by a change in law, a decision of a competent authority or court, or an urgent security risk affecting users or the service may take effect on the date that requirement demands, without waiting for the 30-day period. In that case users are informed by in-app notice as soon as possible.
§10.6 Changes requiring consent: changes that expand the purposes of data processing, retention periods, or the scope of third-party sharing take effect for existing users only upon obtaining their explicit consent. For a change requiring explicit consent, continued use of the App does not constitute consent; consent is obtained through a separate, explicit confirmation step within the App. If a user does not accept a change, they may exercise the right to close their account and delete their data under the pre-change terms. Legal-obligation exception: processing that is based on a legal obligation rather than on explicit consent (e.g., the traffic records in §3.9-D) is not subject to this consent requirement; such changes take effect from the date the obligation is applied and are separately notified to users in-app.
§10.7 Right to decline and continued use: a user who does not accept a change may, before the effective date and without any penalty or additional charge, close their account, disable the relevant feature, or cancel their subscription through the Apple App Store / Google Play; in that case their data is deleted under the pre-change terms (subject to statutory retention obligations, e.g., §3.8). Changes affecting paid subscriptions apply from the next renewal period, not to the current period already paid for; rights relating to the paid period are reserved under Subscription Terms §9. For price changes, Subscription Terms §6 and the rules of the relevant store also apply. For changes that do not require consent, continued use of the App after notice has been given and the effective date has passed constitutes acceptance of the updated terms.
§10.8 No retroactive effect and version history: changes do not apply retroactively; data collected before a change continues to be processed under the terms in force when it was collected, unless a legal requirement applies or the user's explicit consent is obtained. Every update to this Policy and the linked documents is published together with its effective date and a summary of the changes; previous versions are retained by the Developer and provided on request. In the event of a dispute, the version in force on the date of the relevant transaction applies.
§10.9 Interpretation of scope — data categories and purposes: this Policy defines processing activities by data category and processing purpose, independently of specific feature or screen names. A new feature added to the App that falls within a data category and purpose already defined in this Policy is subject to the relevant provisions of this Policy. A new data category or a new processing purpose is processed only after it has been added to this Policy and, where required, notified to the user or made subject to their explicit consent. This principle of interpretation does not narrow the information obligations under KVKK Art.10 and GDPR Art.13-14.
Complaint authorities: in Turkey, the Personal Data Protection Board (kvkk.gov.tr); in the EU, the competent Member State data-protection authority; in California, the California Privacy Protection Agency (cppa.ca.gov).