Privacy Policy & KVKK Disclosure

1. PURPOSE AND SCOPE

This Privacy Policy and KVKK Disclosure Text has been prepared to define the principles regarding the collection, processing, storage, and protection of personal data belonging to Circle App users.

Circle App is a mobile application that allows users to share products only within their circle of friends. To enable this feature, the application requires access to the user's phone contacts.

As KEREM KARŞILIKLI ŞAHIS ŞİRKETİ ("Company"), we value the privacy of our users and process all personal data in accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK") and the General Data Protection Regulation ("GDPR").

2. PERSONAL DATA COLLECTED

The following types of data may be processed when using Circle App:

a. Identity and Contact Information

• Full name
• Phone number
• Email address
• Profile photo (optional)

b. Device and Application Data

• Device type, operating system information
• IP address, session duration, error logs

c. Contact List (Address Book) Information

Circle App temporarily reads the names and phone numbers stored on the user's device for the purpose of matching friends within the app. These data are not uploaded to servers and are processed only locally for matching.

d. User Content

• Product photos shared by the user
• Descriptions, pricing information
• In-app messaging or notification preferences

3. PURPOSES OF PROCESSING PERSONAL DATA

• Providing Circle App services and creating your user account
• Matching contacts to form your in-app friend list
• Ensuring user experience and security
• Detecting fraud, spam, or misuse
• Fulfilling legal obligations
• Providing user support and technical notifications

Personal data is never sold, rented, or shared with third parties for marketing purposes.

4. LEGAL BASIS FOR PROCESSING

Personal data is processed based on the following legal grounds:

• KVKK Article 5/2(c): Necessary for the performance of a contract
• KVKK Article 5/2(f): Processing is mandatory for legitimate interests
• Explicit consent (Article 5/1): For contact access, notifications, or optional features

5. TRANSFER OF DATA

Personal data may be shared only with technical service providers (e.g., hosting or security services), and such transfers are secured contractually under Article 8 of KVKK.

Data is not transferred abroad. In cases where international data transfer becomes necessary, user consent will be obtained.

6. DATA RETENTION PERIOD

Personal data is stored:

• As long as the user account remains active
• Up to 1 year after account deletion, in line with legal obligations

After these periods, data is anonymized or destroyed.

7. DATA SECURITY

The Company takes necessary technical and administrative measures to ensure data security, including:

• SSL encryption and secure server infrastructure
• Access control and authentication
• Regular security testing against unauthorized access, loss, or breach

8. USER RIGHTS (KVKK Article 11)

Users have the right to:

• Learn whether personal data is processed
• Request information if processed
• Learn the purpose of processing and whether it is used accordingly
• Learn about third parties receiving data
• Request correction or deletion of data
• Request correction if processed inaccurately
• Request compensation in case of unlawful processing

You may exercise your rights by emailing: info@usecircleapp.com. Requests will be answered within 30 days.

9. COOKIES AND TRACKING TECHNOLOGIES

Circle App may use cookies within its web version or support services. No third-party advertising cookies or tracking are used within the mobile application.

10. CHANGES TO PRIVACY POLICY

This Privacy Policy may be updated periodically. The latest version will be published within the application.

11. CONTACT

KEREM KARŞILIKLI ŞAHIS ŞİRKETİ Email: info@usecircleapp.com

12. EFFECTIVE DATE

This Privacy Policy was published on October 24, 2025 and applies to all Circle App users.