1. Data Controller

Under Turkish Personal Data Protection Law No. 6698 ("KVKK"), your personal data is processed within the scope below by the data controller as described below. Data controller: Tolga Polat, Esentepe Mahallesi, Gökçedağ Sokak No:9 Daire:2, Kartal / İstanbul 34870. Contact: destek@zemberek.app

2. Personal Data Processed

• Identity / contact: user identifier provided by Apple, name, email.
• Customer transaction: subscription status, scan and search records, usage counters.
• User content: watch details, photos, documents, community profile, posts, comments and interactions.
• Membership application: watch brand/model/serial number, verification photos, handwritten note, consent record.
• Transaction security: app version, device model, iOS version, last seen, error and crash records, notification (push) token.

We do not request special-category personal data; please cover ID/address details in photos and documents.

3. Purposes

• Creating accounts and providing the service, syncing the collection,
• Watch recognition and market-value research, applying usage entitlements,
• Evaluating community membership, running the community safely, handling reports and abuse, preventing fraud,
• Subscription validation,
• Sending notifications, subject to your permission (application result, community interactions),
• Error detection, information security and service quality,
• Compliance with legal obligations.

4. Legal Bases

Your data is processed under KVKK art. 5/2: establishment and performance of a contract (c), compliance with a legal obligation (ç), establishment, exercise or protection of a right (e), legitimate interest (f); and — for items such as membership application photos — your explicit consent (art. 5/1).

5. Transfers

Your data may be transferred to our infrastructure and service providers to deliver the service (cloud hosting and database: Supabase; authentication, subscription and notification delivery: Apple; AI watch recognition: Anthropic; search: SerpAPI; crash/analytics: Google Firebase) and, where legally required, to competent public authorities. Data is hosted in Germany (EU); since some AI, search and analytics providers may be in countries such as the US, data may be transferred abroad in accordance with the conditions in KVKK art. 9.

6. Method of Collection

Your data is collected electronically through the app (information you enter, camera/gallery, Sign in with Apple) and automatically (technical records).

7. Your Rights under KVKK Art. 11

• Learn whether your data is processed,
• Request information if it has been processed,
• Learn the purpose of processing and whether it is used accordingly,
• Know the third parties to whom it is transferred in Türkiye or abroad,
• Request correction of incomplete or incorrect data,
• Request deletion or destruction under art. 7 and its notification to third parties,
• Object to an adverse result arising from analysis exclusively by automated systems,
• Claim compensation for damage caused by unlawful processing.

8. How to Apply

To exercise your rights, write to destek@zemberek.app from the email address registered in the app. Your request is concluded free of charge within 30 days at the latest, depending on its nature. You can also delete your account yourself via Settings > Account > Delete Account. You also have the right to complain to the Personal Data Protection Board.

See the Privacy Policy for details.