Privacy Policy and Privacy Notice

1. Data controller and contact details

Hasan Hüseyin Korkmaz, operating under the KELD Digital brand, is the data controller responsible for processing your personal data within Claspy.

Address: Işıktepe Organize Sanayi Bölgesi Mah. 75. Yıl Bulvarı Demirciler Sitesi No:5 B Blok İç Kapı No:24, 16140 Nilüfer/Bursa

Email: hello@kelddigital.com

This notice explains the purposes for which your personal data is processed when you use the Claspy mobile app and the claspyapp.com website and communicate with us, with whom it may be shared, how it is transferred abroad, and your rights.

2. Personal data processed

Depending on the features you use, the following data is processed:

• Account information: Email address, display name, user ID, sign-in and account preferences, language preference and, for solo use, the relationship status you provide.
• Profile and images: Profile, cover and memory photos you upload.
• Pairing and shared content: Partner pairing, the relationship start date you provide, daily question answers, comments, memories, future notes, shared lists, goals and mood updates.
• Solo content: Your answers to Discover yourself questions and, if you consent, reflections prepared from those answers.
• Game information: Game sessions, choices, answers, moves and results.
• Purchase information: Subscription type, transaction IDs, purchase, renewal, cancellation and access status.
• Gift information: Gift codes you buy or redeem and, optionally, the recipient name, recipient email address, sender name and personal message you enter.
• Report and review records: Content you report or that is reported about you, the reason for the report, a copy of the content at the time of review and the outcome of the review.
• Usage and technical information: App and feature usage events, analytics identifiers, values derived from search operations, device and app information, notification tokens, error and crash logs, IP addresses and server access logs.
• Communications and requests: Your support requests, messages you send and information needed to resolve your request.
• Preference and permission records: Your consent for relevant features and its date, notification preferences and, where applicable, permissions for commercial communications.

The current version of Claspy has no audio recording or location features and does not access your contacts. You are not asked to provide special categories of personal data, such as information about health, sex life, sexual orientation, religion or political opinions. We recommend that you do not share such information or unnecessary personal data about third parties in free-text fields.

Claspy does not receive the full card number or card security code used for your App Store payments.

The claspyapp.com website does not use cookies and contains no analytics tool that tracks visitors. Your theme and language preferences are stored only in your browser. The website’s hosting service keeps technical access logs, such as IP addresses, for security and operation.

3. Why do we process your data?

Your personal data is processed for the following purposes:

• Creating your account, verifying your sign-in and securing your account.
• Enabling you to pair with your partner and use shared features.
• Saving the content you create and displaying it according to the applicable access conditions.
• Providing games, shared history and personalized in-app features.
• Verifying purchases, managing subscription access, restoring purchases, and creating and redeeming gift codes.
• Delivering service notifications and sign-in codes.
• Understanding app usage, improving its operation, and detecting and fixing errors and crashes.
• If you consent, measuring whether our ads lead to app installs.
• Reviewing reported content, acting on content and accounts that violate the community rules, and preventing misuse.
• Resolving support requests and personal data requests.
• Providing AI features you have consented to.
• Sending campaign and promotional messages if you give separate permission.
• Fulfilling legal obligations and establishing, exercising or protecting rights.

4. Collection methods and legal grounds

Your data is collected electronically, by fully or partly automated means, through the information you enter in the app, content you upload, app and server operations, integrated service providers and communication channels.

Processing necessary for account creation, authentication, pairing, providing shared content, managing subscription access and handling gift codes is based on the establishment or performance of a contract under Article 5/2-c of the Turkish Personal Data Protection Law (KVKK).

Processing necessary to fulfil legal obligations is carried out under Article 5/2-ç; processing necessary to establish, exercise or protect a right is carried out under Article 5/2-e.

Account security, prevention of misuse, review of reported content, and keeping error and crash logs are based on the legitimate interest ground under Article 5/2-f, provided that your fundamental rights and freedoms are not harmed.

For optional activities such as measuring product usage with a pseudonymous ID, measuring our ads, AI features and campaign messages, separate information is provided and explicit consent or permission for commercial messages is obtained before the relevant processing. Consent to product usage and ad measurement is asked with a separate, unticked option when you first enter the app; accepting the terms of use does not mean giving this consent. You can withdraw it at any time in the app under Settings > Usage Data. Reading this privacy notice or using the app does not, by itself, constitute explicit consent or permission for commercial electronic messages.

If you enter another person’s name or email address when creating a gift code, you must inform that person before sharing this information. This information is processed only to deliver the gift.

5. Information your partner can see

After pairing, information you create for shared use is shown to your partner according to the visibility and access conditions of the relevant feature. For daily question answers to become visible to each other, both people must answer and have the relevant read access.

Areas for individual use differ from shared areas; not all content is automatically shared with your partner.

Your partner may save or share content they can access outside the app. If you enable content previews in notifications, or use home screen widgets, some information may appear on your device’s lock screen or home screen.

6. AI features

Our Weekly and Monthly Talk analyses are prepared after both people in the pairing give their consent separately. These features may send mutually unlocked answers and activity summaries needed for the analysis to Google Gemini.

Discover yourself reflections are prepared only if you give separate consent. This feature sends your most recent answers to Discover yourself questions (up to 30) to Google Gemini.

Names are not sent to the model; people are referred to with placeholders. This does not mean that answer texts are fully anonymous. Information you write in your answers may identify you or other people.

Features such as anniversary summaries and profile statements do not send answer texts; they may use only summaries of themes, skills and activities.

We use Google Gemini under its paid service terms; under these terms, content sent is not used to improve Google’s products.

AI outputs may contain errors and do not constitute medical assessment, psychological counselling or therapy services. You can report outputs you find inaccurate or inappropriate in the app.

You can withdraw your consent to AI features in the app settings. Withdrawal does not retroactively affect the lawfulness of previous processing.

7. Service providers and data sharing

Data may be processed with the following service providers to the extent necessary to deliver the service:

The same data is not sent to all these providers. Sharing is limited to the data required by the feature and service being used. Data may also be disclosed to authorized public institutions and authorized persons involved in legal proceedings to the extent required by law.

Within KELD Digital, only persons authorized to resolve support requests, maintain security and review reported content access your data, and only as necessary.

Claspy does not show third-party ads; your personal data is not sold or rented. The install and open information shared with Meta is used only to measure our own ads; your answers and what you write are not sent to Meta.

8. Transfers abroad

Because our service providers’ servers are located in European Union countries and the United States, your personal data is transferred abroad. Our main database and file storage are in Germany, our server application is in the Netherlands, and our product usage and error logs are in Germany. Purchase verification, ad measurement, AI features, notifications and email delivery may be carried out through US-based providers.

Transfers abroad are made in accordance with the conditions and procedures set out in Article 9 of the KVKK, limited to the data required by the relevant service.

9. Campaign and promotional emails

Campaign and promotional emails are sent after the necessary separate permissions have been obtained. Giving this permission is not a condition of creating a Claspy account or using the core services.

You can change your preference using the opt-out or unsubscribe method in promotional messages. Opting out of promotional messages does not prevent sign-in codes, security alerts and non-promotional transactional emails necessary to operate the service.

Records of permissions and opt-outs for commercial communications are processed to fulfil obligations under the applicable legislation.

10. Retention and account deletion

Personal data is retained for as long as necessary for the relevant processing purpose and in accordance with applicable legal retention obligations. When the reason for processing no longer applies, data is deleted, destroyed or anonymized in accordance with applicable legislation.

You can use the account deletion feature in the app. Account deletion covers your account records, your answers, your solo content and AI reflections, related report records, gift codes you created and your stored photos. Ending a pairing, deleting the shared archive and deleting an account are different actions; the scope stated on the relevant screens should be taken into account.

Deleting an account does not mean that all transactions and records held by all service providers are deleted at the same time. For example, purchase records may be kept by Apple and RevenueCat, and error and usage logs by the relevant providers, according to their own retention periods. Records that must be retained are limited to the relevant legal ground and retention period.

Deleting your account may not automatically cancel your App Store subscription. You can manage your subscription separately in your Apple account’s subscription settings.

11. Age limit and device permissions

Claspy is intended for people aged 18 and over. People under 18 should not create accounts. You can report use that violates the age limit or related data processing to hello@kelddigital.com; the relevant account and data will then be deleted.

You can manage camera, photo access, saving to your photo library and notification permissions in your device settings. Turning off permissions may affect use of the relevant feature.

Using device authentication features such as Face ID does not mean that your biometric face template is transmitted to Claspy; authentication takes place on your device.

12. Your rights and requests

Under Article 11 of the KVKK, you may:

• Learn whether your personal data is processed and, if it is, request information about that processing.
• Learn the purpose of processing and whether your data is used in accordance with that purpose.
• Learn which third parties receive your data within Türkiye or abroad.
• Request correction of incomplete or inaccurate data.
• Request deletion or destruction of your data when the legal conditions are met.
• Request that relevant third parties be notified of corrections, deletions or destruction.
• Object to a result against you arising from analysis carried out exclusively through automated systems.
• Request compensation if you suffer damage due to unlawful processing.

You may submit requests in writing to the address above, using the methods set out in the Communiqué on the Procedures and Principles for Applications to the Data Controller, or to hello@kelddigital.com from the email address registered in our system. Necessary and proportionate information may be requested to verify your identity.

Requests are resolved free of charge as soon as possible, depending on their nature, and within 30 days at the latest. If the action involves an additional cost, a fee may be charged according to the tariff set by the Personal Data Protection Board.

If your request is rejected, you find the response insufficient, or no response is given in time, you may file a complaint with the Personal Data Protection Board under Article 14 of the KVKK.

13. Changes to this notice

This notice is updated when data processing activities change, and the update date is shown at the top of the page. We also announce significant changes in the app or by email. Where changes require new explicit consent or separate information, the relevant process is carried out separately.