KVKK notice (Türkiye)

This notice is provided under Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”). It repeats, in the form that law asks for, what the Remyra privacy policy describes in full. The Turkish version is the one that applies in Türkiye: KVKK aydınlatma metni.

1. Data controller

The data controller is AggiNova. You can reach us about your personal data at destek [at] re-my-ra.com.

2. Personal data we process

• Identity and contact: if you create an account, your email address, the name you give and your app language. If you sign in with Google, your Google account ID; with Apple, your Apple user ID (and relay address if you hid your email).
• Account security: the hash of your password, session records (hashed token, creation and last use, a coarse device label such as “Android”) and hashed verification and reset codes.
• App content: when you are signed in, the text of your memories and reminders; with Remyra Pro, the photos your memories use. Without an account, this data stays on your device.
• Link previews: the web address you are saving reaches our server, which fetches that page to read its title, description and picture. The address and what the page said are kept for 30 minutes and are not linked to you. Text and QR codes read out of a photo are read on your own device and never reach us.
• Usage records: the time, type, model, token counts, estimated cost and credits of AI requests. These records do not contain the content of the request.
• Subscription data: your Remyra Pro status, the product and its expiry, the store’s order or transaction ID, and the purchase records and notifications from Google Play or the App Store. Your card details never reach us.
• Advertising data: without Pro, Google AdMob collects your IP address, advertising ID, device and app information and your interactions with ads; for rewarded ads, your account ID and the views Google confirms (view ID, ad unit, time) are processed.
• Support and error records: problem reports you send and error reports, which you can turn off. Error reports contain no memories, notes, photos or search questions.

3. Purposes

• Creating your account, signing you in and keeping the account secure.
• Backing up your memories and reminders and syncing them between your devices.
• Providing AI features, applying monthly credit limits, controlling cost and preventing abuse.
• Recognising and maintaining a Remyra Pro subscription and verifying purchases with the store.
• Showing ads in the free version, adding credits for rewarded ads and, only with your consent, showing personalised ads.
• Answering your questions, fixing faults and improving the service.
• Meeting our legal obligations.

4. Legal grounds

Under Article 5 of the KVKK we rely on: necessity for the performance of a contract (Art. 5/2-c) for accounts, backup and sync, AI credits and subscriptions; compliance with a legal obligation (Art. 5/2-ç); our legitimate interests (Art. 5/2-f) for security, abuse prevention, error reports, improving the service and non-personalised ads that fund the free version; and your explicit consent (Art. 5/1) for optional features such as sending a photo for AI analysis, and for personalised ads.

5. Transfers abroad

Some providers we use are outside Türkiye, so the related data is transferred abroad: Google LLC receives what you send with an AI request (Google's Vertex AI), the text of address searches and the areas of maps you view (Google Places, Google Maps) and the advertising data described above (Google AdMob) and, if you sign in with Google, handles that sign-in; Google and Apple verify your store purchases; Apple Inc. handles Sign in with Apple and its email relay; Cloudflare, Inc. provides network protection, encrypted database backups and Pro photo backup (R2, EU jurisdiction); Amazon Web Services (Amazon SES, Stockholm region) delivers verification and password reset emails; our hosting provider runs the API, database and error tracker. These transfers are made within the framework of Article 9 of the KVKK.

6. How data is collected

Data is collected electronically and directly from you while you use the app: what you enter when creating an account, what you save in the app, what you send with an AI request, the technical records created by the app's requests to our server, and the data collected by the Google ad and map components in the app.

7. Your rights

Article 11 of the KVKK gives you the right to learn whether your personal data is processed, to request information about it, to learn the purpose of processing and whether it is used accordingly, to know the third parties in Türkiye or abroad it is transferred to, to have incomplete or incorrect data corrected, to request deletion or destruction under Article 7, to have correction, deletion and destruction notified to third parties, to object to a result against you produced solely by automated analysis, and to claim compensation for damage caused by unlawful processing.

The app also lets you use some of these rights directly: Settings → Privacy & security exports your records as a file and deletes everything on the device, and Settings → Account deletes your account and its cloud copies.

8. Making a request

Send your request to destek [at] re-my-ra.com in line with the Turkish Communiqué on Application Procedures to Data Controllers, stating your name, the email address registered to your account and your request. We answer within thirty days at the latest. If your request is refused, our answer is not satisfactory or we do not answer in time, you may lodge a complaint with the Turkish Personal Data Protection Board.