Privacy Policy

This Privacy Policy explains how ZOLLO APP YAZILIM TİCARET LİMİTED ŞİRKETİ ("Zollo Apps", "we", "us" or "our") collects, uses, shares and protects personal data when you use our website zollo.app and our mobile applications and games (together, the "Services").

1. Who we are (data controller)

The data controller responsible for your personal data is:

ZOLLO APP YAZILIM TİCARET LİMİTED ŞİRKETİ
Güzeloba Mah. Rauf Denktaş Cad. No: 56/102, Muratpaşa / Antalya, Türkiye
Trade Registry No: 146316 (Antalya Trade Registry)
Tax No: 9991520975 (Antalya Kurumlar Vergi Dairesi)
Email: support@zollo.app

We act as the "data controller" (veri sorumlusu) under the Turkish Personal Data Protection Law No. 6698 ("KVKK") and, where applicable, the EU/UK General Data Protection Regulation ("GDPR").

2. Scope

This policy applies to all Services published by Zollo Apps on the Apple App Store, Google Play and our website. Some apps may have features that require additional information; in that case, the app will explain it in-app and in its App Store "App Privacy" label or Google Play "Data safety" section, which form part of this policy.

This policy does not cover third-party websites or services linked from our Services, which have their own privacy policies.

3. Data we collect

3.1 Data you give us

• Support & communications: your email address, name (if provided) and the content of messages when you contact us.
• Account data (only in apps that offer accounts): email address, display name, and authentication identifiers if you use Sign in with Apple or Google Sign-In. With Sign in with Apple you may choose to hide your real email address.
• User content: content you create or save inside an app (e.g. notes, settings, game progress). Where possible, this is stored only on your device or in your own iCloud / Google account.

3.2 Data collected automatically

• Device & technical data: device model, operating system and version, app version, language, region/time zone, and a random app-instance identifier.
• Usage data: anonymous or pseudonymous events such as screens viewed, features used, game levels played, session length and in-app interactions.
• Diagnostics: crash reports, performance data and error logs that help us fix bugs.
• Advertising identifiers: in ad-supported apps, the Apple IDFA (only if you allow tracking) or the Google Advertising ID, plus ad interaction data. See Section 6.
• Purchase data: confirmation that a purchase or subscription was made and its status. We never receive your full payment card details; these are handled by Apple or Google.
• Website data: when you visit zollo.app, our hosting provider (Cloudflare) processes your IP address and standard request logs for security and delivery. We do not use advertising cookies on our website.

3.3 Data we do not collect

Unless an app clearly asks for it for a specific feature, and only with your permission, we do not collect precise location, contacts, photos, microphone or camera data, health data, or other special categories of personal data. Any permission can be revoked at any time in your device settings.

4. How and why we use your data

We do not sell personal data, and we do not use personal data for automated decision-making that produces legal or similarly significant effects on you.

5. Service providers we work with

We share data only with trusted providers who process it on our behalf under contracts and appropriate safeguards. Depending on the specific app, these may include:

The exact providers used by each app are disclosed in its App Store privacy label and Google Play data safety section. We may also disclose data if required by law, court order or a competent authority, to protect our rights and users' safety, or as part of a merger, acquisition or sale of assets (in which case this policy will continue to apply).

6. Advertising and tracking

• iOS: we will only track you across apps and websites owned by other companies if you allow it through Apple's App Tracking Transparency prompt. You can change this anytime in Settings → Privacy & Security → Tracking. If you decline, you will only see non-personalised or contextual ads.
• Android: you can reset or delete your advertising ID in Settings → Privacy → Ads.
• EEA, UK and Switzerland: ad-supported apps show a consent message (via a certified Consent Management Platform) before personalised ads are served. You can change your choice from the app's settings.
• Where available, removing ads via an in-app purchase stops ad-related data processing within that app.

7. In-app purchases and subscriptions

All payments are processed by Apple (App Store) or Google (Google Play). We receive only the information needed to confirm and manage your purchase (for example, a transaction identifier, product, date and subscription status). Refunds and billing are handled under the store's policies.

8. International data transfers

Our service providers may process data outside Türkiye, including in the United States and the European Union. For such transfers we rely on the mechanisms available under Article 9 of the KVKK (such as standard contracts notified to the Personal Data Protection Authority, or your explicit consent where required) and, for GDPR, on adequacy decisions or the European Commission's Standard Contractual Clauses.

9. How long we keep data

• Account data and user content: for as long as your account is active; deleted within 30 days after you delete your account.
• Analytics and diagnostics: typically up to 14 months, then deleted or anonymised.
• Support emails: up to 2 years after the request is resolved.
• Purchase and financial records: as long as required by Turkish tax and commercial law (generally up to 10 years).

When data is no longer needed, we delete, destroy or anonymise it in line with the KVKK Regulation on the Deletion, Destruction or Anonymisation of Personal Data.

10. Security

We use appropriate technical and organisational measures, including encryption in transit (TLS), access controls, least-privilege principles and reputable infrastructure providers, to protect your data. No method of transmission or storage is 100% secure, but we work hard to protect your information and will notify you and the authorities of any breach where required by law.

11. Children's privacy

Our Services are not directed at children under 13 (or the minimum age of digital consent in your country, e.g. 16 in some EU countries). We do not knowingly collect personal data from children. Where a game may appeal to younger audiences, we configure it to serve only non-personalised, age-appropriate ads and to disable behavioural tracking, in line with COPPA, GDPR and store requirements. If you believe a child has provided us with personal data, contact us at support@zollo.app and we will delete it.

12. Your rights

Depending on where you live, you have the right to:

• know whether we process your personal data and receive information about it;
• access a copy of your data and, where applicable, receive it in a portable format;
• request correction of incomplete or inaccurate data;
• request deletion or destruction of your data;
• object to or restrict certain processing, including processing based on legitimate interests;
• withdraw consent at any time (this does not affect processing carried out before withdrawal);
• learn the purpose of processing, whether data is used accordingly, and the third parties to whom it is transferred in Türkiye or abroad;
• object to a result against you arising from analysis exclusively by automated systems;
• claim compensation for damages arising from unlawful processing.

Türkiye (KVKK Article 11): you may submit requests to us in writing or by email in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. We will respond free of charge within 30 days at the latest. You may also lodge a complaint with the Personal Data Protection Authority (kvkk.gov.tr).

EEA / UK: you may lodge a complaint with your local data protection supervisory authority.

California (CCPA/CPRA): you have the right to know, delete and correct personal information and to opt out of its "sale" or "sharing". We do not sell personal information. To opt out of cross-context behavioural advertising, deny tracking permission or reset your advertising ID as described in Section 6. We will not discriminate against you for exercising your rights.

To exercise any right, email support@zollo.app with the subject "Privacy request". We may need to verify your identity before acting on a request.

13. Deleting your account and data

In apps that support accounts, you can delete your account directly in the app (usually Settings → Account → Delete account). You can also request deletion by email. See our Account & Data Deletion page for full instructions.

14. Changes to this policy

We may update this policy from time to time. The "last updated" date at the top shows when it was last changed. If changes are significant, we will notify you in-app or by other appropriate means before they take effect.

15. Contact us

For any privacy question or request, contact:

ZOLLO APP YAZILIM TİCARET LİMİTED ŞİRKETİ
Güzeloba Mah. Rauf Denktaş Cad. No: 56/102, Muratpaşa / Antalya, Türkiye
Email: support@zollo.app