Privacy Policy

Effective Date: January 1, 2025 | Last Updated: January 1, 2025

1. Introduction

Epinko Teknoloji Limited Sirketi ("we", "us", "our", or "Company"), located in Turkey, is committed to protecting your privacy when you use the Goalwise mobile application ("App"). This Privacy Policy explains what information we collect, how we use it, how we share it, and how we protect it.

This policy applies to all users of our App regardless of location, and we comply with applicable data protection laws including GDPR, CCPA, and Turkish data protection regulations (KVKK).

2. Information We Collect

2.1 Information You Provide

• Account Preferences: Favorite teams, preferred leagues, display settings, and notification preferences
• User Settings: Language preferences, theme settings, and app configuration
• Support Communications: Information you provide when contacting customer support

2.2 Automatically Collected Information

• Device Information: Device type, model, operating system version, unique device identifiers (IDFA/GAID), screen resolution, and device language
• Usage Data: App interactions, features used, screens viewed, session duration, and timestamps
• Technical Data: IP address (anonymized), crash reports, performance data, and error logs
• Analytics Data: Aggregated and anonymized usage statistics collected through Firebase Analytics

2.3 Subscription Information

• Subscription status and type (weekly/monthly)
• Purchase dates and renewal information
• Note: All payment processing is handled by Apple App Store or Google Play Store. We do NOT collect or store your payment card information, billing address, or financial data.

3. How We Use Your Information

We use the collected information for the following legitimate purposes:

• Service Delivery: To provide, maintain, and improve our App features and services
• Personalization: To customize content based on your preferences (favorite teams, leagues)
• Technical Support: To diagnose technical issues, prevent fraud, and ensure App security
• Analytics: To understand how users interact with our App and improve user experience
• Subscription Management: To verify subscription status and provide appropriate access levels
• Communication: To respond to your inquiries and send service-related notifications
• Legal Compliance: To comply with applicable laws and legal obligations

4. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), we process personal data based on:

• Contract Performance: To provide the services you requested
• Legitimate Interests: To improve our services and ensure security
• Consent: For optional analytics and personalization features
• Legal Obligation: To comply with applicable laws

5. Information Sharing and Disclosure

We do NOT sell, rent, or trade your personal information to third parties. We may share your information only in the following limited circumstances:

5.1 Service Providers

• Firebase (Google): Analytics, crash reporting, and performance monitoring
• RevenueCat: Subscription management and verification
• API-Football: Match data, statistics, and live scores (no personal data shared)
• Anthropic (Claude AI): AI-powered match analysis (no personal data shared, only match data)
• Supabase: Backend infrastructure and edge functions

5.2 Other Disclosures

• Legal Requirements: When required by law, court order, or government request
• Safety: To protect the rights, safety, or property of our users or others
• Business Transfers: In connection with a merger, acquisition, or sale of assets

6. Data Security

We implement industry-standard security measures to protect your data:

• TLS/SSL encryption for all data transmission
• Secure cloud infrastructure with regular security audits
• Access controls and authentication measures
• Regular security assessments and vulnerability testing
• Data minimization practices

While we strive to protect your information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

7. Data Retention

We retain your personal data only for as long as necessary:

• Account Data: Retained while your account is active and for 30 days after deletion request
• Analytics Data: Aggregated and anonymized, retained for up to 26 months
• Support Communications: Retained for up to 2 years
• Legal Requirements: Data may be retained longer if required by law

8. Your Rights and Choices

Depending on your location, you may have the following rights:

• Access: Request a copy of personal data we hold about you
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your personal data ("Right to be Forgotten")
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing based on legitimate interests
• Restriction: Request limitation of processing
• Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, contact us at [email protected]. We will respond within 30 days.

9. Children's Privacy

Our App is not intended for children under the age of 13 (or 16 in some jurisdictions). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately, and we will delete such information.

10. International Data Transfers

Your data may be transferred to and processed in countries outside your country of residence, including the United States (for Firebase, RevenueCat) and European Union (for Supabase). We ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data Processing Agreements with all service providers
• Compliance with applicable data transfer regulations

11. Third-Party Services

Our App integrates with third-party services, each with their own privacy policies:

• Apple App Store: Apple Privacy Policy
• Google Play Store: Google Privacy Policy
• Firebase: Firebase Privacy
• RevenueCat: RevenueCat Privacy Policy

12. California Privacy Rights (CCPA)

California residents have additional rights under the CCPA:

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of the sale of personal information (we do NOT sell personal information)
• Right to non-discrimination for exercising privacy rights

13. Do Not Track

Our App does not respond to "Do Not Track" signals. However, you can control analytics collection through your device settings.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be effective when posted. For significant changes, we will provide notice through the App or via email. We encourage you to review this policy periodically.

15. Platform Compliance

This App and Privacy Policy comply with:

• Apple App Store Review Guidelines
• Google Play Store Developer Policies
• General Data Protection Regulation (GDPR)
• California Consumer Privacy Act (CCPA)
• Turkish Personal Data Protection Law (KVKK)