This notice is for users in Türkiye (under the Turkish Personal Data Protection Law, “KVKK”, No. 6698) and in the EU/UK (under the GDPR). It sits alongside our Privacy Policy and explains the legal bases and rights that apply to you. The data controller is Rulead, based in İstanbul, Türkiye.
1. Data controller
Rulead (İstanbul, Türkiye) is the data controller for personal data processed through Posme. Contact: [email protected].
2. What we process and why
| Data | Purpose | Legal basis |
|---|---|---|
| Device identifier | Run the app without an account; one session per device | Legitimate interest / performance of service |
| Name, email, profile photo, provider ID (Google/Apple sign-in) | Create and manage your account | Performance of a contract |
| Gender selection | Personalize example poses and images | Explicit consent |
| The single submitted frame | Generate your pose guide via our AI provider | Performance of a contract |
| Purchase and entitlement status | Provide shots and subscriptions | Performance of a contract |
| Technical logs | Security and reliability | Legitimate interest |
3. Transfers abroad
Our providers (the AI provider, Supabase, RevenueCat, Apple, Google) may process data outside Türkiye and the EU, including in the United States. Where required, such transfers rely on your explicit consent or appropriate safeguards (such as standard contractual clauses).
4. Retention
We keep personal data for as long as your account exists or as needed for the purposes above and to meet legal obligations, then delete or anonymize it. The submitted frame is used to create your result and is not retained by us as part of a gallery; your photos stay on your device.
5. Your rights (KVKK Art. 11 / GDPR)
- Learn whether we process your data and request information about it.
- Access, correct, or complete your data.
- Request deletion or destruction where the legal grounds for processing no longer apply.
- Object to processing and, under the GDPR, request data portability.
- Withdraw a consent you gave (for example, the gender-based personalization) at any time.
- Lodge a complaint with the Turkish Data Protection Authority (KVKK) or your local EU/UK supervisory authority.
6. How to exercise them
Email [email protected] with your request. We may need to verify your identity, and we'll respond within the periods required by KVKK and the GDPR.
7. Changes
We'll update the date above if this notice changes.
This document is for general information and is not legal advice.