TR·EN

Privacy Policy

Last updated: 2026-05-16 · Effective: 2026-05-16

Gleam takes your personal data seriously. This policy is carefully prepared to be aligned with the Turkish Personal Data Protection Law No. 6698 (KVKK) and the EU General Data Protection Regulation (GDPR). The binding version is the Turkish text. Read it together with the KVKK Disclosure and the Cookie Policy.

Our core principles: data minimisation (we collect only what is necessary), purpose limitation (we use data only for the purposes disclosed), transparency and accountability.

In short (TL;DR)

1. Data controller

Bilal Uğur Yayla (individual project), Istanbul, Türkiye.
Contact: legal@yougleam.app · General support: help@yougleam.app

As the data controller is below the Turkish DPA threshold (10,000 individuals/year), registration with VERBİS is not required. A data protection representative is not appointed as the mandatory thresholds are not met; all requests go directly to the data controller.

2. Personal data we collect

The full table of categories and data types is in KVKK Disclosure Section 2. In summary: identity (name, username, date of birth), contact (email), account (profile photo, bio, preferences), content (moments, feelings, Glow/Relate interactions, bond chats, capsules, manifests), security (sign-in times, IP), optional (location, newsletter). We do not request special-category data (health, religion, biometrics, etc.); if a user shares such content in free text, it is their own declaration.

3. Purposes and legal bases of processing

Every processing activity relies on one of the following legal bases (KVKK Art. 5-6 / GDPR Art. 6):

PurposeData processedLegal basis
Account creation and managementIdentity, contact, accountPerformance of a contract
Bond system (mutual follow + mutual Glow match)Content, accountPerformance of a contract
Daily zodiac messageDate of birthPerformance of a contract
NotificationsDevice/push tokenConsent (can be turned off)
Newsletter / marketingEmailConsent (withdrawable)
Product-usage analyticsUsage events (no content)Legitimate interest
Location (city/country)User-declared locationConsent
Security, fraud and abuse preventionSign-in times, IP, logsLegitimate interest
Reports and moderation, community rulesReport record, related contentLegal obligation / legitimate interest
Legal obligations and legal claimsMinimum necessary dataLegal obligation

4. Cookies

Only essential cookies (theme, cookie preference) and cookieless anonymous visitor counting are used. There are no third-party advertising cookies, tracking pixels, Facebook Pixel or Google Analytics. Details: Cookie Policy.

5. Sharing and transfers

Other users

Service providers (data processors)

Service providers process data only on our instructions and within the limits of the contract.

International transfers

Primary database storage is in Tokyo, Japan (Supabase, AWS ap-northeast-1). Analytics in EU Frankfurt (PostHog). All cross-border transfers (Tokyo, US, EU) are made under Standard Contractual Clauses (SCC) + user explicit consent as per Turkish KVKK Art. 9 and GDPR Art. 46.

Legal authorities

Only with a valid court order or binding legal obligation, limited to the minimum data requested.

Advertisers

Never. Your data is not sold, rented or profiled for advertising.

6. Where data is stored

Primary storage: Tokyo, Japan (Supabase). Analytics: EU Frankfurt (PostHog). Backups kept encrypted. Cross-border transfers protected by SCCs.

7. Retention and erasure

Data whose retention period has expired is deleted, destroyed or anonymised through periodic erasure (at most every 6 months) or within 30 days upon request. When an account is deleted, all data is permanently erased within 30 days (except data we must retain by law).

8. Data security (KVKK Art. 12)

We apply appropriate technical and organisational measures:

No system is 100% secure; we aim for the highest reasonable protection.

9. Data breach notification

In case of a personal data breach, we notify the Authority/competent supervisory authority and affected users without undue delay (as a rule, within 72 hours under the GDPR), in line with KVKK and the GDPR.

10. Automated decision-making and profiling

We do not make decisions based solely on automated processing that produce legal effects or similarly significantly affect you. The zodiac message, Duel and Bond matching are app features only; no advertising, credit or employment-type profiling is performed.

11. Your rights

Under KVKK Art. 11 and the GDPR you have the rights of information/access, rectification, erasure ("to be forgotten"), restriction of processing, objection, data portability, withdrawal of consent, and objection to automated decisions.

To exercise them: email legal@yougleam.app with the subject "KVKK Application — [right]". Identity verification may be requested. Requests are answered free of charge within 30 days (a tariff set by the Authority may apply in case of disproportionate cost). If you are not satisfied, you may apply to the Turkish Data Protection Authority: kvkk.gov.tr.

12. Marketing and withdrawal of consent

Newsletter / waitlist sign-up is done only with explicit consent. You can request removal and to stop receiving email anytime via legal@yougleam.app. Withdrawal does not affect the lawfulness of prior processing.

13. Children's data

Gleam is for ages 13 and over. Date of birth is collected at sign-up and users under 13 are blocked from registering. If an under-13 user is detected, the account is closed and their data is deleted.

14. Third-party links

The site/app may contain third-party links. We are not responsible for the privacy practices of those sites; we recommend reviewing their policies.

15. Changes

We announce significant changes via in-app notification + email, with reasonable notice before they take effect. The current version is always on this page; the date is stated above.

16. Contact and complaints

Data controller: Bilal Uğur Yayla (individual project), Istanbul, Türkiye. For detailed categories, legal bases and the application procedure, see the KVKK Disclosure.