Gallery Cleaner: AI Sweep — Privacy Policy
Version 1.0 · Effective date: 19 October 2026 · Last updated: 19 October 2026
Data controller: Tuğrulhan Çınar, trading as Portal Studio, Kemalöz Mahallesi, 2. Barut Sk. No: 16, Kat: 1, Daire: 2, Uşak/Merkez, Türkiye · Contact: portalstudio.info@gmail.com
Summary
- Your photos never leave your device to reach us. Gallery Cleaner analyses your photo library on your device. We do not run a server for your content and we never receive your photos, videos or anything derived from them — similarity prints, quality scores, face data, text read from photos, notes, lists, names, receipts or the Private Vault.
- No account. The App does not ask for your name, e-mail address or phone number.
- A few features send small pieces of information over the internet, never the photo itself: place names and venues (Apple Maps), book and film details (Open Library, Wikidata), subscriptions (Apple, RevenueCat), ads in the free version (Google AdMob), usage statistics, crash reports and remote settings (Google Firebase).
- Ads in the free version are personalised only if you allow tracking in iOS and, in the EEA, the UK and Switzerland, in Google's consent form. Premium shows no ads and does not start the ad software.
- Face grouping creates face data only on your device. We never receive, sell or share it.
- You can delete everything stored on your device by deleting the App — but remember that this also deletes the Private Vault (see our Terms and Conditions, Section 6.9).
- Your rights under the GDPR, UK GDPR, Turkish KVKK, U.S. state laws and other laws are described in Section 12. Write to us at portalstudio.info@gmail.com.
1. Who we are and what this policy covers
1.1 This Privacy Policy explains how Tuğrulhan Çınar, trading as Portal Studio ("we", "us", "our"), handles personal data in connection with the Gallery Cleaner: AI Sweep application for iPhone and iPad, its widgets, Siri and Shortcuts actions, Spotlight entries and notifications (together, the "App"), our support e-mail and any support pages we operate for the App.
1.2 For the processing described in this policy we are the data controller within the meaning of the EU General Data Protection Regulation ("GDPR"), the UK GDPR and the Turkish Law No. 6698 on the Protection of Personal Data ("KVKK"), except where this policy says that another company acts as an independent controller.
1.3 This policy applies together with our Terms and Conditions (Terms and Conditions). Words defined in the Terms (such as "Your Media", "Suggestion" and "Private Vault") have the same meaning here.
1.4 This policy does not cover the processing that Apple, Google or other third parties carry out for their own purposes under their own privacy policies (for example when you use iCloud, the App Store, Siri or Google's services). Links to their policies are given below.
2. Our core principle: analysis happens on your device
2.1 The App's analysis of Your Media — finding duplicates, bursts, blurry photos, screenshots and long videos, grouping faces, reading text, recognising documents, receipts and recipes, building the search index, suggesting items for lists, detecting possibly sensitive photos, assembling memory films and composing their music — runs on your device.
2.2 We do not operate a server for your content. Your photos and videos, and all data derived from them, stay on your device (and in Apple's backups of your device, if you use them). We have no access to them.
2.3 We do not use Your Media to train any artificial-intelligence model, and we do not sell, rent or share Your Media with anyone.
3. Data stored only on your device
3.1 To work, the App stores the following data locally on your device, in the App's own storage and in an App Group shared with the App's widgets. None of it is sent to us.
| Data | What it is |
|---|---|
| Library index | Technical identifiers of the items in your library, capture dates, sizes, types, locations taken from photo metadata, and analysis results (similarity prints, quality and blur scores, categories, detected text and spoken words, document, receipt and recipe classifications, semantic search vectors). |
| Face data | Numerical face representations ("face prints") produced by the on-device face-recognition model, face groups, your corrections, the person you marked as "This is me" and the names you give to people. See Section 4. |
| Your content | Lists and list memberships, notes and tags, product and warranty records, receipt corrections, expense reports, growth journals, wardrobe corrections, place marks, smart rules, cleanup history and the decisions you made ("keep", "rejected", "done"). |
| Private Vault | Copies of the original files you moved into the Vault, with an index (file name, capture date, date added). Protected by iOS Data Protection and opened through Face ID, Touch ID or your device passcode. |
| Sensitive-content results | Only if you turn this experimental feature on: scores of the on-device sensitive-content model. Turning the feature off deletes them. |
| Cached place and title information | City names, venue positions and book or film details that were looked up once (Section 5) and are kept on your device so that they need not be asked again. |
| Settings and counters | Your settings, language and appearance, your notification choices, your usage-analytics choice with its date (Section 9), the use of Free Allowances, the cached subscription status, and technical flags (for example whether the tracking pre-prompt was shown). |
| Widget data | Small summaries (space you can free, a memory of the day with its thumbnail) written to the App Group so that the widget can display them. |
3.2 Device backups. If you use iCloud Backup or back up your device to a computer, iOS may include this local data — including the Private Vault — in that backup. Such backups are provided and controlled by Apple or by your computer; we have no access to them.
3.3 System features. If you use them, iOS also processes some of this information in its own on-device features: Spotlight can show your lists, people and trips in system search; Siri and Shortcuts pass your question and the App's answer through Siri; widgets and notifications can show counts, names, memories and thumbnails on your Home Screen and Lock Screen. You control these features in iOS settings.
3.4 Deletion. You can delete individual content in the App. Turning off face grouping deletes the face prints and groups (the names and corrections you entered are kept). Turning off sensitive-content detection deletes its results. Deleting the App deletes all of this local data from your device, including the Private Vault.
4. Face data and biometric information
4.1 When face grouping is on, the App uses an on-device face-recognition model to create numerical representations of faces found in your photos and to group photos of the same person. This is done only on your device.
4.2 We do not collect, capture, receive, purchase, store on our systems, sell, lease, trade, disclose or otherwise profit from face prints, face groups or any other biometric identifier or biometric information. This data is never transmitted to us or to any third party, and it is not used for advertising or analytics. The analytics described in Section 5 contain only a rounded count of how many people you have named — never a face, a name or a photo.
4.3 Retention and destruction. Face data remains on your device until (a) you turn off face grouping in the App's settings, which deletes face prints and groups; (b) you delete the App; or (c) the related photo is removed from your library and the index is updated. Because we never possess this data, we cannot access, export or delete it for you — these controls are in your hands.
4.4 Photos of other people. Your library may contain photos of other people. Face grouping is a feature for your personal and household use. You are responsible for using it lawfully and for respecting the rights of the people in your photos (see Terms, Sections 7.2 and 8.2).
4.5 Face ID and Touch ID. When you open the Private Vault with Face ID or Touch ID, the authentication is performed entirely by iOS. The App receives only the result (success or failure) — never your face or fingerprint data.
5. Data that leaves your device
The following table lists every way in which information leaves your device through the App. No photo or video is ever sent in any of these cases.
| Recipient | What is sent | When | Why |
|---|---|---|---|
| Apple Maps — reverse geocoding (Apple) | One coordinate per area in which your located photos were taken | When Trips or Search need a city name; each area is asked once and the answer is cached on your device | To show place names (for example "in Bursa") |
| Apple Maps — venue search (Apple) | The name of a venue read from a screenshot and the approximate centre of the area you are most often in | When the places map opens; if "Near you" or "Remind me before a trip" is on, when the App comes to the foreground (cached) | To place your saved venues on the map and to notify you near them |
| Apple Maps — geocoding for trip reminders (Apple) | Only a location typed as text in a calendar event in the next three days (for example "İzmir"), and the area around your usual places as a search region — never the event's title, time, attendees, notes or meeting links, and never the coordinates of a place picked on a map | If "Remind me before a trip" is on, when the App comes to the foreground (cached) | To find out whether an event is in another city |
| Apple Maps — map tiles and "Open in Maps" (Apple) | The map region displayed (including the area around your current location when you tap "Near me"); the location of a photo when you tap "Open in Maps" | When you open the map or tap these options | To display maps |
| Open Library (Internet Archive, USA) | A book title or ISBN read from a photo; a technical "User-Agent" with the App's name and version; your IP address (as with any internet request) | When a Books list is opened | To show the author, year and similar details |
| Wikidata (Wikimedia Foundation, USA) | A film or series title read from a photo; your IP address | When a Films / Series list is opened | To show the year and similar details |
| Apple — model downloads (Background Assets) | Ordinary download request data (such as IP address and device type); no information about your library | After the first launch | To download the on-device AI model used for search and analysis |
| Apple — iCloud Photos | Requests for originals that are stored only in iCloud | When you open, shrink, convert, move into the Vault or analyse an item whose original is not on the device | To work on the full-quality original |
| Apple — Translate and Siri | The text of a photo you choose to translate; the question you ask Siri or Shortcuts and the App's answer (for example "186 photos on 24 different days") | Only when you tap "Translate text" or use Siri or Shortcuts | To translate text and answer your request (you can download languages in iOS to translate on device) |
| Apple — speech recognition | No content from your videos; if needed, only a speech-language model is downloaded | When speech in videos is made searchable | Transcription takes place on your device |
| RevenueCat (RevenueCat, Inc., USA) | A random App User ID created by RevenueCat that does not identify you; your purchase and subscription history from the App Store (product, transaction identifiers, purchase and expiry dates, price, currency, storefront country, trial and renewal status); device and app information (device model, iOS version, app version, language and region); your IP address | At launch, when you buy or restore Premium and when your subscription status is checked | To verify and restore your subscription and to see aggregated sales statistics |
| Google AdMob and User Messaging Platform (Google) — free version only | Your IP address and the approximate location derived from it, device model, iOS version, app identifier and version, language, interactions with ads (views, taps), consent status and — only if you allow tracking — the advertising identifier (IDFA); attribution of ad installs through Apple's SKAdNetwork | If you do not have Premium: at launch (if your consent status is known) and when ads are requested or shown | To show and measure ads, prevent fraud and — only with your permission — personalise ads |
| Google Firebase Analytics (Google) | A random app-instance identifier, the App's own fixed event names and parameters, rounded or bucketed counts, and summary properties (see 5.3); device model, iOS version, app version and language; a country or region derived by Google from the IP address | While the App is used; in the EEA, the UK, Switzerland and Türkiye only after you allow it; never while Usage analytics is off (Section 9) | To understand how the App is used and to improve it |
| Google Firebase Crashlytics (Google) | Technical crash data: the error and stack trace, device state at the time of the crash (such as device model, iOS version, free memory and disk space, orientation), app version and a random installation identifier | When the App crashes or encounters a serious error (in release versions), with the same consent and Settings switch as Firebase Analytics | To find and fix errors |
| Google Firebase Remote Config (Google) | A Firebase installation identifier, app version, platform, language or region settings and technical SDK data | At launch and periodically (at most about once an hour) | To receive remote settings, such as advertising frequency and the minimum supported App version |
5.1 No identifier that identifies you. We do not send your name, e-mail address, phone number, Apple Account or any account of ours with these requests. The identifiers used (Firebase app-instance and installation IDs, RevenueCat's App User ID) are random. The advertising identifier (IDFA) is read only if you allow tracking.
5.2 Never sent to analytics, crash reports or ads: photos or videos; text read from photos or spoken in videos; names of people; face data; locations; the names of albums, lists, places or trips; your notes and tags; search terms or questions; receipt contents; anything you type. This is enforced in the App's code: analytics accept only fixed labels and numbers.
5.3 Analytics properties. Besides events (for example a screen opened, a feature used, a cleanup completed with rounded counts and sizes, ad and subscription events), Firebase Analytics receives these summary properties: Premium or not; photo-access level; library size (in ranges); whether indexing is complete; number of people named (in ranges); whether the Vault is used; number of your own lists (in ranges); App language; appearance; notification and tracking permission status; personal-setup stage; whether Apple Intelligence is available; free space on the device (in ranges); and whether a widget is installed. No user ID is set. Google Signals is turned off. The App sets Google's advertising consent signals for Analytics to "denied", and the collection of the identifier for vendors (IDFV) by Analytics is turned off.
5.4 Support e-mails. If you write to us, we receive your e-mail address, your name if you give it, the content of your message and any attachments or device information you choose to include. Please do not send us private photos, payment details or passwords.
5.5 Apple's own analytics. If you have chosen in iOS settings to share analytics with app developers, Apple may provide us with aggregated usage statistics and crash reports about the App. Apple decides what is included; we cannot identify you from it.
5.6 Purchases. Subscriptions are sold by Apple. Apple processes your payment as an independent controller; we never receive your payment card or bank details.
6. What we do not do
- We do not upload Your Media or anything derived from it.
- We do not create an account for you or ask for your name, e-mail address or phone number.
- We do not read your contacts.
- We do not track your location. Location is used on your device only for the features described in Section 7, and is never stored by us or sent to us.
- We do not use your photos, notes, lists, search terms or any library content for advertising, and we do not send them to advertisers.
- We do not read the advertising identifier unless you allow tracking.
- We do not sell Your Media and we do not sell personal data for money.
- We do not use automated decision-making that produces legal or similarly significant effects on you.
7. Permissions
The App asks for each permission only when a feature needs it. You can change your choices at any time in iOS settings.
| Permission | Why | What happens without it |
|---|---|---|
| Photos (full or limited) | To analyse, organise, search and clean up your library; analysis happens on your device | The App cannot work with your library; with limited access only the photos you selected are analysed |
| Notifications | Weekly cleanup reminder, "On this day" memories, anniversaries, trip films, warranty reminders, place alerts and reminders before a trip — all scheduled locally on your device | No notifications |
| Location while using the App | "Near you": iOS monitors the areas of your saved places (up to 5 on the free plan, up to 20 with Premium) and notifies you nearby; "Near me": your location is read once to sort your places by distance. Your location stays on your device | These features are not available |
| Calendars (full access, read only) | "Remind me before a trip": the locations of your events in the next three days are read on your device; no event is changed, stored or sent (only a typed location text is looked up in Apple Maps, see Section 5) | This feature is not available |
| Reminders | To add the ingredients you choose from a recipe screenshot to Reminders; existing reminders are not touched | This feature is not available |
| Face ID | To open the Private Vault; your face data never leaves the device and is never accessible to the App | You can use your device passcode instead |
| Speech Recognition | To make speech in your videos searchable; transcription happens on your device | Spoken words are not searchable |
| Tracking (App Tracking Transparency) | To allow personalised ads in the free version | You still see ads, but they are not based on your interests; the advertising identifier is not read |
8. Advertising and tracking
8.1 Free version only. The free version shows ads served by Google AdMob: a banner in Library, interstitial ads between some pages and a rewarded ad before deleting with swipe review. With Premium no ads are shown and the ad software is not started.
8.2 App Tracking Transparency. The iOS question "Allow the App to track your activity?" is shown after you first free up space in the App, preceded by a short explanation. If you decline, the advertising identifier is not read and ads are not personalised. You can change your choice in iOS Settings → Privacy & Security → Tracking.
8.3 EEA, United Kingdom and Switzerland. Before ads are requested, Google's consent form lets you decide whether personalised ads and the storage of or access to information on your device may be used for advertising purposes. You can change your choice at any time under Settings → Ad privacy options in the App.
8.4 U.S. states. Where U.S. state laws require it, Google's form offers you a choice to opt out of the "sale" or "sharing" of personal information for targeted advertising (see Section 12.4).
8.5 Google's use of data. Google acts as an independent controller for some of the data it collects through AdMob. See How Google uses information from sites or apps that use its services and the Google Privacy Policy.
9. Purposes and legal bases
| Purpose | Data | Legal basis (GDPR / UK GDPR) | Legal basis (KVKK) |
|---|---|---|---|
| Providing the App's features at your request (place names, venue search, trip reminders, map display, book and film details, model downloads, iCloud originals) | Coordinates, venue names, typed event locations, titles, ISBNs, IP address | Performance of the contract with you (Art. 6(1)(b)) | Necessary for the conclusion or performance of a contract (Art. 5(2)(c)) |
| Selling, verifying and restoring subscriptions; preventing purchase fraud | RevenueCat App User ID, purchase history, device and app information, IP address | Performance of a contract (Art. 6(1)(b)); our legitimate interest in preventing fraud (Art. 6(1)(f)) | Performance of a contract (Art. 5(2)(c)); legitimate interest (Art. 5(2)(f)) |
| Aggregated sales statistics | Purchase history (aggregated) | Legitimate interest in understanding our business (Art. 6(1)(f)) | Legitimate interest (Art. 5(2)(f)) |
| Showing ads in the free version, measuring them and preventing ad fraud | IP address, approximate location, device and app information, ad interactions, consent status | Your consent where required (Art. 6(1)(a)), in particular for personalised ads and access to your device in the EEA, UK and Switzerland; otherwise our legitimate interest in funding the free version (Art. 6(1)(f)) | Explicit consent where required (Art. 5(1)); legitimate interest (Art. 5(2)(f)) |
| Personalised ads using the advertising identifier | IDFA, ad interactions | Your consent (Art. 6(1)(a)) given through App Tracking Transparency and, where applicable, Google's consent form | Explicit consent (Art. 5(1)) |
| Usage statistics to improve the App | Firebase app-instance ID, fixed events, bucketed properties, device information | In the EEA, the UK and Switzerland: your consent (Art. 6(1)(a); for storing and reading the analytics identifier on your device, Art. 5(3) of the ePrivacy Directive and the equivalent national rules, such as the UK PECR), asked once in the App before anything is sent. Elsewhere: our legitimate interest in understanding and improving the App (Art. 6(1)(f)) | In Türkiye: your explicit consent (Art. 5(1)), asked once in the App before anything is sent. Elsewhere: legitimate interest (Art. 5(2)(f)) |
| Crash reports to fix errors | Crash data, device state, installation ID | In the EEA, the UK and Switzerland: your consent (Art. 6(1)(a) and Art. 5(3) ePrivacy Directive), given with the same question as usage statistics. Elsewhere: our legitimate interest in a stable and secure App (Art. 6(1)(f)) | In Türkiye: your explicit consent (Art. 5(1)), given with the same question. Elsewhere: legitimate interest (Art. 5(2)(f)) |
| Remote settings (ad frequency, minimum supported version) | Firebase installation ID, app version, platform | Our legitimate interest in operating, securing and updating the App (Art. 6(1)(f)) | Legitimate interest (Art. 5(2)(f)) |
| Answering your requests and complaints | E-mail address, message content | Performance of a contract and our legitimate interest (Art. 6(1)(b) and (f)); legal obligation where a request concerns your rights (Art. 6(1)(c)) | Performance of a contract, legal obligation, legitimate interest (Art. 5(2)(c), (ç), (f)) |
| Establishing, exercising or defending legal claims; complying with law | Data relevant to the claim or obligation | Legitimate interest and legal obligation (Art. 6(1)(f) and (c)) | Establishment, exercise or protection of a right; legal obligation (Art. 5(2)(e), (ç)) |
Your right to object and to withdraw consent. Where we rely on legitimate interests, you may object at any time (Section 12). For usage statistics and crash reports (Firebase Analytics and Crashlytics) you do not need to write to us:
- In the EEA, the UK, Switzerland and Türkiye the App asks you once, with two equally weighted choices ("Allow" and "Don't allow"), before any of this data is collected. Nothing is sent until you answer, and declining has no effect on the App's features. We decide whether to ask from your device's region setting and from Google's location-based answer in its ad consent tool; if either indicates one of these regions, you are asked.
- Elsewhere usage statistics and crash reports are on by default.
- In all regions you can switch them off or on at any time under Settings → Privacy → Usage analytics in the App. Switching off, or declining, stops collection immediately, deletes crash reports that have not yet been sent and the analytics data stored on your device, and resets the analytics identifier, so that data collected after you switch it back on is not linked to the earlier identifier.
We keep a record of your choice on your device (the choice, its date and the version of the question). Withdrawing consent does not affect the lawfulness of processing before the withdrawal. Data already sent to Firebase is deleted automatically after the periods in Section 11; to ask for earlier deletion, write to us (Section 12.2).
10. Recipients and international transfers
10.1 Recipients. Personal data described in Section 5 is received by the following categories of recipients: Apple (maps, model downloads, iCloud, Siri, Translate, App Store); Google (AdMob, User Messaging Platform, Firebase Analytics, Crashlytics and Remote Config); RevenueCat (subscription management); the Internet Archive (Open Library) and the Wikimedia Foundation (Wikidata). RevenueCat and Google (for Firebase) process data on our behalf as processors or service providers; Apple, the Internet Archive, the Wikimedia Foundation and, for some advertising purposes, Google act as independent controllers under their own policies. We may also disclose data where required by law, to comply with a court order or a lawful request of a public authority, or to protect our rights, safety or property or those of others. If our business is transferred (for example in a merger or acquisition), personal data may be transferred to the successor, which will remain bound by this policy until it is changed with notice.
10.2 Transfers abroad. Some recipients process data outside your country, in particular in the United States. For users in the EEA, the UK and Switzerland, such transfers rely on an adequacy decision (including the EU-U.S. Data Privacy Framework and its UK and Swiss extensions, where the recipient is certified) or on the Standard Contractual Clauses approved by the European Commission (and their UK and Swiss equivalents) offered by the recipient. For users in Türkiye, transfers abroad are carried out under Article 9 of the KVKK: on the basis of the standard contracts published by the Personal Data Protection Board, entered into with the recipient and notified to the Authority within the statutory period, or, where such safeguards are not available, on the basis of the other grounds listed in Article 9 — including, for incidental transfers, your explicit consent. Usage statistics and crash reports (Firebase Analytics and Crashlytics) of users in Türkiye, the EEA, the UK and Switzerland are collected and transferred to Google only after you have allowed them in the App (Section 9). If you decline, or later switch off Usage analytics in Settings, no further such data is transferred.
10.3 Third-party policies. Apple · Google · Firebase · RevenueCat · Internet Archive · Wikimedia Foundation
11. How long data is kept
| Data | Retention |
|---|---|
| Data stored on your device (Section 3), including face data and the Private Vault | Until you delete it in the App, turn off the related feature or delete the App |
| Firebase Analytics event data | 14 months, then deleted automatically |
| Firebase Crashlytics crash reports | 90 days |
| Firebase Remote Config and installation identifiers | Under Google's Firebase retention terms; a new identifier is created after reinstalling the App |
| AdMob and User Messaging Platform data | Under Google's retention policies |
| RevenueCat subscription records | As long as necessary to provide and verify your subscription and to meet legal and accounting requirements; deleted on a verified request, unless retention is legally required |
| Support e-mails | As long as needed to handle your request and up to two (2) years afterwards, unless a longer period is required by law or to establish, exercise or defend legal claims |
| Place, venue and title information looked up through Apple Maps, Open Library and Wikidata | We do not receive this data. The answers are cached on your device. The recipients retain request data under their own policies |
When the retention period ends, data is deleted, destroyed or anonymised in accordance with applicable law, including the Turkish Regulation on the Deletion, Destruction or Anonymisation of Personal Data.
12. Your rights
12.1 General. Depending on where you live, you may have the right to access your personal data, to receive a copy, to have it corrected or deleted, to restrict or object to its processing, to data portability, to withdraw consent at any time (without affecting processing before the withdrawal), and to lodge a complaint with a supervisory authority.
12.2 How to exercise your rights. Most data is stored only on your device and is fully under your control (Section 3.4). For data held by us or our processors (Firebase, RevenueCat) write to portalstudio.info@gmail.com. Because the App has no account and the identifiers it uses are random, we may not be able to link data to you. To help us, please tell us what you want and, if possible, include information that allows us to find the relevant records (for example the date and the Apple order number of a purchase). We may ask for information to verify your request. We answer within one month (GDPR) or thirty days (KVKK), or within the period required by the law that applies to you.
12.3 European Economic Area, United Kingdom and Switzerland. You have the rights under Articles 15 to 22 GDPR (and the corresponding provisions of the UK GDPR and the Swiss FADP). You may object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests. You can complain to the data protection authority of your country of residence, place of work or the place of the alleged infringement; in the UK this is the Information Commissioner's Office (ICO).
12.4 United States — California and other states.
(a) Notice at collection. In the past twelve months we have collected, through the App and our service providers, the following categories of personal information: identifiers (random app-instance, installation and App User IDs, IP address and — only with your permission — the advertising identifier); commercial information (subscription and purchase history); internet or other electronic network activity information (interactions with the App and with ads); and approximate geolocation derived from the IP address. We do not collect sensitive personal information on our systems: face data and precise location stay on your device. The sources, purposes and retention periods are described in Sections 5, 9 and 11.
(b) "Sale" and "sharing". We do not sell personal information for money. If you allow personalised ads, Google may use information collected through AdMob for cross-context behavioural advertising, which may constitute "selling" or "sharing" under California and other U.S. state laws. You can opt out by (i) choosing "Ask App Not to Track" in iOS or turning tracking off in iOS Settings → Privacy & Security → Tracking; (ii) using the "do not sell or share" choice in Google's form under Settings → Ad privacy options, where offered; or (iii) subscribing to Premium, which turns ads off. We do not knowingly sell or share the personal information of consumers under 16.
(c) Your rights. You have the right to know and access the personal information we collect, to delete it, to correct it, to opt out of its sale or sharing, and not to be discriminated against for exercising these rights. You may use an authorised agent; we may ask the agent for proof of authorisation and verify your identity. We respond within 45 days, which may be extended as permitted by law.
(d) Other U.S. states. Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon and other states with comprehensive privacy laws have similar rights. If we decline your request, you may appeal by replying to our answer with the subject "Appeal". We will respond within the period required by your state's law. If your appeal is denied, you may contact your state Attorney General.
12.6 Other countries. If the law of your country gives you additional rights, write to us and we will tell you how we can meet them.
13. Security
13.1 Data stored by the App on your device is protected by iOS Data Protection; Vault files are protected so that they cannot be read while the device is locked. Network requests made by the App use encrypted connections (HTTPS/TLS). We keep the data that leaves your device to the minimum needed and choose service providers that offer appropriate safeguards.
13.2 No method of storage or transmission is completely secure. The security of the data on your device also depends on you — on your device passcode, your Face ID or Touch ID settings, your Apple Account and your backups. To the extent permitted by law, we are not responsible for access to data on your device by anyone who can unlock it, or for the security of files after you export or share them. If we become aware of a personal-data breach affecting data under our control, we will notify you and the competent authorities as required by law.
14. Children
The App is not directed to children under 13, and we do not knowingly collect personal data from children under 13 (or under the age of digital consent in your country). If you believe that a child has provided us with personal data, contact us and we will delete it.
15. Do Not Track and Global Privacy Control
The App does not respond to browser-based "Do Not Track" signals. Your tracking choice in iOS and your choices in Google's consent form are the mechanisms the App honours.
16. Third-party services and links
The App contains links to and integrations with third-party services (for example Apple Maps, the App Store and advertisers). When you leave the App or interact with an ad, the privacy policy of that third party applies. We are not responsible for their practices.
17. Changes to this policy
We update this policy whenever the App's data practices change — before a new type of data, a new recipient or a new purpose is introduced. The "Last updated" date at the top shows the latest version. If a change is material, we will inform you in the App or in another appropriate way. Where a change requires your consent under applicable law, we will ask for it.
18. Contact
Data controller: Tuğrulhan Çınar (Portal Studio), Kemalöz Mahallesi, 2. Barut Sk. No: 16, Kat: 1, Daire: 2, Uşak/Merkez, Türkiye E-mail: portalstudio.info@gmail.com
You can write to us in English or Turkish. For users residing in Türkiye, the Turkish version of this policy prevails; for all other users, the English version prevails.