Last update: November 2, 2020
- Introduction
1.1 Our Purpose
Here at Pepapp Teknoloji A.Ş. (“We”, “Us”, “Pepapp”), we are deeply concerned about our Users’ (“You”, “User”) privacy and to that end when you’re using Pepapp mobile application or our services (collectively “Application”, “App”) we process your personal data regardless of point of access or your country of residency. This Privacy Policy (“Policy”) informs you about who we are, why we are collecting your Personal Information, to whom we are sharing your information with, our legal basis and reasons for doing so, and finally your rights.
We reserve the right to and may change this Privacy Policy from time to time, in the event of any changes you will be notified by email (which you used for registration) or it will be presented in the app with the new version.
The Personal Information when signing-up for an account, inviting your friends, using the Application, or by contacting us, may differ for each action, and Pepapp using the Policy herein informs you about how we are handling your Personal Information.
1.2 Contact Details
Pepapp Company contact information:
| Name | Pepapp Teknoloji Anonim Şirketi |
| Location | İstanbul, Turkey |
| E-mail address | [email protected] |
| Trade Registry Number | Registered in Istanbul Trade Registry Directorate179346-5 |
| DPO Officer and/or EU Representative | Emrah Yiğit |
1.3 Definitions
For the Policy the definitions provided herein shall be understood as follows;
CCPA: The California Consumer Privacy Act of 2018, signed into law on June 28, 2018, by the State of California
CalOPPA: California Online Privacy Protection Act, signed into law on July 1, 2004, by the State of California
Controller: A natural or legal person who determines the means of and purposes for processing personal data
Data Subject: A natural person who can be identified or rendered identifiable through the personal data related to
GDPR: The General Data Protection Regulation, signed into law on May 25, 2018, by the European Union
Non-Personal Data: Information that is collected by Pepapp that cannot be tracked back to the data subject or rendered untraceable by Pepapp through the means of anonymization
Personal Information: Information that makes it possible for any other person to identify an individual to whom the data relates to
Personal Information Breach: A breach of security whether accidental or on purpose, resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.
Processing: Collecting and manipulating data items to generate meaningful information
Processor: A natural or legal person who processes personal data on behalf of a Controller
Sensitive Personal Information: Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership and; genetic and biometric information, information concerning data subject’s sex life or sexual orientation
Third-Party: Any other natural or legal person that is not part of Pepapp
- Collection of Personal Data and Information
2.1 Personal Information You Provide to Us To provide our services, understand your needs, and communicate with you:
2.1.1 The Personal Information listed hereunder may be collected when you;
- create an account,
- use our App,
- provide us with your feedback,
- purchase and use our premium services,
- contact us,
- make an order in PepStore section,
- recommend the App to your friends or,
- request technical support services.
2.1.2 The categories of personal information and types when you access or use the App, we may automatically collect;
- Contact Information Country, Email Address, Delivery Address, Telephone Number
- Financial Information Payment Card Details
- Identity Information First and Last Name, Place of Birth, Time and Date of Birth
- Marketing and Communications Information Preferences for marketing communications such as the Newsletter and how you engage with therewith
- Transaction Information Any and all details about payments from you and other related details thereto
- Personal Mood Information Daily Emotional Mood Information
- Health Information Ovulation and Menstrual Cycle Dates and Length, Ovulation and Menstrual Cycle Details, Daily Menstrual Pain Information, Daily Menstrual Bleeding Information, Daily Menstrual Symptoms, Medication Information, Height, Weight
- Sexual Life Details Usage of Birth Control Pills, Pregnancy Information, Planned Pregnancy Preference, Frequency of Sexual Activity, Protected Sexual Activity Information, Sex of the Unborn Baby
- Account Information Account Password
- Other Contacts
2.1.3 The Personal Information listed hereunder may be collected through automatic means including without limitation cookies, server logs and other technologies of equivalent nature. In cases where a Third Party uses our cookies, we may also receive Personal Information therefrom.
- User Feedback Feedback when prompted automatically by the App
- Technical Information Internet Protocol (IP) address, login data, device version and type, time zone settings, operating system and platform (collectively “Cookie Information”)
- Profile Information Password preferences and how you contact our User Services
- Usage Information The pages that you have visited, and time spent, the frequency of your use of App, the links that you access, language preferences
3. How Your Personal Information is Processed
Your Personal Information either given to or collected by us shall only be processed when necessary, to do so we may refer to reasons (“Processing Reason”) and a limited number of legal reasons (“Legal Basis”) associated therewith.
Your Personal Information may be used;
- To form the contract that we are entering or perform the contract that has entered with you,
- To comply with legal and/or regulatory obligations when required by the law, and
- When it is necessary for our legitimate interests given that your fundamental rights and interests are not violated.
We do not rely on consent for our legal basis except for your Health & Sexual Life Information, Marketing Preferences, and Contacts, which you can opt-out at any time in the App.
| Personal Information Category | Personal Information | Processing Reason | Legal Basis |
| Identity | First Name and Last Name | Creation of an account | Entering into a contract |
| First Name and Last Name | Making deliveries | Performance of a contract | |
| Birth Place | Provision of astrological predictions | Performance of a contract | |
| Birth Date and Time | Provision of astrological predictions | Performance of a contract | |
| Personal Mood | Daily Emotional Mood Information | Provision of premium services | Performance of a contract |
| Marketing and Communications Information | Marketing Preference | Personalized offers and services | Consent |
| Contact | Email Address | Creation of an account | Entering into a contract |
| Email Address | Notifying you about changes to our Policy | The necessity to comply with a legal obligation | |
| Email Address | Notifying you about changes in the App | Performance of a contract | |
| Notifying you about your purchased orders | Performance of a contract | ||
| Country | Determining App language | Legitimate interest in User satisfaction | |
| Country | Adjusting the scope of services, we provide | Legitimate interest in User satisfaction | |
| Telephone Number | Making deliveries | Performance of a contract | |
| Delivery Address | Making deliveries | Performance of a contract | |
| Financial Information | Payment Card Details | Processing the payment | Performance of a contract |
| Transaction Information | Payment History | In the event of a dispute | Legitimate interest to keep our records updated |
| Health | Ovulation and Menstrual Cycle Dates and Length | Provision of accurate period cycle predictions | Consent |
| Ovulation and Menstrual Cycle Details | Provision of accurate period cycle predictions | Consent | |
| Daily Menstrual Pain Information | Personalized period cycle predictions | Consent | |
| Daily Menstrual Bleeding Information | Provision of accurate period cycle predictions | Consent | |
| Daily Menstrual Symptoms | Personalized period cycle predictions | Consent | |
| Medication Information | Provision of accurate period cycle predictions | Consent | |
| Height | Personalized period cycle predictions | Consent | |
| Weight | Personalized period cycle predictions | Consent | |
| Sexual Life Details | Usage of Birth Control Pills | Personalized period cycle predictions | Consent |
| Pregnancy Information | Provision of accurate period cycle predictions | Consent | |
| Planned Pregnancy Preference | To support your pregnancy plans | Consent | |
| Frequency of Sexual Activity | To support your pregnancy plans | Consent | |
| Protected Sexual Activity Information | To support your pregnancy plans | Consent | |
| Sex of the Unborn Baby | Provision of accurate pregnancy recommendations | Consent | |
| User Feedback | Feedback | Improvement of the App | Legitimate interest to improve our App |
| Other | Contacts | To recommend by users | Consent |
| Account Information | Password | Creation of an account | Entering into a contract |
| Usage Information | Use of the App | Improvement of the App | Legitimate interest to study how our Users use the App |
| Technical Information | IP Address | Accessing the App | The necessity to comply with a legal obligation |
| Cookie Information | Improvement of the App | Legitimate interest to analyze how our App is performing |
4. Third Parties Processing Your Personal Data
We will not share your Personal Data with any third parties except as specified below.
- Technical Identifiers as; IP addresses, IDFA (iOS Advertising ID), GAID (Google Advertising ID) and Customer-issued user ID.
- Age group
- Subscription Status
- Application Usage Status
4.1 Processing Your Personal Data for Personalized Ads
Pepapp may share information with ad networks to serve you personalized ads. Pepapp use Mediation platform to optimize its’ ad revenue, you can find Admost Mediation’s Privacy Policy here. If you are not comfortable with any data being shared for ad customization, you can go to Settings and change your preferences as specified below;
- For iOS devices: Settings > Privacy > Advertising > Limit Ad Tracking.
- For Android devices: Google Settings > Ads > Opt Out of Interest-Based Ads. Another option is to reset the Advertising ID (IDFA) on your mobile device.
- For iOS Devices: Settings > Privacy > Advertising > Reset Advertising Identifier.
- For Android: Google settings > Ads > Reset advertising ID.
4.2 Processing Your Personal Data for User Acquisition
Pepapp may share non-health data with Adjust, a mobile marketing platform, for user acquisition. You can find Adjust’s Privacy Policy here. Pepapp send your data to analyze it and provide reports and insights on how to optimize our promotional campaigns. The aim of sharing your personal data is to find people who are likely to be interested in Pepapp.
You can see the detailed illustration of how we work with Adjust and its integrated partners:
ILLUSTRATION
You can opt-out from sharing your data with sending us and email at [email protected] or reset your Advertising ID as specified above.
4.3 Processing Data for Application Operation
Pepapp works with processors that perform particular operations with your Personal Data for Application Operation. These processing operations could only
These Processors act only in accordance with our instructions and process only such amount of Personal Data as we instruct them to process. We remain fully liable for any acts or omissions of our processors and undertake to execute formal data processing agreements with them to the extent required by applicable law.
You can see the list of Processors and the aim of using below;
| Processor | Privacy Policy | Purpose |
| Amazon Cloud Services | AWS Privacy Policy | Storage of Personal Data |
| Google Analytics | Google Analytics Privacy Policy | Analytics to improve the functionality of our App |
| Apple | Apple Privacy Policy | to collect and process payments for subscription to the App |
| Google Privacy Policy | to collect and process payments for subscription to the App | |
| Apple HealthKit | Apple Health Privacy Policy | Synchronize your “height”, “weight” and “menstruation” data with Apple HealthKit app in your Apple device |
| Google Fit | Google Fit Privacy Policy | Synchronize your “height”, “weight” and “menstruation” data with Google Fit app in your Android device |
| Freshdesk | Freshdesk Privacy Policy | to process and sort all emails received from you |
4.4 Links
The App may contain third party website links or embedded third-party media and services. Since this Policy applies to data that have collected by us, we want to inform you that Pepapp is not responsible from such data collection practices.
4.5 Information Posted by You
Information (including Personal Data) posted through App or Pepapp Website are open the Pepapp Community. What you post can be seen, disclosed to, or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes.
5. Information Security
We have enacted appropriate security measures to ensure the safety, protection and the encryption of your Personal Information such that we may prevent accidental or unauthorized destruction, loss, theft or; unauthorized use, alteration and disclosure.
To do so, we limit the accessibility of your Personal Information to our employees, agents, contractors, affiliates, directors and other relevant third parties on a need-to-know basis. Any legal or natural person processing your Personal Information shall be under the duty of confidentiality and shall act with fiduciary care.
In addition, any case of Personal Information Breach or reasonable suspicion of shall be handled according to our internal documents detailing how to act under such circumstances.
6. Children’s Privacy
Our App is not intended for those under the age of 16 (a “Minor”) as stipulated in our Terms of Use, as a result of this Pepapp does not knowingly collect and/or is provided with Personal Information belonging to a Minor.
If we learn that any Personal Information processed by us, belongs to a Minor we shall take the appropriate measures to delete such Personal Information.
7. GDPR Rights for EU people
General Data Protection Regulation imposes a restriction for using personal data without getting the consent of EEA and Switzerland users.
Any and all references to Personal Information in this Policy shall be read as “Personal Data” under GDPR.
Pepapp Teknoloji Anonim Şirketi is the data controller under the relevant provisions of GDPR as set forth in §1.2
Pepapp takes consent before reaching any Personal Data before the usage of App. Your Personal Data listed under §3.3 shall be processed,
- lawfully, fairly and in a transparent manner in relation to the Data Subject (“lawfulness”, “fairness” and “transparency”)
- accurately and where necessary, kept up to date (“accuracy”)
- for specific, explicit and legitimate purposes (“purpose limitation”),
- relevant, limited and proportionate to the purposes for which they are processed (“data minimization”), and
- in a manner that ensures appropriate security of the Personal Data and kept in a form which allows identification of Data Subjects for no longer than is necessary for the Processing Reasons.
7.1 Legal Basis
Legal Basis for processing Personal Data listed thereunder §3.3 shall be understood as listed under GDPR Art. 6 as;
Entering into a contract: Processing your Personal Data such that we can enter into a contract to provide you access to the App, i.e. signing up for an account
Performance for a contract: Processing your Personal Data such that we can honor our obligations arising out of the contract between you and Us, i.e. providing you the personalized period cycle
Necessity to comply with a legal obligation: Processing your Personal Data because of a valid European Law, i.e. logging your IP address
Legitimate interest: Processing your Personal Data for the security concerns or development of the App, i.e. your Transaction History
Consent: Giving us permission to use your Personal Data in accordance with our Processing Reasons via an opt-in mechanism
7.2 Your Rights
Right to be informed: Providing you with clear and concise information about company, your Personal Data collected by or given to us, generally our Policy
Right of access: Your request to learn your Personal Data collected by or given to us (“subject access”)
Right of rectification: Your request to rectify or complete, if incomplete, your Personal Data in relation with Art. 5 (1)(d) of GDPR
Right to erasure: Your request to have your Personal Data erased (“the right to be forgotten”)
Right to restrict processing: Your request to limit the way your Personal Data is used
Right to data portability: Your request to receive your Personal Data in a machine-readable format and/or request us to transfer your Personal Data to another Controller
Right to objects: Your request for us to stop processing your Personal Data
Rights in relation to automated decision making
In the cases where we process your Personal Data via automated decision making (where no human is involved, i.e. sending you personalized marketing offers based on your Transaction Information), you may request us to stop doing so.
Unless extenuating circumstances apply, we shall respond to your requests in one calendar month after your request has reached us, and we shall do so free of charge notwithstanding extraordinary efforts on our part.
*You may also delete your all data, including your processed Personal Data. Please visit “Delete All Data” button in the settings section of App.
In cases where we take longer due to the number of requests, we shall notify you and keep you updated of the process.
We may also need identity-proving documentation on your part such that we can verify the identity of the requester, we may also contact you about your request in order for us to hasten the process.
7.3 Retention
We shall only keep your Personal Data in accordance with Principles under §7.3.2, specifically Data Minimization to the satisfaction of our relevant Legal Basis.
In determining your Personal Data retention, we consider the nature, amount, the potential risks associated with in case of Personal Data Breach, our Processing Reasons and whether or not such reasons can be achieved in a different manner.
We keep your Personal Data for different amounts of time and by exercising your right to access listed under §7.3.4, you can learn in detail our data retention policy.
7.4 International Transfers
Personal Information given to or collected by us may be sent out of the United States and/or the European Economic Area to be processed by us in our facilities or on the cloud services offered by our service providers.
We shall always protect your Personal Information regardless of where processing takes place.
7.5 Cross Border Transfer
If we transfer your Personal Information out of the Europe, we shall ensure the safety and security of your Personal Information and in cases where we are required to comply with different sets of regulations concerning your Personal Information, we shall do so.
8. California Privacy Rights
In regard to CalOPPA & CCPA and relevant state laws, Our Users and those who visit our App residing in the State of the California have the right to contact us to be informed about their Personal Information, if any processed by us or shared by us with third parties.
Pepapp takes consent before reaching any Personal Data before the usage of App.
If you satisfy the conditions listed hereunder, you may contact us at [email protected].
8.1 California and Delaware “Do Not Track” Disclosures
As per California and Delaware State Laws, Pepapp honors the “Limit Ad Tracking” settings in user devices that turn-off targeted advertising.
10. Contact Us
If you have any questions about this Privacy Policy, please contact us at [email protected].
