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Official Legal DocumentEffective: October 12, 2026Version v2.0

Privacy Policy & Personal Data Protection (KVKK / GDPR Notice)

This document is published publicly in accordance with App Store Connect, Google Play Console, and regulatory requirements.

Article 1 - Identity of the Data Controller

Pursuant to Turkish Personal Data Protection Law No. 6698 ("KVKK"), General Data Protection Regulation ("GDPR"), and applicable privacy regulations, your personal data is processed by Bugim Platform as the data controller.

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    Official Website: bugim.online
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    Official Privacy & Data Contact: support@bugim.online

(Bugim maintains no call center, physical branch, or external registration agencies outside of these official credentials).

Article 2 - Processed Personal Data Categories & Masking Standards

Bugim strictly adheres to data minimization principles. Only minimal necessary data is processed:

1
Identity Data: First and last name. In public lobby lists and radar views, names are masked (e.g. A K) for privacy.
2
Contact Data: Phone number (for SMS/OTP two-factor security authentication) and email address.
3
Location (GPS) Data: Active foreground GPS location is used solely to calculate nearby radar events within a 20 km radius and to verify physical venue arrival (150-metre check-in perimeter). Background continuous tracking is NEVER conducted. Location data is never sold to advertisers or data brokers.
4
Profile & Demographic Data: Age range, gender, biography, optional Instagram username, city/district, blurred avatar photo (unblurred only upon mutual event confirmation).
5
Security & Device Data: Unique device identifier (UUID), device model, OS version, IP address, port details, session tokens, and consent timestamps (under statutory Law No. 5651 logging mandates).
6
Community & Review Data: Host cards created, meetup participations, lobby votes, double-blind rating scores, and report/block logs.
7
Financial Data: Club Pass subscription payments are processed exclusively by Apple App Store and Google Play Store. Bugim never views, processes, or stores credit/debit card numbers or security codes (CVC).

Article 3 - Purposes of Personal Data Processing

Personal data is processed for:

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    Account registration, identity verification via SMS OTP, and security protection.
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    Calculating radar proximity and listing nearby meetups.
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    Verifying physical presence at event venues (150-metre GPS check-in).
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    Preserving statutory access logs for 2 years pursuant to Law No. 5651 Art. 7.
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    Operating the double-blind review system to maintain community trust.
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    Reviewing user safety reports within 24 hours and enforcing zero-tolerance policies.

Article 4 - Methods of Data Collection and Legal Grounds

Data is gathered through automated mobile application forms and system permissions, based on:

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    Contract Performance (KVKK Art. 5/2-c / GDPR Art. 6/1-b): Account creation, matchmaking, venue check-in verification, Club Pass service delivery.
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    Legal Obligation (KVKK Art. 5/2-ç / GDPR Art. 6/1-c): Law No. 5651 traffic and access logging, responding to lawful court orders.
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    Legitimate Interest (KVKK Art. 5/2-f / GDPR Art. 6/1-f): Community safety, preventing fake accounts, operating Ghost Shield masking.
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    Explicit Consent (KVKK Art. 5/1 / GDPR Art. 6/1-a): Optional profile avatar, Instagram username, and live GPS sharing.

Article 5 - Data Transfers and Security

Data is stored securely on encrypted cloud databases (Supabase, AWS) and notification gateways (Firebase FCM, Apple APNs). Data is never sold, leased, or distributed to marketing agencies or third parties.

Article 6 - Retention and Deletion Policy

When an account is deleted via the mobile app or web deletion form, profile and personal data are immediately purged or irreversibly anonymized. Mandatory legal traffic logs under Law No. 5651 are automatically destroyed after the statutory 2-year retention window.

Article 7 - Rights of the Data Subject (KVKK Art. 11 / GDPR Art. 15-22)

Users possess the right to:

1
Learn whether personal data is processed,
2
Request information regarding processing,
3
Ascertain processing purposes and compliance,
4
Know third-party recipients,
5
Request rectification of inaccurate data,
6
Request erasure or destruction of personal data,
7
Object to automated decision-making,
8
Claim compensation for unlawful processing.

Article 8 - Application Procedure and Contact

To exercise your rights, email us from your registered account to support@bugim.online. Inquiries are resolved free of charge within 30 days.

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    Website: bugim.online
  • •
    Support: support@bugim.online