KVKK Privacy Notice (Türkiye)
Last updated: November 5, 2026
This Notice was prepared to inform users of the Ferah app in accordance with Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform.
Data controller
Data controller under the KVKK: Darius Medya Limited Şirketi · Gazicelal Mah. 10052 Sk. Özmen İş Merkezi K:2 No:25, Edremit / Balıkesir, Türkiye · Edremit Chamber of Commerce registration no. 9502 · digital@dariusmedya.com
Information within the app
The profile, habit, journal, saved-moment, health-benefit, badge, garden, Savings Jar, and game information you enter in Ferah is processed only on your phone. This information is not sent to us or transferred by us to third parties; we cannot see it.
- Purpose: to provide the features you request, such as quit-smoking tracking, motivation, journaling, the garden, and the health timeline.
- Legal basis: establishment and performance of a contract for general information under Article 5(2)(c). Because information such as smoking, mood, craving level, and smoking again may be considered health data and therefore sensitive personal data, the consent you give during initial setup by reading and accepting the Privacy Policy, under Article 6(3)(a).
- Withdrawing your consent: Because Ferah cannot function without this information, you can withdraw your consent by deleting your information: you may first obtain a copy through Profile > Export my data and then delete it using Delete my account.
If you enable optional Backup, a copy of this information is written, by your choice, to your own iCloud or Google Drive account. The legal ground for this is the explicit consent you give separately when enabling Backup (Article 6(3)(a), and Article 9 for transfers abroad). We cannot access this backup.
Other personal data we process, purposes, and legal bases
Purchase information
- Data: order information the store sends us as a sales report (the order number, plan, date, and information such as country to the extent shared by the store). The validity of your Pro entitlement is checked directly with the store on your phone; no information is sent to us for this.
- Purpose: to track Pro sales, respond to consumer requests, and comply with tax and similar legal obligations.
- Legal basis: establishment and performance of a contract under Article 5(2)(c), compliance with a legal obligation under Article 5(2)(ç), and the establishment, exercise, or protection of a right under Article 5(2)(e).
Email correspondence
- Data: your email address and message.
- Purpose: to respond to your request.
- Legal basis: legitimate interests under Article 5(2)(f). You do not need to include health information in your message; if you voluntarily include it, we do not use any portion that is unnecessary to respond and delete it as soon as possible.
Collection method
Information within the app is processed by automated means on your phone to the extent that you enter it. Sales information is sent to us electronically by the store (Apple or Google) as a sales report, and email correspondence is collected electronically when you email us.
Transfers
- Google (Google Workspace): emails you send us are stored in our Google Workspace email account under our business agreement with Google; its servers may be located outside Türkiye. You choose whether to email us; the transfer is made with the safeguards described in Google's privacy and data processing terms and, to the extent the law requires, based on your explicit consent.
- Apple / Google: sign-in, backup to your own account, and purchase transactions are handled by these companies under their own terms; their servers may be located outside Türkiye. You initiate these transactions, and your separate consent is obtained for Backup.
- Advisors: only when necessary for accounting, tax, or a legal dispute and subject to confidentiality obligations.
- Authorized public authorities and judicial authorities: only when legally required.
- A person taking over Ferah: if Ferah is transferred to another person, only the email and purchase records we hold, provided that the same protections remain in place.
Apart from these circumstances, your personal data is not transferred to anyone in Türkiye or abroad.
Retention periods
- Email correspondence: no later than 1 year after the matter is resolved; if there is a dispute, until it is resolved.
- Purchase records: during the subscription and for the periods required by distance-contract, tax, and commercial-books legislation.
- Records that must legally be retained for a longer period are retained for the applicable period; when that period expires, they are deleted, destroyed, or anonymized.
Security and data breaches
We take reasonable technical and administrative measures for the records we hold, such as restricting access, using a strong password, and enabling two-step verification. If we become aware that others have unlawfully obtained these records, we will notify you and the Personal Data Protection Board as soon as possible under Article 12 of the KVKK.
Your rights under Article 11 of the KVKK
- to learn whether your personal data is processed and, if so, request information about the processing,
- to learn the purpose of the processing and whether your personal data is used in accordance with that purpose,
- to know the third parties in Türkiye or abroad to whom your personal data is transferred,
- to request correction if your personal data has been processed incompletely or inaccurately,
- to request deletion or destruction under the conditions set out in Article 7 of the KVKK,
- to request that correction, deletion, and destruction be communicated to third parties to whom your personal data has been transferred,
- to object to an adverse result arising from the analysis of your personal data exclusively through automated systems,
- to request compensation if you suffer damage due to unlawful processing.
Application
You may submit your application to digital@dariusmedya.com, clearly stating your first and last name; if you are a citizen of the Republic of Türkiye, your Turkish ID number; if you are a foreign national, your nationality and passport or identification number; your address for service; your contact information; and your request. You may also submit your application by email signed with a secure electronic signature or mobile signature, or as a signed written petition to Gazicelal Mah. 10052 Sk. Özmen İş Merkezi K:2 No:25, Edremit / Balıkesir, Türkiye. We may request only the additional information necessary to verify your identity.
Your application will be resolved free of charge within no more than 30 days. If the process requires an additional cost, the fee specified in the tariff set by the Personal Data Protection Board may be charged. If your application is rejected, you find the response inadequate, or no response is provided on time, you may file a complaint with the Personal Data Protection Board within 30 days after learning of the response and, in all cases, within 60 days after the date of your application.
You can view and export the data on your phone through Profile > Export my data and delete it using Delete my account.
