1. Data controller
The data controller under Personal Data Protection Law No. 6698 (KVKK) is:
CONTRAWORKS YAZILIM DANIŞMANLIK VE TİCARET LTD. ŞTİ., VEKO GİZ Plaza 3/79, Maslak / Sarıyer / Istanbul, Türkiye. Tax Office: Maslak · Tax ID: 2111316977 · destek@birnefes.app
2. Personal data processed
- Device and transaction security: random device ID, IP address, platform, version, session and security logs
- Use and preferences: content-category choices, display/progress, pause entitlement and usage times
- Purchases and entitlements: store, product, verification result and subscription status
- Communication: email, device code, verification details and request content supplied during support or KVKK applications
3. Purposes
- create and authenticate an anonymous device session
- deliver selected content, pause duration and app-pausing experience
- manage viewed content and learning progress
- apply the 14-day introductory period, daily free entitlement and Premium
- verify store subscriptions and manage entitlements
- prevent fraud, abuse and security incidents
- resolve support, deletion and data-subject requests
- meet legal duties and protect rights in disputes
4. Legal grounds
The duty to inform and explicit-consent process are separate. Withdrawal does not affect earlier lawful processing; personalization based on the relevant preferences may end.
- Contract formation or performance for sessions, entitlements, content delivery and purchase verification — KVKK Art. 5/2(c)
- Compliance with legal obligations for billing, consumer requests and authority notices — Art. 5/2(ç)
- Establishment, exercise or protection of rights and legitimate interests for security and abuse prevention — Art. 5/2(e)-(f)
- Contract performance and protection of rights for support requests
- A suitable condition under Art. 6 and explicit consent where necessary for potentially sensitive content preferences
5. Collection method
Data is obtained wholly or partly by automated means through the mobile app, operating-system permissions, ContraWorks servers, App Store or Google Play verification responses and email. Selected-app lists and iOS Screen Time tokens are primarily processed on-device.
6. Transfers
Data may be transferred, strictly for stated purposes, to competent public authorities, legal advisers and essential technical providers. Bir Nefes data is hosted in Türkiye. Apple and Google may act as independent controllers for their store operations.
7. Retention
Active device and usage records are kept during the service relationship; inactive records for up to 24 months after last use, then deleted or anonymized. Legal, security and application records are limited to necessary statutory periods.
8. Your rights under KVKK Article 11
- learn whether your personal data is processed and request information
- learn the purpose and whether data is used accordingly
- know recipients in Türkiye or abroad
- request correction of incomplete or inaccurate data
- request deletion or destruction when conditions apply and notification to recipients
- object to adverse results of automated analysis
- claim compensation for unlawful processing
9. How to apply
Send your application with identity and in-app device/support code to destek@birnefes.app or our postal address. We may request proportionate information for verification. Applications are normally resolved free of charge within 30 days; statutory fees may apply where processing creates additional cost.
Contact us at about these documents. destek@birnefes.app
