Data Controller: Zeynep Türker
Contact: fhouse.floatinghouse@gmail.com
Location: Balıkesir, Türkiye
Zeynep Türker ("PLATÉ", "we," "our," or "us"), an individual developer, respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use the PLATÉ mobile application.
1. Purpose
PLATÉ processes users' personal data in accordance with applicable data protection laws, including but not limited to the Law on the Protection of Personal Data No. 6698 ("Law No. 6698"), the EU General Data Protection Regulation (GDPR), and the UK Data Protection Act 2018 (UK GDPR).
Personal data that you provide to the Company, or which is obtained through other means, may be processed by PLATÉ as a Data Controller for specific and lawful purposes, in a limited and proportional manner, while ensuring data accuracy and currentness.
2. Collection of Personal Data and Method
PLATÉ collects and processes personal data for purposes outlined in this policy. This includes information such as:
- Anonymous User ID: Automatically generated via Firebase (no email required).
- Device Information: Device model, OS version, unique device identifiers, locale/language settings.
- Purchase History: In-app coin purchases, subscription status, and transaction receipts.
- Uploaded Images: Photos temporarily uploaded for AI processing.
- Usage Data: Features used, filters applied, session duration, and crash logs.
Unlike traditional apps, PLATÉ uses anonymous authentication and does NOT collect: name and surname, email address or phone number, login credentials (username, password), or advertising identifiers (IDFA/AAID) for marketing purposes.
Data Categories and Types
| Category |
Data Types |
| Identity Information |
Anonymous User ID (Firebase UID) |
| Process Security |
IP address, device info, session tokens |
| Visual Records |
Photos uploaded by the user (temporarily processed, NOT stored permanently) |
| Customer Transaction |
Order data, coin balance, subscription status |
3. Purposes and Legal Basis of Processing
3.1 Purposes
- Provide and maintain the Service (generating images via AI).
- Manage subscriptions and in-app purchases (Coins).
- Legal compliance and enforcement.
- Service improvement and personalization.
- Information security and business continuity.
- Customer support and complaint resolution.
3.2 Legal Grounds
- Contract Performance: Necessary to provide the AI generation service you purchased.
- Legal Obligations: Compliance with tax and consumer laws.
- Legitimate Interests: Improving app stability and security.
4. Third-Party Sites and Services
Our applications may include links to external websites or services. We share data with the following third-party providers solely for the purpose of operating the app:
- Firebase (Google): Authentication, database, and analytics infrastructure.
- Google Cloud Vertex AI / Gemini: Artificial Intelligence API for image processing and generation.
- Apple App Store: Processes all payments. We do not have access to your credit card information.
User-uploaded photos and prompts are sent to Google Cloud servers solely for generating the requested content. We do not allow third parties to use your data to train their public models, in accordance with Google Cloud's data privacy commitments.
5. Cookies and Tracking Technologies
We use limited technologies to improve your experience. We do not use cookies for advertising purposes.
We use identifiers for:
- Analytics: To understand app usage and crashes (Firebase Analytics).
- Session Management: To keep your coin balance and settings synced.
6. Push Notifications
We may send push notifications related to service updates (e.g., "Your image is ready") or alerts. You can manage or disable notifications via your device settings.
7. Data Retention
Personal data is retained only as long as necessary.
- Active Users: Anonymous account data is retained while the app is installed or active.
- Photos: Deleted immediately after the AI generation process is complete (< 24 hours). We do not build a permanent library of your uploads.
- Purchase Records: Retained for 7 years as required by tax laws.
- Deleted Accounts: If you use the "Delete Account" feature, all data associated with your anonymous ID is permanently deleted within 30 days.
8. Security Measures
PLATÉ applies technical and administrative measures to protect personal data, including:
- Encryption (HTTPS/TLS) for data in transit.
- Firebase security rules to restrict database access.
- No permanent storage of sensitive user photos.
9. Data Transfers
Personal data may be transferred internationally for processing (e.g., to Google Cloud servers).
- These transfers are necessary to provide the AI service.
- We ensure compliance with Standard Contractual Clauses (SCCs) for GDPR and UK GDPR requirements.
10. Your Rights
Under Article 11 of Law No. 6698, the GDPR (EU), and the UK Data Protection Act 2018, you have the right to:
- Request information on how your data is processed.
- Request deletion of your data ("Right to be Forgotten").
- Object to processing.
To exercise these rights:
- In-App: Go to Settings > Privacy > Delete Account to instantly remove your anonymous data.
- Email: fhouse.floatinghouse@gmail.com
- Response Time: We will respond within 30 days.
11. Children's Privacy
Our Service does not address anyone under the age of 13 (or 16 in certain jurisdictions like the UK/EU). We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.
12. Updates to the Policy
PLATÉ may update this Privacy Policy. Continued use of our services following changes constitutes your acceptance of the new terms. Updates will be indicated by the "Effective Date" at the top.
13. Contact Information
Email: fhouse.floatinghouse@gmail.com
Address: Balıkesir, Türkiye
Supervisory Authorities
- Turkey (KVKK): Personal Data Protection Authority — kvkk.gov.tr
- UK (ICO): Information Commissioner's Office — ico.org.uk