**Privacy Policy for SorÇöz** **Effective Date: 06/08/2026** **1. Introduction** Welcome to SorÇöz, a mobile application developed by PALMIA SALES LTD ("we," "us," or "our"). We understand that your privacy is of paramount importance, and we are deeply committed to protecting the personal data you share with us. This comprehensive Privacy Policy is designed to clearly and transparently explain how we collect, use, store, share, and protect your personal information when you use our SorÇöz mobile application (the "App"). As an expert privacy lawyer, we have meticulously crafted this policy to comply with the stringent requirements of major data protection laws, including the General Data Protection Regulation (GDPR) for users in the European Union (EU) and European Economic Area (EEA), the California Consumer Privacy Act (CCPA) for residents of California, and other applicable global privacy regulations. We aim to provide you with a clear understanding of your rights and our practices regarding your personal data. By accessing or using the SorÇöz App, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with this policy, please do not use our App. We encourage you to review this policy periodically as it may be updated from time to time to reflect changes in our practices or legal obligations. **2. Data Controller Information** PALMIA SALES LTD is the data controller responsible for the processing of your personal data collected through the SorÇöz App. This means we determine the purposes and means of processing your personal data. **Company/Developer Name:** PALMIA SALES LTD **Company Address:** 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ **Contact Email:** abdulganisen29@gmail.com **Website:** https://play.google.com/store/apps/details?id=app.sorcoz **3. Key Definitions** To help you better understand this Privacy Policy, we provide definitions for some key terms: * **Personal Data (or Personal Information):** Any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. For California residents, this aligns with the definition of "Personal Information" under the CCPA. * **Processing:** Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. * **Data Subject:** The identified or identifiable natural person to whom the personal data relates (i.e., you, the user). * **Data Controller:** The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. * **Service Provider:** Any natural or legal person who processes data on behalf of the Data Controller. This includes third-party companies or individuals employed by PALMIA SALES LTD to facilitate the App, provide the App on our behalf, perform App-related services, or assist us in analyzing how the App is used. * **GDPR:** The General Data Protection Regulation (Regulation (EU) 2016/679). * **CCPA:** The California Consumer Privacy Act of 2018. * **COPPA:** The Children's Online Privacy Protection Act. **4. Personal Data We Collect** At SorÇöz, we are committed to collecting only the data that is necessary for the purposes outlined in this policy. We do not collect any sensitive personal data (e.g., health information, racial or ethnic origin, political opinions, religious beliefs, genetic or biometric data) nor do we collect precise geographical location data. We also do not use cookies within the App. The types of personal data we collect fall into the following categories: **A. Information You Provide Directly to Us:** When you register an account, interact with the App, or communicate with us, you may provide us with the following personal data: * **Names:** We collect your name, or a display name, to identify you within the App, personalize your experience, and facilitate user-to-user interaction where applicable. This is typically collected during the account creation process, potentially through social login services. * **Email Addresses:** Your email address is collected primarily for account creation, login credentials, password recovery, and to enable us to communicate with you regarding your account, important service updates, or support inquiries. **B. Information Collected Automatically:** When you access and use the App, certain information about your device and usage may be collected automatically. This data helps us understand how our App is used, improve its functionality, and troubleshoot issues. * **Device & Technical Data:** We collect information about the device you use to access SorÇöz. This includes: * **Device Type:** The specific type of mobile device you are using (e.g., smartphone, tablet). * **Device Model:** The manufacturer and model of your device (e.g., iPhone 13, Samsung Galaxy S22). * **Operating System (OS):** The version of your device's operating system (e.g., iOS 15, Android 12). * *Purpose:* This data is crucial for ensuring the App functions correctly across various devices and operating systems, for debugging, for optimizing performance, and for developing future updates compatible with our user base. It also aids our analytics services in understanding device demographics. **C. Information Not Collected:** We explicitly state that we **do NOT collect** the following types of data: * **Sensitive Data:** As mentioned, we do not collect any special categories of personal data as defined by GDPR (e.g., health, religion, sexual orientation, political opinions, biometric data). * **Location Data:** We do not collect, process, or store any information about your precise geographic location. * **Cookies:** The SorÇöz App does not utilize cookies for tracking or any other purpose. * **Background Data Collection:** The App is not designed to collect any personal data while running in the background. Data collection only occurs when the App is actively in use by the user. **5. How We Use Your Personal Data** We use the personal data we collect for various purposes, all of which are designed to provide, maintain, improve, and secure the SorÇöz App and our services. Each use is carefully considered and aligned with our legal bases for processing. * **To Provide and Maintain the SorÇöz App:** * To register your account and facilitate your login to the App. * To enable you to use the core functionalities of the App, such as interacting with its features. * To ensure the technical functioning and stability of the App. * **To Improve and Personalize Your Experience:** * To understand how you and other users interact with the App, identifying areas for improvement and new feature development. * To personalize your experience within the App based on your usage patterns and preferences. * To troubleshoot and fix any technical issues or bugs that may arise. * **To Communicate with You:** * To send you important service-related announcements, updates, and administrative messages. * To respond to your inquiries, support requests, and feedback. * To deliver push notifications regarding App activity, new features, or important alerts, if you have opted-in to receive them. * **For Security and Fraud Prevention:** * To monitor and detect unauthorized access, fraud, or other malicious activities within the App. * To protect the integrity of our systems and the safety of our users. * To enforce our Terms of Service. * **For Analytics and Performance Monitoring:** * To analyze usage trends, measure the effectiveness of our App features, and understand user demographics. * To track app performance metrics such as crash reports and error rates, helping us to diagnose and resolve issues promptly. * To generate aggregated and anonymized statistical data for internal business analysis and reporting. * **For Advertising and Marketing:** * To display relevant advertisements within the App that may be of interest to you, based on your general usage patterns and interactions within the App, facilitated through third-party advertising services (e.g., Meta Ads). This helps support the free provision of the App. * *Please note: We do NOT sell your personal information for advertising purposes.* * **To Comply with Legal Obligations:** * To meet any applicable legal, regulatory, or governmental requirements. * To respond to legal requests, court orders, or subpoenas. **6. Legal Bases for Processing Your Personal Data (For EU/EEA Users - GDPR)** Under the GDPR, we must have a valid legal basis to process your personal data. We rely on the following legal bases for the various purposes outlined above: * **A. Performance of a Contract:** * When you create an account and use the SorÇöz App, you enter into a contract with us (our Terms of Service). We process your personal data (e.g., Names, Email addresses, Device Data) to fulfill our contractual obligations to you, such as providing you with access to the App, managing your account, and ensuring the App's core functionality. * *Examples:* Account registration, login, core app functionality, customer support related to contract performance. * **B. Your Consent:** * In certain situations, we may ask for your explicit consent to process your personal data for specific purposes. Where we rely on consent, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. * *Examples:* Sending you push notifications (you can opt-out at any time through device settings), certain analytics processing where specifically requested, or if we introduce new features requiring new forms of data processing that are not covered by other legal bases. * **C. Legitimate Interests:** * We may process your personal data when it is necessary for our legitimate interests, provided that these interests are not overridden by your fundamental rights and freedoms. We conduct a "balancing test" to ensure our legitimate interests are proportionate to your privacy rights. Our legitimate interests include: * Improving and optimizing the App's performance, user experience, and functionality. * Ensuring the security of the App and preventing fraud, unauthorized access, or other malicious activities. * Conducting analytics to understand user behavior, troubleshoot issues, and enhance our services. * Marketing and advertising our App (through services like Meta Ads) to reach a broader audience and support the App's operation, without selling your data. * Handling customer inquiries and support requests. * Protecting our legal rights and interests. * *Examples:* Collecting device data for analytics and performance monitoring, using anonymized data for business analysis, direct marketing communications for existing users where there is a clear relationship (subject to opt-out). * **D. Compliance with a Legal Obligation:** * We may process your personal data where it is necessary to comply with a legal or regulatory obligation to which PALMIA SALES LTD is subject. * *Examples:* Responding to valid court orders, subpoenas, or other legal requests from public authorities, complying with tax and accounting requirements. **7. Sharing and Disclosure of Your Personal Data** PALMIA SALES LTD values your privacy, and we want to be clear about our data sharing practices. * **We do NOT sell your personal information to third parties.** This is a firm commitment and is specifically compliant with the CCPA's "right to opt-out of sale" provision. * **We do NOT independently share your personal data with third parties for their own independent marketing purposes without your explicit consent.** However, we do engage with reputable third-party service providers who assist us in operating, analyzing, and improving the SorÇöz App. These third parties act as "data processors" on our behalf and are contractually bound to process your data only according to our instructions, implement appropriate security measures, and comply with applicable data protection laws, including GDPR and CCPA requirements. We only share the minimum necessary personal data with these service providers to perform their functions. We may disclose your personal data in the following limited circumstances: * **To Our Service Providers:** As detailed in Section 8, we use third-party tools and services for analytics, advertising, and user authentication. These service providers may have access to or process your personal data as part of providing their services to us. * **For Legal Reasons:** We may disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to: * Comply with a legal obligation or lawful request from public authorities (e.g., a subpoena or court order). * Protect and defend the rights or property of PALMIA SALES LTD. * Prevent or investigate possible wrongdoing in connection with the App. * Protect the personal safety of users of the App or the public. * Protect against legal liability. * **Business Transfers:** In the event that PALMIA SALES LTD is involved in a merger, acquisition, asset sale, or bankruptcy, your personal data may be transferred as a business asset. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy. **8. Third-Party Service Providers** The SorÇöz App integrates with various third-party services to enhance functionality, provide analytics, enable social logins, and support advertising. These providers may collect and process data in accordance with their own privacy policies. We encourage you to review their policies for a complete understanding of their data practices. * **A. Analytics Services:** * **Firebase (Google LLC):** We use Google Firebase for analytics, crash reporting, and general backend services. Firebase helps us understand how users interact with the App, monitor performance, identify bugs, and manage push notifications. Firebase may collect device data (device type, model, OS), unique identifiers (e.g., Firebase installation ID), and usage data (e.g., how often the app is opened, features used, session duration). This data helps us improve the App's stability and features. * *For more information, please refer to Google's Privacy Policy:* [https://policies.google.com/privacy](https://policies.google.com/privacy) * **Meta SDK (Facebook, Inc.):** The Meta SDK is integrated to help us analyze app usage, track app events (e.g., account creation, specific actions within the app), and understand user engagement. This data is also used to support our advertising efforts through Meta Ads, helping us to deliver more relevant advertisements and measure their effectiveness. The SDK may collect device identifiers, usage data, and information about in-app actions. * *For more information, please refer to Meta's Data Policy:* [https://www.facebook.com/policy.php](https://www.facebook.com/policy.php) * **B. Advertising Services:** * **Meta Ads (Facebook, Inc.):** We use Meta Ads to display advertisements within the SorÇöz App. This service utilizes data collected via the Meta SDK (as described above) to personalize ads and measure campaign performance. While we do not sell your data, Meta's services may use information about your activity within the App to show you more relevant ads. You can often manage your ad preferences through your device settings or directly within Meta's platforms. * *For more information, please refer to Meta's Data Policy:* [https://www.facebook.com/policy.php](https://www.facebook.com/policy.php) * **C. Social Login Services:** * **Google Sign In (Google LLC):** We offer Google Sign In as a convenient way to create an account and log into SorÇöz. When you choose to sign in with Google, you grant us permission to access basic profile information, typically your name and email address, which we use for account identification within the App. We do not access other information from your Google account. * *For more information, please refer to Google's Privacy Policy:* [https://policies.google.com/privacy](https://policies.google.com/privacy) * **Apple Sign In (Apple Inc.):** If available on your device and selected by you, we also offer Apple Sign In for account creation and login. Similar to Google Sign In, this service allows you to use your Apple ID to sign in, providing us with your name and email address (or a private relay email address if you choose to hide your email). We use this information for account identification. * *For more information, please refer to Apple's Privacy Policy:* [https://www.apple.com/legal/privacy/](https://www.apple.com/legal/privacy/) * **D. Other Services:** * **Firebase (Google LLC):** In addition to analytics, Firebase also provides other backend services critical for the App's operation, such as cloud messaging for push notifications and potentially other infrastructure services. This processing is essential for the App to function as intended. * *For more information, please refer to Google's Privacy Policy:* [https://policies.google.com/privacy](https://policies.google.com/privacy) Please remember that these third-party services have their own privacy policies that govern how they use the information they collect. While we select our partners carefully and ensure they adhere to high data protection standards, we are not responsible for the privacy practices of these external services. **9. Data Retention** We retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. * **General Retention Policy:** We retain your personal data for the entire duration of your active account with SorÇöz. This means your names, email addresses, and associated device data will be stored until your account is deleted. * **Deletion Process:** You have the ability to delete your account directly within the SorÇöz App. Upon initiation of an account deletion request through the in-app option, your personal data will be promptly removed from our active databases. We aim to complete the deletion process within a reasonable timeframe, typically within 30 days, unless a longer retention period is required or permitted by law (e.g., for legal compliance, fraud prevention, or resolving disputes). * **Exceptions:** Even after your account deletion, some data may be retained for a limited period if required by law (e.g., tax records, financial transactions), to resolve disputes, enforce our agreements, or for legitimate security purposes to prevent fraud or abuse. Any such retained data will be kept in an anonymized or pseudonymized form where feasible. **10. Data Security** PALMIA SALES LTD is committed to protecting the security of your personal data. We implement industry-standard technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, and destruction. These measures include, but are not limited to: * **Encryption:** Where appropriate, personal data is encrypted both in transit (e.g., using Transport Layer Security/SSL) and at rest to prevent unauthorized interception or access. * **Access Controls:** We restrict access to personal data to only those employees, contractors, and service providers who need to know that information to process it on our behalf and who are subject to strict contractual confidentiality obligations. * **Pseudonymization and Anonymization:** Where feasible and appropriate, we apply pseudonymization or anonymization techniques to personal data to reduce its identifiability. * **Regular Security Audits and Assessments:** We periodically review our security practices and systems to identify and address potential vulnerabilities. * **Data Minimization:** We strive to collect and process only the personal data that is strictly necessary for the purposes outlined in this policy. * **Employee Training:** Our staff members are regularly trained on data protection best practices and our internal privacy policies. While we take all reasonable steps to protect your personal data, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. You also play a role in protecting your data by maintaining the confidentiality of your account credentials. **11. International Data Transfers** PALMIA SALES LTD is based in the United Kingdom, and we are committed to ensuring that your personal data is handled in compliance with the highest data protection standards. * **Data Storage Location:** All personal data collected through the SorÇöz App is stored within servers located in the European Union (EU). This means your data benefits from the robust protections offered by the GDPR. * **No Transfers Outside EU/EEA:** We explicitly state that we **do NOT transfer your personal data outside the EU/EEA**. Our data processing activities, including those involving third-party service providers, are confined to jurisdictions within the European Union or the European Economic Area that are deemed to provide an adequate level of data protection under GDPR. Should this policy change in the future, we would update this section and ensure appropriate safeguards (e.g., Standard Contractual Clauses, Privacy Shield replacements) are in place, and that we provide explicit notification to you. **12. Your Data Protection Rights** Depending on your geographical location, you have specific rights regarding your personal data. We are committed to upholding these rights. **A. For EU/EEA Users (Under GDPR):** If you are located in the European Union or European Economic Area, you have the following rights concerning your personal data: * **Right to Access:** You have the right to request a copy of the personal data we hold about you, along with information about how we process it. * **Right to Rectification:** You have the right to request that we correct any inaccurate or incomplete personal data we hold about you. * **Right to Erasure ("Right to be Forgotten"):** You have the right to request the deletion of your personal data under certain conditions (e.g., when the data is no longer necessary for the purposes for which it was collected, or when you withdraw consent and no other legal basis for processing exists). * **Right to Restriction of Processing:** You have the right to request that we restrict the processing of your personal data under certain conditions (e.g., if you contest the accuracy of the data, for a period allowing us to verify its accuracy). * **Right to Data Portability:** You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller where technically feasible and the processing is based on consent or contract. * **Right to Object:** You have the right to object to the processing of your personal data when we process it based on our legitimate interests (see Section 6), including for direct marketing purposes. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims. * **Rights in relation to Automated Decision-Making and Profiling:** You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless certain exceptions apply. We do not currently use such automated decision-making processes. * **Right to Withdraw Consent:** Where we rely on your consent for processing your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal. * **Right to Lodge a Complaint:** You have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work, or the place of the alleged infringement, if you believe that our processing of your personal data infringes GDPR. **B. For California Residents (Under CCPA):** If you are a California resident, you have the following specific rights regarding your personal information: * **Right to Know:** You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you, the categories of sources from which that information is collected, the business or commercial purpose for collecting your personal information, and the categories of third parties with whom we share your personal information. * **Right to Delete:** You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions. * **Right to Opt-Out of Sale:** You have the right to opt-out of the "sale" of your personal information. **As stated repeatedly, PALMIA SALES LTD does NOT sell your personal information.** Therefore, there is no need to exercise this right with us, as we do not engage in such activities. * **Right to Non-Discrimination:** We will not discriminate against you for exercising any of your CCPA rights (e.g., by denying goods or services, charging different prices, or providing a different level or quality of goods or services). * **Right to Designate an Authorized Agent:** You can designate an authorized agent to make a request under the CCPA on your behalf. We may require proof that you have provided the agent with written permission to act on your behalf and may verify your identity directly with us. **C. How to Exercise Your Rights:** To exercise any of these rights, please contact us by email at abdulganisen29@gmail.com. We may need to verify your identity before fulfilling your request to ensure the security of your data. This may involve requesting additional information from you. We will respond to your request within the timeframes required by applicable law (e.g., one month for GDPR requests, 45 days for CCPA requests). **13. Children's Privacy (COPPA Compliance)** The SorÇöz App is **NOT directed at children under the age of 13**. We understand the importance of protecting the privacy of young children, and we fully comply with the Children's Online Privacy Protection Act (COPPA) and other relevant regulations. * **Age Restriction:** Our App is intended for a general audience and is designed for users who are 13 years of age or older. We do not knowingly collect personal data from children under 13. * **Inadvertent Collection:** If we become aware that we have inadvertently collected personal data from a child under the age of 13 without verifiable parental consent, we will take immediate steps to delete that information from our servers. * **Parental Contact:** If you are a parent or guardian and believe that your child under the age of 13 has provided us with personal data, please contact us immediately at abdulganisen29@gmail.com. We will work with you to address the issue and ensure the deletion of any such data. **14. Mobile-Specific Features and Permissions** * **Device Permissions:** * **Camera:** The SorÇöz App requests access to your device's camera. This permission is specifically used to enable you to capture images or photos within the App. For example, if the app is designed to solve problems by scanning them, the camera is essential for this core functionality. We do not access your camera or collect images from your camera roll without your explicit action within the App. The captured images are processed to provide the App's service and are not stored on our servers longer than necessary to provide the service, unless explicitly saved by the user. * You can manage these permissions at any time through your device's operating system settings. * **Push Notifications:** * We may use push notifications to send you updates, reminders, or other relevant information about the SorÇöz App. We will only send you push notifications if you explicitly opt-in to receive them. * You can manage your push notification preferences or disable them entirely at any time through your device's operating system settings. * **Background Data Collection:** * As stated previously, the SorÇöz App **does NOT collect any personal data while running in the background.** All data collection occurs only when the App is actively in use by the user. **15. Data Breach Notification** While PALMIA SALES LTD employs robust security measures to protect your personal data, no system is entirely invulnerable. In the unfortunate event of a data breach—an unauthorized access, disclosure, alteration, or destruction of personal data—that could result in a high risk to your rights and freedoms, we are committed to acting swiftly and in full compliance with applicable data protection laws. * **Notification to Users:** We will notify you and any other affected data subjects without undue delay if a personal data breach is likely to result in a high risk to your rights and freedoms. This notification will include clear information about the nature of the breach, the likely consequences, and the measures we have taken or propose to take to address it. * **Notification to Supervisory Authorities:** We will notify the relevant supervisory authorities (e.g., the Information Commissioner's Office in the UK, data protection authorities in the EU/EEA, or the California Attorney General's Office) of any personal data breach within 72 hours of becoming aware of it, where required by GDPR and CCPA, unless the breach is unlikely to result in a risk to your rights and freedoms. * **Mitigation:** We will promptly investigate the breach, take all reasonable steps to mitigate its effects, and implement measures to prevent recurrence. **16. Changes to This Privacy Policy** We may update our Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any significant changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top of this policy. We may also inform you through other means, such as an in-App notification, email (if you have provided your email address and consented to receive such communications), or a prominent notice within the App before the changes become effective. We encourage you to review this Privacy Policy periodically for any changes. Your continued use of the SorÇöz App after any modifications to this Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the updated Privacy Policy. **17. Contact Us** If you have any questions or concerns about this Privacy Policy, our data practices, or if you wish to exercise your data protection rights, please do not hesitate to contact us. **Company/Developer Name:** PALMIA SALES LTD **Company Address:** 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ **Contact Email:** abdulganisen29@gmail.com We are committed to resolving any concerns you may have regarding your privacy and our handling of your personal data.