Effective Date: 2026-02-02
Service: Polinvest iOS App (iPhone-only)
Data Controller: entity["company","Unify Bilisim LTD. ŞTI.","turkish software company"]
Website (domain): www.useelio.com
Contact Email: berkay@useelio.com
Company Address: [Company Address]
Bundle Identifier: [Bundle Identifier]
This Privacy Policy (the “Policy”) explains how the Polinvest mobile application for iOS (the “App”) and related services we provide (together, the “Service”) handle information, including what information is processed, where it is stored, and how it is shared.
This Policy is drafted in native English legal style for use by a Türkiye-based provider, and is designed to align with Türkiye’s Personal Data Protection Law No. 6698 (“KVKK”), including the requirement to inform data subjects at the time personal data are obtained (KVKK Article 10). citeturn3view3turn2view0turn1search8 In addition, where you are a consumer, mandatory Turkish consumer protections apply and “unfair terms” in consumer contracts are void; this Policy is intended to be clear and comprehensible, and does not waive mandatory rights. citeturn8view0
This Policy also addresses the Service’s U.S. public-record context: the App presents publicly available congressional disclosure information about securities transactions and related filings, which are available for public inspection through official U.S. government channels. citeturn7view6turn6search7
For purposes of this Policy, “personal data” means any information relating to an identified or identifiable natural person, and the Company is the “data controller” where it determines the purposes and means of processing. citeturn3view3 KVKK requires that personal data be processed lawfully and fairly, for specified and legitimate purposes, in a relevant/limited/proportionate manner, and be retained only for the period required by the purpose or applicable legislation. citeturn3view3
For App Store disclosure, Apple requires developers to provide accurate privacy information in App Store Connect, including the practices of third-party partners whose code is integrated into the app, and to keep those disclosures up to date. citeturn7view3turn2view1 Apple defines “collect” (for App Store “Privacy Nutrition Label” purposes) as transmitting data off the device in a manner that allows the developer and/or third-party partners to access it for a period longer than is necessary to service the transmitted request in real time. citeturn2view1
The App is designed to operate without user registration and without collecting direct identifiers (such as name, postal address, or in-app account credentials). At the same time, certain technical identifiers and purchase-related information may be processed by third-party services used to deliver configuration/data and to manage subscriptions; those practices are disclosed below and in the providers’ own privacy documentation. citeturn2view1turn2view2turn7view5
The table below summarizes the principal information categories relevant to this Service.
| Information category | Examples (non-exhaustive) | Where stored/processed | Primary purpose | Typical retention logic |
|---|---|---|---|---|
| Local app preferences | Onboarding completion flag; watchlist politician IDs; paywall state flag | Stored locally on your device (e.g., iOS local preferences) | App functionality and user experience continuity | Persists until you delete the App or reset device/app data |
| Configuration/data delivery identifiers (third-party) | Firebase installation ID used to deliver Remote Config values | Processed by entity["company","Firebase","google developer platform"] services | Selecting and returning configuration values and enabling Remote Config delivery | Firebase retains installation IDs until the customer deletes the ID via API; after deletion, removal from live and backup systems occurs within up to 180 days citeturn2view2turn4search10 |
| Subscription and entitlement identifiers (third-party) | RevenueCat anonymous App User ID; purchase/subscription status derived from App Store receipts | Processed by entity["company","RevenueCat, Inc.","subscription management platform"] and Apple systems | Receipt validation, entitlement management, fraud prevention, subscription status synchronization | RevenueCat can generate anonymous App User IDs by default when SDK initializes; retention depends on the vendor’s service configuration and policies citeturn7view5turn2view3 |
| App Store purchase processing (platform) | Apple account and payment information; purchase history; device and IP logging by Apple | Processed by entity["company","Apple","consumer technology company"] | App Store service delivery, purchase processing, fraud prevention, refund handling | Apple retains purchase-related personal data for legally required financial reporting periods (often at least 10 years) citeturn7view1turn7view2 |
| Support communications (only if you contact us) | Email address, message content, attachments you choose to send | Stored in our support inbox and systems | Customer support, troubleshooting, legal compliance | Retained as long as needed to address the request and meet legal obligations (reasonable retention) |
The Service’s content includes information about public officials and their publicly disclosed transactions. This content is not “user account data” about you, but it may still be data about identifiable individuals (the public officials) drawn from public sources and presented for informational purposes. citeturn7view6turn6search7