Speetz Privacy Policy

1. Introduction

As Prime IT ("Company"), we have adopted the principle of protecting the privacy of personal data of the users ("User") of the Speetz mobile application ("Application"). This Privacy Policy has been prepared in accordance with the Law on Protection of Personal Data No. 6698 ("KVKK") and the European Union General Data Protection Regulation ("GDPR") to explain which of your personal data is processed, for which purposes, how it is shared, stored, and protected.

2. Categories of Processed Personal Data and Processing Purposes

• Identity and Contact Information: (Name, surname, email address, phone number) For account creation, verification, establishment and execution of the contractual relationship, and communication.
• Profile Information: (Biography, profile picture, interests, gender, date of birth) For personalizing and presenting social interaction features.
• User Content: (Posts, photos, videos, comments, messages, participated event and tournament information) For the complete provision of application functions.
• Location Data: (GPS, IP Address, base station data) For providing location-based features (nearby users/events), security, and analysis.
• Social Interaction Data: (Friend lists, follower information, blocked users, likes) For operating social network features.
• Technical and Usage Data: (Device model, operating system, unique device identifiers, network information, in-app navigation times, click data) For performance analysis, debugging, improving service quality, and providing a personalized experience.
• Transaction Security Data: (Passwords, IP logs, data for fraud detection) For ensuring security.

3. Legal Grounds for Data Processing

• Establishment or performance of a contract (provision of Application services).
• Fulfillment of the Company's legal obligations (tax, accounting legislation).
• Establishment, exercise, or protection of a right.
• Legitimate interest of the Company (service development, marketing, providing security).
• Your explicit consent (for specific marketing communications, etc., in cases reliant on consent).

4. Transfer of Personal Data

Your personal data may be transferred:

• To Our Service Providers: To third parties we have contracted with to provide services such as server hosting, data analysis, email sending, customer services, limited to the purpose of the service and obligated to act in accordance with KVKK and GDPR (e.g., Google Firebase, CRM providers).
• To Legal Authorities: Upon the lawful request of authorized legal, administrative, or law enforcement authorities.
• To Third Parties: To third parties who acquire the Company's rights and obligations within the scope of a merger, transfer, or bankruptcy process.

5. Transfer of Data Abroad

The Application uses services such as Google LLC's Firebase for data storage and analysis services. In this context, your personal data may be transferred to servers located in the USA. The USA is not recognized by the European Commission as a country with an adequate level of protection. Therefore, these transfers are based on legal validity grounds compliant with the GDPR, such as the application of Standard Contractual Clauses and additional technical-security measures.

6. Data Retention Period

Your personal data is stored for the legal periods required for the processing purposes. When the processing purpose ceases to exist or a deletion request is received, your data is deleted, destroyed, or anonymized, unless a legal obligation requires its retention.

7. Data Security

We implement appropriate technical and administrative security measures (encryption, access controls, regular audits) to protect your personal data. However, no data transmission over the internet or electronic storage is 100% secure.

8. User Rights (Data Subject Rights)

In accordance with KVKK and GDPR, you can contact us to exercise your rights such as access, rectification, deletion, restriction, objection, and data portability. You can submit your requests via the contact details in Section 13.

9. Children's Privacy

The Application is not intended for individuals under the age of 13, and we do not knowingly collect personal data from such individuals. If we learn that a child under 13 has provided us with personal data, we will take reasonable steps to delete such data immediately.

Speetz strictly prohibits any form of child sexual abuse and exploitation (CSAE) content. Such content will be removed immediately and reported to the relevant legal authorities. Users can also report this content via the in-app reporting system or by contacting us directly.

10. Speetz Child Safety Standards

Speetz by Prime IT Bilişim Hizmetleri is committed to providing a safe, respectful, and secure environment for all users. We maintain a zero-tolerance policy against any form of Child Sexual Abuse and Exploitation (CSAE) or Child Sexual Abuse Material (CSAM).

Speetz Child Safety Standards

Our Zero Tolerance Policy

The Speetz application does not host, distribute, promote, or facilitate any CSAE or CSAM content. Any such material discovered or reported through our system will be immediately removed and reported to relevant law enforcement authorities.

Our Commitments

• Zero tolerance for child sexual abuse and exploitation (CSAE).
• Strict compliance with all applicable child protection laws and digital safety regulations.
• Continuous review and improvement of our safety monitoring tools.
• Immediate removal and reporting of any CSAE or CSAM content.
• Availability of in-app and email-based reporting channels for users.

Reporting & Contact Information

If you encounter any content, user, or behavior that may endanger children or violate our child safety policies, you can report it to us using one of the methods below:

1. In-App Reporting

Speetz provides a built-in reporting system to help users quickly notify us of inappropriate or harmful content. You can access this feature by tapping the “Report” option available in the relevant user profile, or content menu. All in-app reports are automatically sent to our moderation team for review within 24–48 hours.

2. Direct Contact with Child Safety Officer

You can also contact our designated Child Safety Officer directly for urgent concerns or additional information:

Contact Person: Çağla Ersizer
Title: Child Safety Officer
Email: cagla.ersizer@primeit.com.tr
Phone: +90 (216) 999 45 36

Reporting Process

• All reports are handled confidentially and securely.
• Investigations are initiated within 24–48 hours of receiving a report.
• Content found to be in violation is immediately removed from the platform.
• Where appropriate, incidents are escalated to law enforcement authorities.
• We maintain detailed logs for internal auditing and continuous policy improvement.

Ongoing Commitment

Speetz continuously monitors user activity to prevent any form of child exploitation. Our moderation and safety systems are regularly reviewed to maintain the highest level of user protection

11. Policy Changes

We may update this Privacy Policy at any time. Updates become effective on the date they are published in the Application or on our website.

12. Third-Party Services and Links

The Application may include third-party services such as Google Firebase whose privacy practices are independent of us. We recommend reviewing their privacy policies separately.

13. Contact