GDPR Privacy Notice and Consent Declaration

PART A — PRIVACY NOTICE

1. Data Controller and Contact

Data controller: Abdullah Onur Şimşek (individual developer)

Address: Tunahan Mahallesi 210. Sokak 17625 Ada Gökkuşağı Evleri, Etimesgut/Ankara, Türkiye

Email: contact@berryfilm.art

EU representative (Art. 27 GDPR): Given the currently limited scope and nature of the personal data processing, the data controller has assessed that the appointment of an EU representative under Art. 27(2) GDPR is not required. Should this assessment change, an EU representative will be appointed and the contact details published in this notice.

The appointment of a data protection officer (DPO) is not mandatory; for all requests concerning data protection, you may use the email address above.

2. Categories of Personal Data Processed

In guest (anonymous) use, no identity/contact data is collected; browsed and saved aphorisms and preferences are linked not to your identity but to an anonymous user identifier tied to the device.

3. Purposes of Processing and Legal Bases (Art. 6 GDPR)

• Performance of a contract (Art. 6(1)(b)): creation of the account, authentication, synchronization of saved items/preferences, and provision and management of the Pro subscription.
• Consent (Art. 6(1)(a)): sending daily edition / announcement push notifications (asked separately in the App and switchable off in Settings); showing personalised advertising via Google AdMob (collected through the consent form shown when the App opens). You may withdraw your consent at any time, with effect for the future.
• Legitimate interests (Art. 6(1)(f)): security of the App, prevention of abuse and fraud; fixing defects through crash reporting; improving the service through aggregate usage analysis with Firebase Analytics that is not linked to your account identifier. These interests are balanced against your rights and freedoms; you can object to and switch off both kinds of processing using the toggles in Settings.
• Legal obligation (Art. 6(1)(c)): fulfilment of obligations arising under applicable law.

4. Recipients and Processors

Your data is processed through the following providers for the purpose of delivering the service:

We do not sell your data and do not transfer it to third parties for advertising purposes.

• Google (Firebase): authentication, database (Firestore), server functions, storage, notifications (FCM). Data hosting is in the EU region (Frankfurt, Germany).
• Google (Firebase Analytics): usage analysis.
• Google (AdMob): serving advertisements in the Free version (Google acting as a separate data controller).
• Apple: Sign in with Apple, App Store subscription infrastructure, notifications (APNs).
• Google: Sign in with Google and Google Play subscription infrastructure.
• Email delivery service (Gmail/SMTP): data export and informational emails.

5. Transfers to Third Countries (Art. 44–49 GDPR)

Primary data hosting takes place within the EU (Frankfurt). Nevertheless, some providers (Apple, Google) may process data outside the EU/EEA, in particular in the United States. These transfers are carried out on the basis of the appropriate safeguards required by the GDPR, such as the European Commission's Standard Contractual Clauses (SCC) and/or, where applicable, an adequacy decision under the EU–U.S. Data Privacy Framework. You may request a copy of the safeguards applied.

6. Retention Period

Your personal data is retained for as long as your account is active and necessary for the purposes set out in this notice. When you delete your account, your data is erased or anonymized; data that must be retained under applicable law may be kept for the relevant period.

7. Rights of the Data Subject (Art. 15–22 and 7(3) GDPR)

If you are located in the EU/EEA, you have the following rights:

You may exercise these rights by contacting contact@berryfilm.art. The App also provides direct tools to export your data ("Send me my data"), clear it ("Clear data") and delete your account ("Delete my account"). Pursuant to Art. 12 GDPR, your requests are, as a rule, fulfilled within one month.

• Access (Art. 15), rectification (Art. 16), erasure/"right to be forgotten" (Art. 17), restriction of processing (Art. 18);
• Data portability (Art. 20): to receive your data in a structured, commonly used and machine-readable format;
• Objection (Art. 21): to object to processing based on legitimate interests;
• Withdrawal of consent (Art. 7(3)): without affecting the lawfulness of processing carried out before the withdrawal;
• Automated decision-making (Art. 22): the App does not engage in solely automated decision-making or profiling that produces legal effects concerning you.

8. Complaint to a Supervisory Authority (Art. 77 GDPR)

If you believe that the processing infringes the GDPR, you have the right to lodge a complaint with the competent data protection supervisory authority in the EU Member State of your habitual residence, place of work, or the place where the alleged infringement occurred.

9. Children's Data

The App is intended for users aged 16 and over and does not knowingly collect personal data from anyone under 16. The applicable age of consent for information society services varies between 13 and 16 depending on the Member State; the App applies the highest threshold.

10. Changes

We may update this notice from time to time; the current version is published within the App and/or through the relevant channels. In the event of significant changes, we will provide appropriate notice.

PART B — CONSENT AND YOUR CHOICES

This notice contains no separate tick-boxes. By continuing on the App's entry screen you accept the Terms of Use, the Privacy Policy and this notice; consent for processing that relies on consent is collected separately, in the App, at the moment it applies.

Notifications: asked separately during onboarding; can be switched off at any time in Settings > Notifications. Advertising: Google's consent form is shown when the App opens; it can be reopened from Settings > Ad preferences. Usage analytics and crash reports: rely on legitimate interests (see section 3) and can be switched off with the toggles in Settings — that is how you exercise your right to object.

You may withdraw your consent at any time from the App's settings or by writing to contact@berryfilm.art; withdrawal does not affect the lawfulness of processing carried out before it.