KVKK Privacy Notice

Last updated: November 11, 2026

English translation of the Turkish personal data notice under Law No. 6698. This notice does not replace any separately required GDPR disclosures.

1. Data Controller

For the purposes of Türkiye's Personal Data Protection Law No. 6698 (“KVKK”), the controller of personal data processed through RecoGol is:

Pinilia LLC

1209 Mountain Road Pl NE #5432

Albuquerque, NM 87110, USA

Email: hi@recogol.com

Phone: +1 505 636 9444

This notice informs users in Türkiye about the processing of their personal data.

2. Categories of Personal Data

We may process:

• Account identifiers: Username and unique user ID.
• Contact information: Email address.
• Security information: Authentication records, secure password hashes, session and security logs.
• Gameplay information: Predictions, scores, Football IQ indicators, response times, hints, achievements, streaks, friends, duels, and tournament records.
• Technical information: Device country and language settings, app version, and necessary error records.
• Subscription information: Subscription type, status, renewal details, and store transaction identifiers when enabled.

3. Purposes and Legal Grounds

Personal data may be processed for the following purposes under Article 5 of the KVKK:

• Account information — Registration and authentication — Contractual necessity, Art. 5/2(c)
• Gameplay information — Providing game services — Contractual necessity, Art. 5/2(c)
• Friends and tournaments — Social gameplay — Contractual necessity, Art. 5/2(c)
• Security records — Preventing abuse — Legitimate interests, Art. 5/2(f), where conditions are met
• Subscription records — Managing entitlements — Contractual necessity, Art. 5/2(c)
• Legally required records — Legal compliance — Legal obligation, Art. 5/2(ç)
• Optional processing — Activities requiring separate consent — Explicit consent, Art. 5/1, where required

Legitimate interests must be balanced against the fundamental rights and freedoms of users.

Any new advertising personalization activities will be assessed separately before activation.

4. Collection Methods

Data is collected electronically through registration and login forms, gameplay, subscriptions, support requests, and necessary automated technical processes.

5. Data Recipients

Data may be disclosed, as necessary, to:

• Supabase: Authentication and database services.
• epostapazarlama.com: Verification and password-reset emails.
• RevenueCat: Subscription management when enabled.
• Apple and Google: Relevant store purchases and subscriptions.
• Public authorities: Where legally required.

Google AdMob may be introduced in the future. This notice will be updated before applicable processing begins.

6. International Transfers

Pinilia LLC is based in the United States. The reported primary Supabase database region is Germany. Other service providers may process data in additional jurisdictions.

Cross-border transfers must satisfy the requirements of Article 9 of the KVKK, including applicable legal transfer conditions and safeguards.

The specific transfer mechanism must be determined following an assessment of actual data flows and the relevant parties.

7. Retention and Deletion

Personal data is retained only as necessary for its processing purpose and applicable legal obligations.

Following a verified deletion request, data is deleted, destroyed, or anonymized where appropriate, subject to lawful exceptions and technical procedures.

Specific retention periods must be established by data category.

8. Your Rights

Under Article 11 of the KVKK, where applicable, you may request:

1. Confirmation of whether your data is processed.
2. Information about processing.
3. Details of processing purposes and appropriate use.
4. Information about domestic and international recipients.
5. Correction of incomplete or inaccurate information.
6. Deletion or destruction where legal conditions are met.
7. Notification of relevant corrections or deletions to third parties.
8. Objection to adverse outcomes resulting exclusively from automated analysis.
9. Compensation for damage resulting from unlawful processing.

9. Requests

Submit requests to:

hi@recogol.com

Pinilia LLC

1209 Mountain Road Pl NE #5432, Albuquerque, NM 87110, USA

Requests will be assessed under applicable identification and procedural requirements.

10. Updates

This notice may be updated to reflect changes in processing activities or legal obligations.