This Privacy Policy explains how Kutluca Labs ("we", "us") collects, uses, and protects information when you use our mobile applications (collectively, "the Applications").
Our Applications fall into two groups, and they are treated very differently by this policy:
The data controller responsible for your personal data is:
Kutluca Labs
[Abdullah Kutluca]
[Pozanti, Adana, Türkiye]
Email: kutlucalabs@icloud.com
We do not collect any Personally Identifiable Information in our games. There is no account, no login, and no profile. These games do not ask for permission to track you across other companies' apps and websites, and we do not do so. The only data processed is that described in Section 4 (advertising) and Section 5 (diagnostics).
To provide pen-pal matching and letter delivery, we collect the following:
| Category | What it includes | Why we need it |
|---|---|---|
| Account data | Email address, authentication credentials (handled by Google Firebase Authentication — we never see or store your password), account creation date | To create and secure your account |
| Profile data | Nickname, self-declared country, date of birth, selected interests | To show you to other users, to match pen pals, and to verify the minimum age |
| User content | Letters you send and receive, notice-board posts | To deliver your correspondence |
| Safety data | Users you have blocked; reports you submit, which include the reported user's identifier and a copy of the reported content | To enforce our community rules and to review reports |
| Purchase records | Virtual currency balance and completed in-app purchase transactions | To deliver purchased items and restore them on a new device |
Your email address and date of birth are stored separately from your public profile and are not visible to other users. Other users can see only your nickname, country, interests, and the content you choose to send or post.
Where the GDPR or UK GDPR applies, we rely on the following legal bases:
We use Google AdMob to display advertisements, including rewarded video ads. AdMob may process device identifiers, coarse location derived from your IP address, and ad interaction data in order to serve and measure ads. See how Google uses information from apps that use its services.
Before ads are loaded, we present a consent form provided by Google's User Messaging Platform (UMP). You may choose personalised ads, non-personalised ads, or refuse consent for the purposes offered. You can reopen this form at any time from the app's settings and change your choice.
This applies to InkedApp only. Our games do not request tracking permission and do not track you.
On iOS, InkedApp asks for your permission before tracking you across apps and websites owned by other companies, using Apple's App Tracking Transparency framework. If you decline, we do not track you and you will see non-personalised advertising instead; the app remains fully usable. You can change this decision at any time in iOS Settings → Privacy & Security → Tracking.
We collect non-personal diagnostic data, such as crash reports and basic error logs, to identify and fix defects. This data is processed through Google Firebase and is not used to identify you or to build a profile about you.
To protect users — particularly younger ones — text written in InkedApp (letters and notice-board posts) is automatically screened on your device before it is sent. The screening looks for profanity, sexual content, and attempts to exchange personal contact details such as phone numbers or social-media handles.
If a message is blocked, you are told and may edit and resend it. This screening is automated and happens locally; the content of a blocked message is not transmitted to us. It does not produce any legal or similarly significant effect for you, and it does not replace human review of reports.
We do not sell your personal data. We share information only as follows:
Our services run on Google Cloud infrastructure and your data may be stored and processed in countries other than your own, including the United States. Where data is transferred out of the EEA or the UK, the transfer is covered by the European Commission's Standard Contractual Clauses or another approved safeguard, as implemented by Google.
| Data | Retention |
|---|---|
| Account and profile | Until you delete your account. After deletion, data is removed from our active systems within 30 days. |
| Letters between real users | Kept while either correspondent still holds the letter. A letter is permanently deleted once both the sender and the recipient have deleted it — deleting a letter does not remove it from the other person's archive. |
| Letters from automated accounts | Automatically deleted 180 days after they are sent. |
| Notice-board posts | Automatically deleted 24 hours after posting. |
| Reports of abuse | Retained after review for as long as necessary to enforce our rules and to detect repeat offenders. |
| Backups | Residual copies may persist in encrypted backups for a limited period after deletion. |
To keep InkedApp usable while its community is still growing, some profiles and notice-board posts are generated automatically by us rather than written by real people. These accounts exist only to populate the app; they are not real individuals, and any correspondence with them is machine-generated. No personal data of yours is shared with a third party through them.
Depending on where you live, you may have the right to:
To exercise any of these rights, write to kutlucalabs@icloud.com. We respond within 30 days. We may ask you to verify ownership of the account before acting on a request.
Note that your date of birth cannot be changed after registration. It is used to enforce our minimum age requirement, and allowing it to be edited would defeat that purpose. If it was entered incorrectly, contact us.
InkedApp is not for children. You must be at least 16 years old to create an InkedApp account.
We ask for your date of birth during registration and refuse registration to anyone under 16. Our games are not directed to children and do not collect personal information from anyone.
We do not knowingly collect personal information from children under 16. If you believe a child under 16 has created an account, contact us at kutlucalabs@icloud.com and we will delete the account and its data promptly.
Data is transmitted over encrypted connections and stored on Google Firebase with access restricted by server-side security rules, so that one user cannot read another user's private data. Authentication credentials are handled entirely by Google Firebase Authentication and are never stored by us. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this page shows when it last changed. Where a change is material, we will give notice within the Applications before it takes effect.
Questions about this policy, or about your data:
kutlucalabs@icloud.com
kutluca.game@gmail.com