Privacy Policy

1. Introduction

 

Welcome to PekiBook’s Privacy Policy. Your privacy is important to us. This policy explains what information we collect, how we use and share it, and your rights regarding that information. We are committed to handling your personal data transparently, securely, and in compliance with applicable privacy laws, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) as amended by the CPRA, Turkey’s Law on Protection of Personal Data No. 6698, and other relevant regulations.

By using the PekiBook mobile app or website (collectively, the “Service”), you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our practices, please do not use the Service. We encourage you to read this document carefully and contact us if you have any questions.

Data Controller: For the purposes of data protection laws, the “data controller” (the party responsible for your personal information) is Erenay Kaya, the developer of PekiBook, located in Turkey. You can find our contact details at the end of this policy.

This policy applies to all users of PekiBook worldwide. However, certain provisions apply specifically based on your location (for example, additional rights for EU/EEA users or California residents). We will highlight those where relevant.

 

2. Information We Collect

 

We collect several categories of information from and about users of PekiBook. The types of personal data we collect depend on how you interact with the Service. Generally, the information falls into these categories:

Information You Provide Directly:

• Account Information: When you create an account, we may collect identifiers such as your name, email address, username, profile photo (if you choose to add one), and login credentials. If you sign in via a third-party platform (like “Sign in with Google” or “Sign in with Apple”), we receive basic account information from them (e.g., your name and email) as permitted by that service’s privacy settings.

• Profile and Learning Data: You may provide additional information within the app, such as your language proficiency level, learning goals, or settings/preferences (e.g., interface language, notification preferences). This also includes data about your progress, such as completed "Daily Deeds," "Unit Deeds," and achievements unlocked in the "Glory Gallery," which we record to track your progress and provide a backup of your accomplishments.

• Content and Submissions: Any content you submit through the Service, including your answers to exercises and "homework" questions, feedback, or support inquiries. When you submit answers, they may be stored on our servers and sent to our third-party AI provider to evaluate whether they are correct. We analyze this data to improve our lessons and for backup purposes. Please avoid sharing sensitive personal information in your submissions.

• Game and Activity Data: If you participate in in-app games, we collect and store your scores, the number of coins you collect, the amount of gems you have, and records of virtual items you purchase, such as backgrounds and skins. This information is necessary to operate the game features and save your progress.

• Payment Information: If you subscribe to PekiBook Premium, purchase gems from the "Peki Market," or make other purchases, our third-party service providers process the transaction. All purchases in the iOS or Android apps are processed by Apple or Google respectively; we do not receive your full credit card number or billing information. We use a subscription management service (RevenueCat) which receives purchase tokens/receipts from the app stores to confirm your purchase, manage your subscription status, and provide us with analytics. We may receive confirmation of your purchase, subscription status, and limited information like an order ID or an email, which we keep for our records.

• Communications: If you contact us directly (via email, support chat, or phone), we will receive your name, email, and the contents of your message or attachments, as well as any other information you choose to provide.

Information We Collect Automatically:

When you use PekiBook, we (and service providers acting on our behalf) automatically collect certain information about your device and usage of the Service through cookies, SDKs, and similar tracking technologies. This may include:

• Device Identifiers: Such as your device model, operating system version, unique device IDs (for example, IDFA for iOS or Android Advertising ID, if available), device language, and device region.

• Log and Usage Data: Details of your usage of the app, like the date and time you launched PekiBook, the features, lessons, or games you interacted with, the time spent on various activities, your scores or progress, and crash or error reports.

• IP Address and Network Info: Your device’s IP address and, by extension, general geolocation information (approximate city or region).

• Cookies and Web Tracking: On our website, we use cookies and similar technologies to remember your preferences, understand how our site is used, and personalize content.

• Analytics Data: We use analytics tools (e.g., Google Analytics, Firebase Crashlytics) that gather data about app or website usage to help us improve the Service.

Information from Third Parties:

• If you link PekiBook with a social media or another account, we might receive profile information from that third party.

• We receive purchase confirmation data from app stores (Apple, Google) and our subscription management provider (RevenueCat) to validate and manage your subscriptions and in-app purchases.

• We may receive aggregate, de-identified demographic or interest information about our user base from advertising or analytics partners.

Children’s Data: As noted in our Terms, PekiBook is not intended for children under 13. We do not knowingly collect personal data from anyone under 13. If you are a parent or guardian and believe we have collected personal information from your child without consent, please contact us.

 

3. How We Use Your Information

 

We use the collected information for various purposes in order to operate, provide, improve, and protect our Service, as well as to comply with legal obligations. Specifically, we may use your information in the following ways:

• To Provide and Personalize the Service: We use your data to deliver PekiBook’s core functionality, such as logging you in, presenting your learning progress, checking your "homework" answers with our AI engine, and managing your in-game experience (scores, gems, items). This is necessary to perform our contract with you.

• To Process Transactions: We use your information to complete transactions, manage your subscriptions (using services like RevenueCat), and provide you with purchased content, such as an ad-free experience or in-game gems.

• To Communicate with You: We use your contact information to send administrative messages, updates, and support responses. We may also send promotional communications, which you can opt out of at any time.

• To Provide Customer Support: If you reach out to us, we use your information to respond and resolve your query.

• To Monitor, Maintain, and Improve the Service: We analyze aggregated data on user interactions (lesson performance, game-play patterns, etc.) to debug, optimize, and improve our app.

• To Enforce Our Terms and Protect Our Users and Service: We use data to prevent fraud, abuse, and violations of our Terms of Use.

• For Legal Compliance: We process personal data as necessary to comply with legal obligations, such as financial regulations and lawful data requests.

 

4. Legal Bases for Processing (for EU/EEA/UK Users)

 

If you are located in the European Economic Area or a similar jurisdiction, we process your information under the following legal bases:

• Performance of a Contract: Most of our processing is necessary to provide the Service you requested under our Terms of Use.

• Legitimate Interests: We process certain data for our legitimate interests, such as improving our services and preventing fraud, provided it does not override your rights.

• Consent: In specific situations, such as for sending marketing emails, we rely on your consent, which you can withdraw at any time.

• Legal Obligation: We process data when necessary to comply with a legal obligation.

 

5. How We Share or Disclose Information

 

We do not sell your personal data. However, we share information with trusted third parties for legitimate operational purposes. The categories of recipients include:

• Service Providers (Processors): We use third-party companies to perform functions on our behalf. These include:

  • Hosting and Infrastructure: Cloud providers (e.g., Amazon Web Services, Google Cloud).

  • AI Platform Providers: Services used to evaluate the correctness of your submitted answers.

  • Analytics and Crash Reporting: Tools like Google Analytics for Firebase.

  • Payment Processors and Subscription Management: Apple, Google, and our subscription management service, RevenueCat.

  • Communication Services: Email and push notification providers.

• Business Transfers: If we undergo a merger, acquisition, or sale of assets, your information may be transferred to the new owner.

• Legal and Safety Disclosures: We may disclose information if we believe it's necessary to comply with the law, protect safety, or enforce our terms.

• Advertising Partners: The free version of PekiBook may be supported by ads. We work with ad networks (like Google AdMob) that may collect device information to show relevant ads. You can opt out of personalized ads via your device settings. Premium users do not see ads, and this data is not shared.

• Aggregated or De-Identified Data: We may share aggregated data that cannot be linked back to you personally (e.g., usage statistics).

 

6. International Data Transfers

 

PekiBook is developed in Turkey, and we use servers and service providers that may be located in multiple countries (e.g., the United States or EU). Your data may be transferred to and processed in a country different from your home country. We implement appropriate safeguards, such as Standard Contractual Clauses (SCCs), to ensure your data is treated securely and in accordance with this policy when it is transferred across borders.

 

7. Data Retention

 

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected.

• Account Data: We keep your account information, learning progress, and game data for as long as your account is active. If you delete your account, this data will be deleted or anonymized.

• Transactional Data: Purchase records are kept for as long as required by tax and financial laws (e.g., up to 10 years).

• Logs and Analytics: This data is generally kept for a finite period.

When we no longer need your data, we will either delete it or anonymize it.

 

8. Your Rights and Choices

 

Depending on your jurisdiction, you have rights regarding your personal information, which may include:

• Right to Access: Request a copy of your data.

• Right to Rectification: Request correction of inaccurate data.

• Right to Erasure (Right to be Forgotten): Request deletion of your data.

• Right to Restrict Processing: Limit how we process your data.

• Right to Data Portability: Obtain your data in a machine-readable format.

• Right to Object: Object to processing based on legitimate interests.

• Right to Withdraw Consent: Withdraw your consent at any time.

• For California Residents (CCPA/CPRA): You have the right to know, delete, correct, and opt-out of the "sharing" of your personal information for targeted advertising. We honor opt-out signals like the Global Privacy Control (GPC).

How to Exercise Your Rights: To exercise any of your rights, please use in-app self-service tools or contact us using the details below. We may need to verify your identity before fulfilling the request.

Right to Complain: You have the right to lodge a complaint with your local data protection authority.

 

9. Security Measures

 

We take the security of your information seriously and have implemented technical and organizational measures to protect it, including encryption, access controls, and secure development practices. However, no method of transmission over the internet is 100% secure. We ask that you also play a role by using a strong password and notifying us of any suspicious activity.

 

10. Cookies and Tracking Technologies

 

On our website, we use cookies for essential functions, analytics, and advertising. In our mobile app, we use SDKs and mobile identifiers for similar purposes. Where required by law, we will obtain your consent before using non-essential trackers. You can control these technologies through your browser or device settings.

 

11. Third-Party Links and Services

 

Our Service may contain links to third-party websites or services. This Privacy Policy does not apply to them. We encourage you to review the privacy policies of any third-party service you interact with.

 

12. International Users (Specific Regional Disclosures)

 

We strive to comply with the privacy laws applicable in the regions where we operate, including specific requirements for users in the EU/EEA, UK, Turkey, USA, Canada, Australia, and Brazil. If you have questions about how your country’s laws are handled, please contact us.

 

13. Changes to This Privacy Policy

 

We may update this Privacy Policy from time to time. We will notify you of any material changes by updating the “Last Updated” date at the top and providing a more prominent notice (e.g., via an in-app notification). Your continued use of the Service after changes become effective constitutes your acceptance of the revised policy.

 

14. Contact Us

 

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

• Email: erenay@pekibook.com

• Mail: Erenay Kaya – PekiBook, İŞÇİ BLOKLARI Mah. 1535 Cad. 217. Blok No: 21, İç Kapı No: 2, Çankaya, Ankara 06530, TURKEY

We recommend email for a faster response. Please include “Privacy Inquiry” in the subject line.