Till C

Legal

FROGIE PRIVACY NOTICE (KVKK) AND PRIVACY POLICY

Version: 2026-10-11 · Same text as in the app (Settings → Legal)

Last Updated: October 11, 2026

This English text is a translation provided for convenience. The Turkish version is the original and legally binding text; in case of any discrepancy, the Turkish version prevails.

This Privacy Notice has been prepared by the data controller TILL C YAZILIM İÇ VE DIŞ TİCARET LİMİTED ŞİRKETİ ("Company", "Frogie", "we") under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform, to tell you for which purposes, on which legal grounds, to whom and how your personal data is processed when you use the Frogie mobile application ("App" or "Platform").

This text is information only; you are not asked to "accept" it. Separate explicit consent forms are provided for processing that relies on your explicit consent. For users located in the European Union, the provisions of the General Data Protection Regulation ("GDPR") are also observed to the extent applicable.

1. DATA CONTROLLER

Your personal data is processed by the Company as data controller. The Company's trade name, MERSIS number and address are given in the last section of this text.

2. PERSONAL DATA WE PROCESS

The following personal data is processed so that the Platform can work:

Identity and contact data: your first name, last name, date/year of birth and the age calculated from it, your gender and email address; your phone number if you provide it; if you sign in with Google or Apple, the name, email and account identifier these services send us.

Account and security data: your password (kept only in the authentication infrastructure in encrypted form; Company staff cannot see it), email verification code records (an encrypted digest, not the code itself), session information, account restriction and suspension records.

Profile data: your profile photos (cropped versions and the originals you upload), bio, answers to profile questions, height, weight, profession, education, relationship goals, lifestyle preferences (alcohol, smoking, etc.), zodiac sign and any other profile information you choose to add.

Special categories of personal data: your sexual orientation and gender identity as may be inferred from your match preference; information such as religion, sect, political opinion or health that you may choose to share in your bio, profile answers or messages. This data is processed only on the basis of your explicit consent.

Location data: if you grant device permission, your location collected only while the App is open (each time it is opened and when you move significantly while using it) and an approximate location code derived from it (Geohash); if you do not grant location permission, the province and district you declare at registration. Your location is not collected while the App is closed or in the background. Your last collected location is kept on your profile for distance calculation and distance filters while the App is closed, and is updated the next time you open it. Other users are shown only an approximate distance, never your exact location.

In-platform interaction data: ratings you give and receive, like and pass actions, "10 Points" (Super Point) and compliment messages, matches, message contents, date invitations and the activity, place, date and notes in them, post-date reviews and social tags, profile verification approvals, referral code use, report and block records; and, to the extent used, online, last seen, typing and read status.

Rating and score data: ratings from 1 to 10 given to you (the "Trust Score"), positive or negative social tags assigned to you, and an algorithmic score calculated in the background from the ratings you receive, reports and your in-app interactions that affects how often your profile is shown to other users (the "Feed Score").

Purchase data: your subscription level and term, products purchased, transaction dates and store transaction identifiers. Your card and payment details are processed by Apple or Google and are not sent to the Company.

Technical data: device type, operating system and version, app language, notification (push) token, device and network identifiers to the extent allowed by the operating system, IP address, server and error logs, in-app preferences (e.g. language, filters) and cache data.

Communication and support data: correspondence and attachments you send us for support, complaints or requests.

Legal consent records: records of which version of the legal texts you accepted, when, in which language and by which method (date and time, IP address, device information).

Note on profile verification: on Frogie, profiles are verified through approvals from users who know you. No facial recognition is performed and no biometric data is processed. Uploaded photos go through automated image screening to detect content that breaks the community rules (nudity, violence, etc.); this screening is not used to identify anyone.

3. PURPOSES OF PROCESSING

Your personal data is processed to:

  • create your account, verify your email address, and manage and secure your account;
  • show you suitable profiles and create matches based on your location, preferences and filters;
  • run the rating, Trust Score, social tag, analysis and Feed Score systems;
  • provide features such as messaging, date invitations, Super Point, boosts, profile verification and referrals;
  • enforce the community rules; prevent fake accounts, harassment, fraud, spam and unlawful content; review reports and take the necessary measures;
  • handle and verify subscriptions and in-app purchases;
  • send notifications and answer support requests;
  • improve the service, detect errors and produce statistics;
  • comply with legal obligations, respond to requests from competent authorities and protect the Company's rights in possible disputes (including legal consent records).

4. METHOD OF COLLECTION AND LEGAL GROUNDS

Your personal data is collected fully or partly by automated means through registration and profile forms, your in-app actions, device permissions, Google/Apple sign-in services, the payment stores, evaluations other users make about you, and support correspondence. The legal grounds are:

  • KVKK Art. 5/2(c): necessity for the conclusion and performance of the Terms of Use (account, matching, messaging, ratings, purchases);
  • KVKK Art. 5/2(ç): compliance with the Company's legal obligations (e.g. Law No. 5651, tax legislation, requests from official authorities);
  • KVKK Art. 5/2(e): establishment, exercise or protection of a right (e.g. report records, legal consent records, evidence in disputes);
  • KVKK Art. 5/2(f): the Company's legitimate interests, provided they do not harm your fundamental rights and freedoms (e.g. platform security, fraud prevention, Feed Score, service improvement);
  • KVKK Arts. 5/1 and 6/2: your explicit consent (special categories of personal data and the processing described in the explicit consent forms). For device location and notifications, your permission is also requested through your device's permission screen.

5. DATA VISIBLE TO OTHER USERS

Frogie is a social platform. Your name, age, photos, bio, profile answers, profile details such as height and profession, and the approximate distance between you are shown to users who see you on the discovery screen or match with you. Once there are enough evaluations (at least 3), your average Trust Score and the tags assigned to you are shown on your profile; the identity of the people who rated you is not shown. Your messages are shared only with the person you are chatting with.

The Company cannot technically fully prevent other users from using device features such as screenshots or screen recording. Sharing content in this way without permission is prohibited under the Terms of Use; the Company takes the necessary measures when such violations are reported.

6. TRANSFER OF PERSONAL DATA

Your personal data is not sold and is not shared with third parties for advertising. Limited to the purposes above, your data may be transferred to the following groups of recipients:

  • Cloud and infrastructure providers: Google LLC / Google Cloud and Firebase (authentication, database, file storage, server functions, notification delivery, Google sign-in and automated photo screening with Google Cloud Vision) and, where necessary, similar cloud infrastructure providers;
  • Apple Inc.: Sign in with Apple, App Store purchases and iOS notifications;
  • Google Play: Android purchases;
  • RevenueCat, Inc.: management and verification of subscriptions and purchases;
  • GoDaddy (email service provider): sending email verification codes and support correspondence;
  • your device's operating system services (Apple/Google): converting your location into a province/district name;
  • legal, consulting and audit service providers: to the extent necessary to protect rights and meet legal obligations;
  • competent public authorities and courts: where legally required and to the extent requested.

Because the servers of these service providers are located abroad (mainly in the USA and the European Union), your data is transferred abroad. These transfers are made under KVKK Art. 9, primarily on the basis of appropriate safeguards such as the standard contracts announced by the Personal Data Protection Board and, where these cannot be applied, on the basis of your separately given Explicit Consent to International Transfer.

7. AUTOMATED PROCESSING AND PROFILING

The average Trust Score, the analysis screens and the Feed Score are calculated by automated systems and may affect the visibility of your profile. These systems do not by themselves take decisions such as closing your account; restriction and closure decisions are based on a review of rule violations. Under KVKK Art. 11/1(g) you may object to a result against you arising from automated analysis.

8. RETENTION PERIODS

  • Account and profile data: kept while your account is open. When you delete your account in the App, your profile, photos, messages, matches, the ratings and reviews given to you and your sign-in account are permanently deleted.
  • Ratings and reviews you gave to others: not deleted, so that the other person's Trust Score and analysis are not distorted; your name and photo are removed and they are stored anonymously under the name "Frogie User".
  • Incomplete registrations: deleted if not completed within 7 days.
  • Report, restriction and security records: kept for the relevant limitation periods.
  • Legal consent records: kept for 10 years from the date of the record (the general limitation period under the Turkish Code of Obligations No. 6098), even if your account is deleted, to prove consent and notification, and deleted or anonymised at the end of that period.
  • Purchase records and other records that the law requires us to keep (e.g. records under Law No. 5651, tax records): kept for the periods set out in the relevant legislation.

Data whose retention period has expired is deleted, destroyed or anonymised in line with the Company's personal data retention and destruction processes.

9. DATA SECURITY

Under KVKK Art. 12, the Company takes the necessary technical and organisational measures to prevent unlawful processing of and access to your personal data: data is transmitted over encrypted connections; database access is limited by authorisation rules; passwords and verification codes are not stored in plain text; access to the admin panel is limited to authorised staff and logged. If your data is nevertheless obtained unlawfully by third parties, the Personal Data Protection Board and you will be notified within the period set by law.

10. YOUR RIGHTS UNDER ARTICLE 11 OF THE KVKK

By applying to the Company you have the right to: learn whether your personal data is processed; request information if it has been processed; learn the purpose of processing and whether it is used for that purpose; know the third parties in Türkiye or abroad to whom it is transferred; request correction if it is incomplete or inaccurate; request its deletion or destruction under the conditions in KVKK Art. 7; request that correction and deletion be notified to third parties to whom it was transferred; object to a result against you arising exclusively from analysis by automated systems; and claim compensation if you suffer damage due to unlawful processing.

You may withdraw your explicit consent at any time. Withdrawal does not affect the lawfulness of processing before the withdrawal. Because the matching service depends on the processing of special categories of data, the service may not be available if you withdraw this consent; in that case you can delete your account in the App.

You can send your requests, in line with the Communiqué on the Procedures and Principles of Application to the Data Controller, in writing to the Company's address (with a wet-ink signed petition), via registered electronic mail, secure electronic signature or mobile signature, or from the email address registered in the App to support@frogie.app. Your application must contain information identifying you and an explanation of your request. Applications are concluded free of charge within 30 days at the latest; if the process requires an additional cost, the fee in the tariff set by the Board may be charged. If your application is rejected, the answer is insufficient or no answer is given in time, you may file a complaint with the Personal Data Protection Board.

11. CHILDREN'S PRIVACY

Frogie is not intended for anyone under 18. Accounts and data of anyone found to be under 18 are deleted.

12. CHANGES

This text may be updated. The current version is always available in the App under Settings → Legal. Where a change requires your explicit consent, the updated texts are shown to you when you open the App and your consent is obtained again.

13. DATA CONTROLLER DETAILS

Data Controller / Service Provider: TILL C YAZILIM İÇ VE DIŞ TİCARET LİMİTED ŞİRKETİ
MERSIS No: 0843093413500001
Address: Emniyet Evler Mahallesi, Eski Büyükdere Caddesi, Sapphire No: 1/1, İç Kapı No: 1B04, Kağıthane / Istanbul, Türkiye
Email: support@frogie.app