Distance Of Life — Legal Documents

Privacy Policy · Data Protection Notice · Explicit Consent · Artificial Intelligence Policy · Terms of Use · Subscription Terms

Document Version: v2.1  |  Last Updated: 23 August 2026  |  Türkçe

Data Controller / Operator: Alp Akın İncesulu. If a sole proprietorship or other legal entity is established in the future, the role of data controller may be transferred to that entity in accordance with applicable law, and Users will be informed.

Contact: For general enquiries, info@distanceoflife.com; for privacy, KVKK requests, account/data deletion and support requests, support@distanceoflife.com.

For account deletion requests and the process: Account Deletion.

This is a translation of the Turkish reference text. Unless mandatory local law requires otherwise, the Turkish version is the reference version (see 16.13).

Distance Of Life is a general life-tracking, productivity and health/fitness support application intended for users aged 18 and over. The Application is not a medical device and does not provide diagnosis, treatment, disease prevention or professional healthcare services. Health, mood and AI features are designed as optional modules, and separate consent mechanisms are used where required.

This document has been prepared primarily on the basis of the laws of the Republic of Türkiye. Where the Application is offered in other jurisdictions, mandatory consumer-protection, data-protection, subscription, child-safety and digital-services rules of the relevant jurisdiction remain applicable for the benefit of the User. Nothing in these Terms shall be interpreted as excluding or restricting rights granted to a User under mandatory law where such rights cannot lawfully be waived by contract.

Where services are offered to individuals in the EU/EEA or their behaviour is monitored, the GDPR applies to the extent legally applicable. For Users in the United Kingdom, the UK GDPR, the Data Protection Act 2018 and applicable amendments are taken into account. In the United States, applicable federal and state consumer and privacy rules may apply depending on the nature of the User, the Operator and the relevant processing activities.

Any feature-specific notice, prominent disclosure, subscription screen, AI consent, or health-data consent applies together with this general document. In the event of an inconsistency, the more specific and current notice relating to the relevant processing activity shall be considered first, subject in all cases to mandatory law.

For the purposes of Turkish Personal Data Protection Law No. 6698 (KVKK), the data controller is Alp Akın İncesulu. General enquiries may be sent to info@distanceoflife.com. Privacy, KVKK requests, account/data deletion requests and support enquiries may be sent to support@distanceoflife.com.

If the Operator later establishes a sole proprietorship or other legal entity, transfers the business, merges, or undergoes a restructuring, the role of data controller/operator may be transferred to the relevant successor entity in accordance with applicable law. Users will be informed of material changes.

• Identity and profile data: username/nickname, year of birth and profile preferences.
• Contact data: email address and support communications.
• Account and security data: account identifier, friend code, session/login records, security events and verification information.
• Productivity and life-tracking data: tasks, habits, goals, plans, notes, journals, reminders, book/film/series/anime tracking, Pomodoro/focus, meditation, spaced repetition, XP/level/badge and similar usage data.
• Financial data: budget, income/expense records and similar personal tracking data entered by the User.
• Health/fitness data: mood, sleep, body measurements, weight, calories, nutrition, water intake, steps, exercise and sports-performance records.
• User Content: journal/text, project and task content, photographs/media, voice-note audio recordings, AI chats and AI requests.
• Shared areas: projects, tasks, subtasks and related content shared with friends or project members.
• Technical data: device/operating-system version, application version, IP and network/security logs, error logs, performance/crash records and necessary technical identifiers.
• Purchase/subscription data: purchase status, product/plan identifier, subscription status and verification data received through Google Play. The Operator does not directly receive or store full credit/debit card numbers.

Health-related information may constitute special categories of personal data under the KVKK and “special category data” under the GDPR/UK GDPR. Such data is processed only where the relevant health/fitness module has been enabled and a valid legal basis is available. Where processing relies on consent, such consent must be explicit, specific, informed and capable of being withdrawn.

The Application does not intend to request data concerning race or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data used for unique identification, or information concerning sex life or sexual orientation. Users should not voluntarily enter such information into free-text fields or AI chats.

• Information entered or uploaded directly by the User.
• Technical and security records automatically generated through use of the Application.
• Subscription verification and status information received from payment/distribution platforms such as Google Play.
• Data obtained from integrations or device permissions enabled at the User’s request, where applicable.
• Device permissions: the camera is used when the User chooses to take a photograph or scan a barcode, and the microphone when the User starts a voice-note recording. Barcode reading is performed on the device and the camera feed is not sent to any server; photographs taken are uploaded to the image hosting provider, and voice notes are stored with the account as part of the note. Permissions can be withdrawn at any time from device or browser settings; where permission is not granted, only the related feature stops working.

The objective is to process only the data necessary to provide the relevant feature, ensure security or comply with a legal obligation. Technically unnecessary permissions and data fields should not be used. Health data in particular should be protected through separate access controls and heightened security measures.

Personal data may be shared with processors and technical service providers to the extent necessary to provide the service. Under the current architecture, such providers may include Google Firebase/Cloud Functions and related Google infrastructure, Cloudinary, OpenAI, DeepSeek and Google Play. Open data sources such as Open Food Facts are used only as content/data sources where they do not receive personal data.

Where the User enables shared projects or friend features, Content selected by the User may be visible to other Users whom the User invites or works with and, depending on the design of the feature, may be edited or deleted by those Users.

Personal data is not disclosed to third parties except where there is a valid legal basis, such as a statutory obligation, an order from a competent authority, the establishment or defence of a legal right, or a security/fraud investigation.

The current version of the Application does not contemplate the sale of User personal data to data brokers or the use of personal or health data for third-party behavioural advertising. If advertising or a similar business model is introduced in the future, this Policy and any necessary consent/preference mechanisms will be updated before the relevant data flows are activated.

Because of the Application’s cloud and artificial-intelligence infrastructure, personal data may be processed outside Türkiye or made accessible from other countries. For international transfers, the mechanism appropriate under applicable law will be used, which may include an adequacy decision, standard contractual clauses, binding corporate rules, other appropriate safeguards or an applicable statutory derogation.

For Türkiye, the international-transfer regime under Article 9 KVKK and, where necessary, standard contracts or other appropriate safeguards published or recognized by the Personal Data Protection Authority shall be considered. For the EU/EEA, adequacy decisions, the European Commission Standard Contractual Clauses (SCCs) or another lawful transfer mechanism may be used. For the United Kingdom, the applicable UK transfer instruments shall be assessed.

When an AI feature is activated, the User will also be informed at the point of activation which provider will receive the relevant input and that processing may take place outside the User’s country.

• Server-side management of API keys and prevention of secrets from being embedded in the client application.
• Firestore/backend security rules and application of the principle of least privilege.
• Use of modern encryption in transit (TLS/HTTPS), to be verified in the production configuration.
• Role-based and need-to-know access to sensitive data and restriction of administrator access.
• Avoiding unnecessary personal or health data in logs.
• Security updates, dependency/SDK monitoring and retention of access/event records for appropriate periods.
• Consideration of the data lifecycle in backup and deletion procedures.

Absolute security cannot be guaranteed for internet-based or cloud systems. The Operator intends to implement reasonable technical and organizational measures appropriate to the nature of the risk.

Where a personal-data breach is suspected, the scope of the incident will be assessed, risk-mitigation measures will be taken, and the competent data-protection authority and/or affected Users will be notified where required by applicable law. Users are also requested to report suspected unauthorized access without undue delay to support@distanceoflife.com.

• To learn whether personal data is being processed and to request information about such processing.
• To access personal data and, where possible, obtain a copy.
• To request correction of inaccurate or incomplete data.
• To request deletion or anonymization where the applicable conditions are met.
• To request restriction of processing or object to processing to the extent applicable.
• To withdraw consent prospectively where processing is based on consent.
• To data portability to the extent applicable.
• Where solely automated decisions produce legal or similarly significant effects, to request relevant information and human intervention where applicable.
• To lodge a complaint with a competent data-protection authority where regional law provides such a right.

Privacy and data-rights requests may be submitted to support@distanceoflife.com. Only the minimum additional information appropriate to verify the identity of the requester will be requested. Requests will be handled in accordance with the time limits and procedures required by applicable law. Financial or legal records that must lawfully be retained may be excluded from deletion to the extent permitted or required by law.

AI-generated recommendations, scores, summaries or analyses are provided to assist the User and should not, by themselves, be used to make a legal or similarly significant decision about the User. If such functionality is introduced in the future, the relevant legal basis, User rights and required additional disclosures will be provided in advance.

If I choose to use the optional health and fitness features of the Distance Of Life Application, I explicitly consent to the processing of my health-related data, including mood, body measurements, weight, sleep, calorie/nutrition information, water intake, steps, exercise and sports-performance data, solely for the purposes of operating and synchronizing the tracking features I select, providing reports/summaries to me, and generating AI analyses that I request.

I understand that I may use the basic account and features that do not require health data without giving this consent; that I may withdraw my consent through the Application settings or by contacting support@distanceoflife.com; and that withdrawal will not affect processing lawfully carried out before withdrawal, but may prevent the relevant health features from functioning.

If I choose to use artificial-intelligence features, I understand that only the text, photographs, chat content and feature-context data necessary to operate the relevant AI function may be transmitted through the server infrastructure to the AI provider disclosed at that time and may, depending on that provider’s infrastructure, be processed outside my country.

The Application intends to use an appropriate international-transfer mechanism under applicable law. Where a particular transfer relies on my consent, I may withdraw that consent prospectively; in that case, AI features may no longer be available to me.

I separately consent to the use of my contact information for campaigns, product news and similar commercial electronic communications. This preference is not a condition of the core service and may be withdrawn at any time.

The Application may use artificial-intelligence models for functions including natural-language data entry, food/calorie estimation from photographs, Companion chat, the Personal Guide onboarding flow, weekly reports, summaries and similar functionality.

Where practicable, AI requests are routed through the Application’s server-side infrastructure to the relevant provider. API keys must not be stored in exposed form on the User’s device or shared with the User. Under the current plan, DeepSeek may be used for Premium and OpenAI may be used for Premium Plus. The Operator may change the provider or model for reasons including service quality, security, cost or technical requirements.

Where a change of provider/model materially affects the country of data processing, the purpose of processing or another matter relevant to the User, the relevant policy and in-feature disclosure will be updated and fresh consent will be obtained where required.

• Text entered by the User into an AI field.
• Photographs/media specifically selected by the User for AI analysis.
• Contextual records required for the requested analysis, such as relevant tasks, habits, journals, meals, mood entries or report summaries.
• The portion of AI chat history necessary to provide the requested response.

The User should not submit another person’s identity, health, financial, private-life or other sensitive information to an AI feature without appropriate authorization.

AI outputs are generated by probabilistic systems and may contain inaccurate, incomplete, biased, out-of-context or outdated information. The Operator does not guarantee the accuracy, completeness, uninterrupted availability or fitness for a particular purpose of AI outputs. Users should independently verify information before relying on it for important decisions.

• Using AI to make a medical diagnosis, determine a prescription or medication dosage, or make an emergency healthcare decision without qualified professional input.
• Requesting or using instructions for self-harm, harm to others, violence, unlawful activity, fraud or dangerous conduct.
• Relying solely on AI output for high-impact decisions concerning employment, credit, insurance, legal consequences or other decisions materially affecting a person’s rights.
• Submitting another person’s personal data or special-category data for analysis without authorization.
• Generating or using Content that infringes copyright, trademarks, trade secrets, confidentiality or privacy rights.
• Using automation or prompts to circumvent system security, model/service restrictions, usage limits or anti-abuse safeguards.

Food/calorie analysis from photographs and similar results are estimates. Portion size, ingredients, preparation method, brand and ingredients not visible in the image may create a significant margin of error. Such values must not be used as a substitute for professional advice in the management of diabetes, eating disorders, pregnancy, medication use or other medical conditions.

Third-party AI providers may have different data-retention, security and model-development practices depending on the product, contract and account settings in use. In production, the Operator intends to minimize data transfers, use appropriate business/API plans, and, where available, select settings that restrict the use of User inputs for model training. Relevant data flows should be reassessed when provider terms or configurations change.

AI features may be temporarily or permanently limited, the provider may be changed, or a feature may be removed due to provider outages, quotas, cost, security concerns, sanctions, regional restrictions or changes in law. The User should not assume that any specific AI model will remain continuously available.

On every screen where artificial-intelligence output is displayed (Companion chat, the daily touch, the Personal Guide, the weekly coach report, AI analysis and calorie estimation from photographs), a ⚠️ report button is provided immediately next to the output. By selecting a reason, the User may report harmful or dangerous advice, incorrect information, abusive language, sexual content, an inappropriate response concerning self-harm and similar situations.

A report records only a copy of the relevant output, the feature it originated from, the selected reason and the User’s optional explanation; the full chat history is not sent. Reports are reviewed and, where necessary, corrections are made at the level of instructions, filters or the model/provider. This mechanism does not remove the warnings stating that AI output is provided for informational purposes and does not replace professional advice.

By creating an account or continuing to use the Application, the User accepts the then-current version of the Terms of Use and the applicable mandatory disclosures. Consents required for optional processing activities are obtained separately from acceptance of these contractual Terms.

The Application is intended for Users who are at least 18 years old. Persons under the age of 18 are prohibited from creating an account or using the Application. The User is responsible for providing accurate age information. Where there is a reasonable concern regarding eligibility, the Operator may request additional age verification or restrict the account.

• Keep login credentials and verification codes confidential.
• Take reasonable measures to prevent unauthorized access to the User’s device.
• Notify the Operator without undue delay of suspected unauthorized access.
• Do not rent, sell or transfer the account to third parties without authorization.

For security purposes, the Operator may terminate suspicious sessions, request re-verification or temporarily lock an account.

The User is responsible for the accuracy and currency of information entered into the Application. To the extent permitted by applicable law, the Operator is not responsible for incorrect calculations, reminders or reports resulting from inaccurate User input.

Distance Of Life is a productivity, tracking, planning, general wellness and personal-organization tool. No guarantee is made that every feature will be continuously available, error-free or supported on every device, in every region, or at all times.

The Operator may update, modify, combine, limit or remove features for reasons including security, technical requirements, legal or regulatory changes, third-party provider changes, cost or product development. Where a change materially affects the core and ongoing value of a paid plan, applicable consumer-protection requirements and Google Play rules will be observed.

Features identified as beta or experimental may contain errors, may use data formats that change, and may be discontinued without continued support. A beta feature should not be used as the sole storage or decision source for critical information.

Operation of the Application may depend on a supported operating-system version, device capabilities, internet connectivity, notification permissions, battery optimization settings and third-party services. Full compatibility with all Android devices, custom ROMs or future operating-system versions is not guaranteed.

The Application may rely on third-party services including Firebase, Cloudinary, AI providers and Google Play. Their own terms, outages, security events or policy changes may affect certain functions of the Application. The Operator does not guarantee the continuity of third-party services outside its reasonable control.

For security or compatibility reasons, use of certain versions may be discontinued and an update may become necessary. The Operator is not required to support obsolete versions indefinitely.

The User retains the rights that the User holds in Content uploaded to or created within the Application. The Operator does not acquire ownership of User Content merely because it is stored or processed through the service.

The User grants a limited, non-exclusive permission, connected to the duration of the service and limited to what is necessary, for User Content to be processed for hosting, synchronization, backup, display to the User, operation of sharing/AI functions requested by the User, and technical support. This permission does not authorize the Operator to sell User Content for advertising purposes or exploit it independently for unrelated commercial purposes.

The User represents that the User has the rights necessary to upload and use the Content and that such Content does not infringe the intellectual-property, privacy, personality or data-protection rights of third parties.

• Use for unlawful activity, fraud, phishing, threats, harassment, hate, violence or the purpose of harming another person.
• Content involving child sexual abuse or exploitation, non-consensual intimate imagery or similarly serious violations.
• Content that infringes copyright, trademarks, trade secrets, confidentiality, privacy or personality rights.
• Malware, exploits, attack tools or activity intended to obtain unauthorized access.
• Spam, automated account generation, scraping, exceeding rate/usage limits, or circumventing API or security controls.
• Reverse engineering or decompilation intended to obtain the Application’s source code, security mechanisms or trade secrets unlawfully, subject to exceptions expressly permitted by mandatory law.
• Uploading or sharing another person’s identity, health, financial or other sensitive data without authorization.
• Selling, renting or fraudulently sharing an account or subscription/credit entitlement with another person.
• Placing a disproportionate load on the service infrastructure or disrupting other Users’ access.

The User understands that, in shared projects the User creates, joins or is invited to, projects, tasks, subtasks and related Content may be visible to other members and, depending on the feature design, may be edited or deleted by them. The User is responsible for disclosure of an invitation code or access link to an unintended person.

Sensitive or special-category personal data concerning third parties should not be entered into shared areas. The User must not share data relating to another person without the necessary legal authority.

Where there is a security risk, unlawful Content, infringement of third-party rights, a violation of platform policy, or a serious or repeated breach of these Terms, the Operator may restrict or remove Content or temporarily or permanently suspend an account. Where required by applicable law, an appropriate appeal or review mechanism will be provided.

In-application reporting and blocking tools are provided. Using the ⚠️ button next to the relevant item, a User may report a profile (nickname, photograph), a friend request, a project or shared-goal invitation, and tasks in shared projects; a reason may be selected and an explanation added. Reports are transmitted to the Operator and reviewed within a reasonable period; Content that breaches the rules may be removed and the relevant account may be restricted or closed. The identity of the reporting User is not disclosed to the reported User.

A User may block any person using the 🚫 button. Content from a blocked person is not shown to the User, any existing friendship between them ends, and the blocked person cannot send the User friend requests, project invitations or shared-goal invitations. The block list can be viewed and cleared under Profile > Blocked People; the list is visible only to the User.

Users may also report unlawful or rights-infringing Content to support@distanceoflife.com.

The Distance Of Life name, logo, application design, software code, original interface elements, documentation and other materials belonging to the Operator are protected by applicable intellectual-property laws. The User is granted only a limited, non-transferable and revocable right to use the Application for personal use.

The Application’s built-in food list uses generic product descriptions instead of brand names (for example “cola (sugar-free)” or “chocolate-coated wafer” rather than a specific product name). That list contains approximate average reference values compiled from general sources; the values vary according to recipe, brand, cooking method and portion size and may not be interpreted as the declared values of any particular commercial product.

Where data for a specific packaged product is needed, the Application queries the Open Food Facts open database upon the User’s search or barcode scan. That data is made available under the Open Database License (ODbL) and the source is credited within the Application. Book page-count information is obtained from the Google Books and Open Library catalogues.

Product, brand and trade names that may appear in results from these sources belong to their respective rights holders and are displayed solely in order to identify the product. Such use does not imply any affiliation, sponsorship, cooperation or endorsement between the Operator and the relevant trademark owners. A rights holder who considers the use to be incorrect may send a notice to support@distanceoflife.com; the request will be reviewed and, if justified, the relevant content will be removed.

The Application may offer Premium, Premium Plus or other paid plans introduced in the future. The price, billing period, renewal type, AI quota and principal benefits of each plan are displayed on the purchase screen.

Eligible digital subscriptions/products offered in the Android application are processed through Google Play’s payment infrastructure. The Operator does not directly access or store the User’s complete credit/debit card information. Purchase and subscription management may be conducted through the User’s Google Play account.

If the User purchases an automatically renewing plan, the subscription may renew for successive billing periods until the User cancels it through Google Play. The purchase screen must clearly disclose the price, billing frequency, renewal conditions and any trial period. Uninstalling the Application does not, by itself, cancel the subscription.

A subscription purchased through Google Play may be managed and cancelled through the Google Play subscription center or an account/subscription-management link within the Application. The effective time of cancellation and access during the current billing period are governed by Google Play rules and applicable local law.

Where Google Play is the purchase channel, refunds are subject to Google Play refund procedures and any mandatory consumer rights applicable in the User’s jurisdiction. Nothing in these Terms excludes any refund, withdrawal or cancellation right that cannot lawfully be waived.

The Operator may change prices, plan names, quotas or benefit structures for future subscription periods. Price increases and material subscription changes will follow any notice or consent processes required by Google Play and applicable consumer law.

• AI credits/quotas do not constitute money or electronic money.
• Unless otherwise stated in the plan description, they are non-transferable and cannot be redeemed for cash.
• Usage may be subject to reasonable rate or quota limits for abuse prevention, security or technical-capacity reasons.
• Quotas and plan benefits must be clearly disclosed on the purchase screen and should provide sustainable/recurring value throughout the subscription.
• Whether unused credits roll over to a later period must be stated on the plan screen; no rollover right is implied unless expressly disclosed.

If a free trial is offered, the trial duration, price charged after the trial, first paid billing period, automatic-renewal terms and the method of cancellation before charging begins must be clearly disclosed. A later automatic charge must not be obscured by describing an offer as “free.”

Distance Of Life is not a medical device and is not designed to diagnose, treat, cure or prevent any disease. The Application does not provide medical advice, diagnosis, treatment, prescriptions or professional healthcare services.

A physician or other qualified healthcare professional should be consulted for medical advice, diagnosis or treatment. The User should not delay or discontinue professional medical care because of information presented in the Application.

Calories, macronutrients, water intake, BMR/TDEE, 1RM, training intensity, sleep metrics and similar calculations or recommendations are estimates or general information. They may not be suitable for a particular individual because of age, medical history, illness, pregnancy, medication, physical capacity or measurement error.

Physical exercise, particularly heavy lifting and 1RM testing, may involve risk of injury or adverse health effects. The User should assess the User’s own physical condition, apply appropriate technique and safety measures, and seek professional advice where necessary. Exercise should be stopped and appropriate professional assistance sought if pain, shortness of breath, dizziness or other unusual symptoms occur.

The Application is not an emergency medical service and does not guarantee that it will detect or respond to an emergency. In an emergency, the User should contact the official emergency services available in the User’s location.

“Distance Of Life is not a medical device and does not diagnose, treat, cure, or prevent any medical condition. Consult a qualified healthcare professional for medical advice, diagnosis, or treatment.”

Features such as mood tracking, journaling, meditation and the AI Companion are provided for personal awareness and general wellness purposes. They are not psychotherapy, psychiatry, a crisis hotline or a professional mental-health service.

The AI or the Application may not always detect a crisis or a risk of self-harm or harm to others. A User experiencing an urgent or serious situation should not rely on the Application and should instead seek appropriate professional or emergency assistance available in the User’s location.

Mood scores, weekly analyses and AI commentary within the Application must not be treated as a clinical assessment.

Financial/budgeting features are personal-organization tools intended solely to help the User record and generally track the User’s own data. The Application does not provide investment advice, financial planning, credit advice, accounting, tax advice or legal services.

Budgets, ratios, summaries and AI commentary within the Application should not be used as the sole basis for a financial decision and must not be treated as official accounting records, tax filings or legally required records.

Reminders and notifications may be delayed or may not be delivered because of the operating system, device manufacturer, battery optimization, internet connectivity, notification permissions, silent mode or third-party service outages. The Application should not be used as the sole reminder source for medication, emergency health actions, payment deadlines, official appointments or other critical obligations.

The User should be able to initiate an account-deletion request through a clear in-application path such as “Settings > Account > Delete My Account” and through an account-deletion page/request form accessible on the internet. A support email may be offered as an additional channel but should not replace the in-app/web deletion route.

Account deletion is intended to remove the User’s account identifier and associated User data that is no longer necessary for the service from active systems, or to irreversibly anonymize such data. Limited records that must be retained because of legal obligations, fraud/security investigations, financial-record requirements or legal disputes may be retained for the applicable mandatory period.

Deleted data may remain for a limited period in disaster-recovery or routine technical backups and may be overwritten or deleted in the ordinary backup cycle. Data in backups should not be restored to active use for ordinary business purposes; if restoration becomes necessary, previously applicable deletion requests should be re-applied as appropriate.

When an account is deleted, certain Content in shared project areas may remain in anonymized form where necessary to preserve other Users’ record integrity or legal rights. Unnecessary links to the deleted User’s personal identity should be removed.

Deleting an account may not automatically cancel a Google Play subscription. To stop recurring charges, the User must also manage or cancel the subscription through Google Play. This point should be clearly displayed on the account-deletion screen.

Distance Of Life is not directed to persons under the age of 18. Persons under 18 are not permitted to create an account or use the Application.

The year of birth or another appropriate age-assurance method may be used during registration. The User is responsible for providing accurate age information. Deliberately falsifying age information constitutes a breach of the Terms of Use.

If the Operator obtains reasonable information indicating that an account belongs to a person under 18, the Operator may suspend the account, request age verification, and delete or anonymize personal data in accordance with applicable law.

A parent or legal guardian who believes that personal data relating to a person under 18 is being processed through the Application may contact support@distanceoflife.com. The request will be assessed subject to appropriate verification of the requester and applicable law.

Store listings, advertising and design elements will not be prepared in a manner intended to target children. If material use by children becomes apparent, the age-assurance approach and applicable regional child-data-protection obligations will be reassessed.

Where EU/EEA or United Kingdom data-protection law applies, processing should be carried out in accordance with the principles of lawfulness, fairness and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity/confidentiality; and accountability.

An appropriate Article 6 legal basis must be identified for each processing purpose. For special-category data such as health information, a valid condition under Article 9 must also apply. Where consent is relied upon, it must be freely given, specific, informed, unambiguous and capable of being withdrawn.

To the extent applicable, Users are afforded rights of access, rectification, erasure, restriction, objection, data portability, withdrawal of consent and rights relating to automated decision-making. A User may also lodge a complaint with the competent supervisory authority.

Transfers from the EU/EEA to third countries will use an adequacy decision, SCCs or another valid safeguard/derogation as appropriate. Restricted transfers from the United Kingdom will use applicable UK transfer mechanisms. Users will be provided with the required transparency regarding destination countries/categories and safeguards used.

Where the Operator is not established in the EU/EEA or United Kingdom, the need to appoint a local representative under the GDPR/UK GDPR should be assessed before production in light of the scope of the service and processing activities. If circumstances such as large-scale processing of special-category data arise, the need to appoint a Data Protection Officer (DPO) should also be assessed. If an appointment is made, the relevant contact details should be added to this Policy.

Where health/mood data, AI analysis, profiling or other high-risk processing is carried out on a material scale, a Data Protection Impact Assessment (DPIA) is recommended and may be legally required. The DPIA should document risks, data minimization, access controls, retention and international-transfer safeguards.

Because the Application is designed for users aged 18 and over, it is not directed to children under 13 and is not intended to knowingly collect personal information from children under 13. If the Operator learns that personal information has been collected from a User under 13, appropriate deletion or blocking measures will be taken in accordance with COPPA and other applicable rules.

Where applicable U.S. state privacy laws apply to the Operator and the User, mandatory rights such as access, correction, deletion, portability, opting out of certain processing activities, or freedom from unlawful discrimination will be provided as required. The scope of these rights may vary by state, business size and processing activity.

Health and wellness data may be subject to specific consumer-health-data requirements in the User’s jurisdiction. The Operator should not sell such data for advertising or data-brokerage purposes and should assess regional obligations and required permissions before adding a new purpose of use.

To the extent permitted by applicable law, the Application is provided on an “as is” and “as available” basis. No warranty is given of uninterrupted operation, zero defects, freedom from data loss, accuracy of AI outputs, compatibility with any particular device, or achievement of any particular result.

To the maximum extent permitted by mandatory law, the Operator shall not be liable for loss of profits or revenue, loss of data, business interruption, indirect loss or consequential loss, particularly where the loss results from the User’s device, connectivity, a third-party service, inaccurate User input or breach of these Terms.

Nothing in these Terms excludes liability arising from the Operator’s wilful misconduct or gross negligence, or liability for death, personal injury, consumer rights or other matters that applicable law does not permit to be contractually excluded or limited.

The User is responsible, to the extent of the User’s own fault and legal liability, for losses and third-party claims arising from unlawful Content, infringement of third-party rights, unauthorized disclosure of data, or breach of security rules.

The Operator may implement reasonable backup and security measures but does not guarantee that data loss will never occur. Users are encouraged to maintain an independent copy of critical or irreplaceable information.

Subject to mandatory law, liability for delay or interruption is limited to the extent the service is prevented by events beyond the Operator’s reasonable control, including natural disasters, war, government action, widespread internet or power outages, cyberattacks, telecommunications/cloud-provider failures, sanctions or similar events.

Where there is suspected fraud, a security risk, unlawful activity, infringement of third-party rights, payment abuse, or a material or repeated breach of these Terms, the Operator may temporarily restrict or terminate the account. Proportionality and applicable appeal rights will be respected.

This document may be updated as laws, Google Play policies, product features or data flows change. Material changes will be communicated by an appropriate method such as an in-app notice or email. Processing that requires a new or different consent will not begin until the required consent has been obtained.

In the event of incorporation, merger, restructuring or transfer of the service, the Operator may assign the rights and obligations under these Terms to a successor operator, provided that Users’ mandatory rights are preserved and required notices are given.

If any provision is found invalid or unenforceable, the remaining provisions remain in force. To the extent legally possible, an invalid provision should be interpreted or replaced by a valid provision that most closely reflects its legitimate economic purpose.

A failure to exercise a right in a particular instance does not constitute a waiver of that right in the future.

The relationship between the Operator and the User is principally governed by the laws of the Republic of Türkiye. However, mandatory consumer-protection or data-protection rules and jurisdictional rights that cannot be waived by contract in the User’s place of residence remain unaffected. For Users who qualify as consumers in Türkiye, mandatory rights concerning consumer arbitration committees and consumer courts are preserved.

This document may be translated into other languages. Unless mandatory local law requires otherwise, the Turkish version is the reference version. If local mandatory law requires different transparency or grants non-waivable rights that cannot be limited by the reference-language provision, those mandatory requirements will apply.

General: info@distanceoflife.com

Privacy / KVKK / Support / Account Deletion: support@distanceoflife.com