Privacy Policy

1. Who we are and how to contact us

Data Controller: CIFROVIE RESHENIYA INSAN KAYNAKLARI VE DANISMANLIK ANONIM SIRKETI

Zeytinlik Mahallesi, Halkçi Sokak, Iren Han, Gur Carsi Blok, No: 28/58

Bakirkoy 34140 Istanbul

Turkey

Contact email for all privacy- related matters: support@duolink.pro

If you have any questions about how we process your data, please write to the above email. We will respond within the time limits provided by the legislation of your country (usually no more than 30 days).

2. What data we collect

We may collect the following categories of information:

  • Data you provide voluntarily: first name, last name, email address, password, profile picture, date of birth, gender, country and city of residence, languages you speak or want to learn, as well as any other content you upload or send through our service (e.g. text messages, photos, audio and video recordings).
  • Service usage data: information about your actions in the application or on the website (clicks, pages viewed, session time), purchase data (if applicable), support request logs.
  • Technical data: IP address, device type, operating system, app version, unique device identifiers (e.g. advertising ID), connection data, cookies.
  • Data from third- party sources: if you register via social networks (Google, Facebook, etc.), we receive from them the information you have authorised them to share (name, email, friends list, etc.) in accordance with their privacy policies.

3. Purposes of data processing

  • Providing the service: creating and maintaining your account, granting access to features (finding partners, messaging, group chats, etc.), technical support.
  • Improving service quality: analysing how users interact with the application, collecting statistics, testing new features.
  • Security and moderation: preventing fraud, detecting suspicious activity, verifying profile authenticity (e.g. comparing photos against a database of blocked users), handling complaints and ensuring compliance with community rules.
  • Communication: sending service notifications (about new messages, policy changes, technical work), responding to your inquiries.
  • Marketing (only with your consent): sending news, personalised offers, notifications about promotions and events; showing personalised advertising in the app and on third- party platforms.
  • Fulfilling legal obligations: storing data for tax and accounting purposes (if applicable), complying with requests from government authorities as required by law.

4. Legal bases for processing

  • Your consent. You give it when registering (a separate checkbox) and in the app settings (e.g. to receive promotional emails or for cross- border data transfer where required by law). You may withdraw your consent at any time.
  • Performance of a contract. Processing is necessary to provide you with access to the service and to fulfil our obligations under the user agreement.
  • Legitimate interests. We may process data to ensure security, prevent abuse, improve the service and conduct analytics, provided your rights and freedoms do not override these interests.
  • Compliance with legal obligations. In cases where processing is required by the law of your country of residence (e.g. retention of financial records).

Your personal data is processed by us in accordance with the data protection legislation of your country of residence. For users in the European Economic Area this is the GDPR, for users in Turkey - Law No. 6698 (KVKK), for users in Russia - Federal Law No. 152- FZ "On Personal Data". For users from other countries we guarantee a level of data protection consistent with international standards.

5. Disclosure of data to third parties and cross-border transfer

We do not sell your personal data. We may share it with a limited circle of trusted partners who help us operate the service:

  • Hosting providers and cloud platforms (e.g. Google Cloud) - to store data and ensure the application runs.
  • Analytics systems (Google Analytics, Firebase, Yandex.Metrica) - to collect usage statistics.
  • Payment systems (Iyzico) - to process payments (if applicable). We do not store your bank card details.
  • Advertising networks (Google Ads, Meta Audience Network) - only with your consent, to show personalised advertising.
  • Authentication services (Google OAuth) - if you use social login.

Cross-border transfer

Your data may be processed on servers located outside your country, including in Turkey, the USA, the Netherlands, Russia - depending on the location of our partners and the storage regions they choose. We ensure the protection of data during such transfer using standard contractual clauses (for GDPR) or other mechanisms provided by law.

Important for users from Turkey: During registration you will see a separate checkbox "I agree to the transfer of my data abroad". By ticking it, you give your explicit consent (açik riza) to the cross- border transfer of your data in accordance with KVKK No. 6698. This is necessary for the operation of the service because our technical partners are located in different countries. You may withdraw this consent at any time in your profile settings.

Important for users from Russia: We notify you that your data may be transferred outside the Russian Federation. Such transfer is carried out in accordance with the requirements of Federal Law No. 152-FZ.

6. Data retention periods

We retain your data for as long as you use the service, unless a longer retention period is required by law. Specific periods depend on the purposes of processing:

  • Account and active data: kept until the account is deleted.
  • Messages and other content: stored permanently in the database until you delete them manually or delete your account. Please note: after account deletion, messages you have sent to other users may remain in their correspondence.
  • Logs and analytics: kept in anonymised or aggregated form for no more than 48 months.
  • Payment data: retained in accordance with tax legislation requirements (usually 5- 7 years).
  • Data of blocked users: certain identifiers may be stored for up to 48 months to prevent repeated violations.

You can delete your account at any time yourself in the app settings. After that, your personal data will be deleted or anonymised, except for data we are obliged to retain by law.

7. Your rights

Depending on your country of residence, you may have the following rights regarding your personal data:

  • Right of access - to request information about what data we hold and how we use it.
  • Right to rectification - to correct or update inaccurate data.
  • Right to erasure ("right to be forgotten") - to request deletion of your data if it is no longer needed for the purposes of processing or if you have withdrawn consent.
  • Right to restriction of processing - to temporarily suspend processing (e.g. while it is being verified).
  • Right to data portability (for the EU) - to receive your data in a structured, commonly used and machine- readable format.
  • Right to withdraw consent - to opt out of promotional emails or cross- border data transfer (for Turkey) at any time.
  • Right to lodge a complaint - to contact the supervisory authority of your country (Roskomnadzor for Russia, KVKK for Turkey, the national data protection authority for EU countries).

To exercise any of these rights, please contact us at support@duolink.pro. We will respond within the time limit set by law (usually 30 days, which may be extended for complex requests).

8. Children and minors

Our service is not intended for persons under the age of 16, unless otherwise provided by the legislation of your country. In Turkey, the minimum age for independent use is 18 (users aged 13 to 18 require parental consent). In Russia, the minimum age is 14 with parental consent. If we learn that we have collected data from a child without verified parental consent, we will delete it immediately. Please notify us if you become aware of such a case: support@duolink.pro.

9. Cookies and similar technologies

Our website and application use cookies and similar technologies (pixels, SDKs) to:

  • Ensure the operation of the service (authentication, security);
  • Collect statistics (Google Analytics, Firebase);
  • Personalise advertising (if you have given consent).

You can manage cookie settings through your browser or via a special banner on the website. In mobile applications you can limit tracking in your device settings (iOS: "Allow Apps to Request to Track"; Android: "Opt out of Ads Personalisation"). Disabling some cookies may affect the functionality of the service.

10. Contact information for inquiries

For any questions related to the processing of personal data, please write to: support@duolink.pro

If you believe that your rights have been violated, you may contact the supervisory authority of your country:

  • Russia: Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) – rkn.gov.ru
  • Turkey: Kisisel Verileri Koruma Kurumu (KVKK) – kvkk.gov.tr
  • Europe: the list of national data protection authorities is available on the website of the European Commission.